Health Professionals
5 December 2007
To further strengthen governance arrangements for controlled drugs supplied privately, from 1 January 2008 the name and address of the supplier of all Schedule 1, 2 and 3 CDs must be recorded indelibly on the private requisition and the original form forwarded by the supplier to NHS National Services Scotland (NSS) for analysis. In the case of pharmacy supply, a pharmacy stamp which includes the full name and address of the pharmacy can be used so long as the information is clear and legible. Information derived from these private requisition forms will be made available to NHS Boards and their Accountable Officers for monitoring purposes.
In Scotland, the new arrangements for private requisitions build on the NHS stock order system whereby authorised practitioners obtain supplies of medicines and appliances from community pharmacies for e.g. the immediate treatment of patients. The changes will not apply when supplies are made from other settings such as from hospitals, pharmaceutical wholesalers and manufacturers. Procedures already in place in these organisations are considered to safeguard against the risk of diversion.
For private requisitions a 'standard' form has been designed - CDRF - which will carry the same security features as NHS and private CD prescription forms, including a unique serial number.
The Misuse of Drugs Regulations already permit such requisitions to be computer generated or handwritten. However, the signature of the person ordering the CDs must be handwritten. In exceptional circumstances, where for example an individual has difficulty accessing the 'standard' CDRF, a CD can be supplied in response to an order written on a non-standard form providing all the legal requirements are met.
The current NHS stock order form (GP10A) in use in Scotland already meets the new MDR requirements therefore these arrangements will continue unchanged. However, it is good practice to use a separate GP10A for schedules 1, 2 and 3 controlled drugs.
Those wishing to obtain a supply of CDRFs must register with the local NHS Board as a private prescriber. For those who are not already registered, completed application forms should be sent to their NHS Board.
Completed application forms will be forwarded by the Board to NSS who will allocate the practitioner with an NSS private prescriber code. Where available, existing NHS prescriber codes will be used. Importantly, if a practitioner works out of more than one practice s/he will require a prescriber code for each practice. NSS will notify the Board of all private prescriber codes.
Supplies of CDRF forms can be ordered by the NHS Board from NSS Practitioner Services Division using the PSD Order Form.
Ordering and invoicing arrangements will be decided by the Board. The Board will invoice the private practitioner or their employer for the cost of supplying the forms. These arrangements mirror those already in place to enable private prescribers to obtain supplies of private CD prescription forms.
From 1 January 2008, dispensed forms CDRF (originals not copies) must be forwarded to NSS Practitioner Services for analysis.
Forms dispensed in one month should be submitted by the 5th working day of the following month and should be covered by submission document CD34.
Supplies of CD34 forms can be obtained from:
Practitioner Services
3 Bain Square
Livingston
EH54 7DQ
Tel: 01506 705100
Although not a legal requirement, where one community pharmacy supplies another with CDs privately it is good practice for the pharmacy supplying the CDs to submit a written CDRF(CP) to NSS Practitioner Services for processing. Supplies of CDRF(CP) can be obtained from:
Practitioner Services
3 Bain Square
Livingston
EH54 7DQ
Tel: 01506 705100
The security of prescription stationery (NHS or private) is the responsibility of the NHS/employing organisation and the practitioner. It is good practice to record the number of the next unused form at the end of the working day. This will help to identify quickly any forms that are lost or stolen. Blank forms must never be pre-signed or left unattended.
Practitioners should report a suspected loss or theft of any prescription stationery to the local NHS Board as soon as the loss/theft is discovered. They should report the approximate number of prescription/requisition forms lost/stolen, their serial numbers and where and when they were lost/stolen. The Board should notify the Fraud Liaison Officer, who is responsible for informing local pharmacists and deciding on the action to be taken. The Fraud Liaison Officer should also notify Counter Fraud Services at the following address:
Counter Fraud Services
Earlston House
Almondvale Business Park
Almondvale Way
Livingston
EH54 6GA
Tel: 01506 705 200
Fax: 08000 15 16 28