Legal position

It is not specified in legislation that only trained and competent professionals should be authorised to practice under Patient Group Directions (PGDs).

However, the MHRA have advised that the original Department of Health guidance envisaged PGDs would only be used by fully trained health professionals and it is doubtful there was any expectation that they would be used for training purposes.

PGD use in training or competency assessment

NICE guidance

NICE Medicines Practice Guideline for PGDs provides good practice recommendations for individual people and organisations involved with PGDs, with the aim of ensuring patients receive safe and appropriate care and timely access to medicines, in line with legislation. Both organisations and individual practitioners have legal and governance responsibilities which are specified in the guidelines under a number of recommendations.

The NICE guidance states:

“1.7 Training and competency:

• 1.7.1 Identify the senior person in each profession who is responsible for ensuring that only fully competent, qualified and trained health professionals use PGDs.”

If an organisation decides to disregard NICE recommendations, in full or in part, it would be advised to formally note and record any justification for this non-compliance with NICE guidelines. It is also suggested that the organisation carries out a local risk assessment, documents any decisions and records any justification for non-compliance (with evidence to support the decision) at Trust Board level, in line with good governance procedures.

Examples in practice

The below are examples from practice where PGD use would not be acceptable – the principles should be applied to other training scenarios.

Joint injector training

A PGD cannot be legally used to allow a registered healthcare professional to undertake their joint injector training/competency as they are not fully trained and competent.  A prescription or Patient Specific Direction (PSD) would be required.

Progestogen-Only Intra-Uterine Device (LNG-IUD) fitting

A PGD cannot be legally used to allow a registered healthcare professional to undertake LNG-IUD fitting as part of their competency training to obtain a Faculty of Sexual and Reproductive Health (FSRH) Letter of Competence in Intrauterine Techniques as they are not fully trained and competent.  A prescription or PSD would be required.

Health Care Professionals Council advice

In 2019 the Health and Care Professions Council (HCPC) advised SPS that:

“Registrants are required to practice in accordance with HCPC standards having regard to other guidance for best practice, such as that produced by NICE. Registrants are expected to practice within the legal and ethical boundaries of their profession, ensuring that they only act within the limits of their knowledge, understanding and skills at all times. HCPC acknowledges the intent behind the legislation on PGDs and the position taken in the NICE guidance. Whilst the use of PGDs for training purposes is a matter for organisations, HCPC expects registrants to always make decisions which can be justified in the best interests of patients.”

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