Pharmacy technicians and Patient Group Directions — what pharmacists need to know

Legislation has been introduced to permit registered pharmacy technicians to supply and administer medicines under Patient Group Directions (PGDs). 

Here, our Head of Healthcare Richard Hough and Solicitor and practising pharmacist Thorrun Govind share what pharmacists need to know from a legal perspective.

This article was originally published in the Chemist and Druggist on 29 August 2024.

What are PGDs?

PGDs are written instructions that allow healthcare professionals specified within the Human Medicines Regulations 2012 (HMRs) to supply and/or administer a medicine directly to a group of patients with an identified clinical condition. It’s a common misconception that PGDs are a form of prescribing — they make one named healthcare professional responsible for assessing a patient and supplying or administering a medicine to them. They can be useful where assessment and treatment follow a clearly predictable pattern.

Those who require treatment but fall outside the pre-defined patient group in the PGD are referred to independent prescribers for individual assessments.

PGD's have been developed by multi-professional groups with extensive expertise. After implementation, they are subject to ongoing monitoring.

Training requirements for the healthcare professional are defined in the PGD.

Who do the amended provisions apply to?

Following a UK-wide public consultation held from 18 August to 29 September 2023, the Amendments to the HMRs came into effect from 26 June 2024. 

The amended provisions apply to registered pharmacy technicians across England, Wales and Scotland. However, in Northern Ireland, pharmacy technicians aren’t registered healthcare professionals. If this changes in future, a further amendment to the HMRs may be made so that they can use PGDs.

PGDs in practice — how do they work?

To practice using a PGD, healthcare professionals must have completed any training outlined in the PGD and be deemed competent and authorised by the provider organisation. They should also determine whether they have the appropriate knowledge and skills to use a relevant PGD. 

Even though the law will change, there will be no immediate impact on the provision of community pharmacy services. Any updates to services would first need to be considered in negotiations between national negotiating bodies, the Government and NHS. Where agreed, the relevant service directions and specifications would then be amended. 

Despite the legislation having been introduced, there’s still debate within the profession about the impact it will have. As a starting point, pharmacy technicians in Great Britain are regulated by and accountable to the General Pharmaceutical Council (GPhC). As with pharmacists, the GPhC has the authority to set standards, maintain a register, quality assure education and investigate complaints regarding pharmacy technicians. Pharmacy technicians are also required to revalidate annually.

PGDs are developed by multi-professional groups with extensive expertise and require significant time and resource to develop and implement. While it may appear odd that pharmacy technicians have been able to author PGDs but unable to follow them, it will be up to responsible pharmacists and superintendent pharmacists to consider which PGDs are suitable for use by pharmacy technicians. 

Each registered pharmacy must have a responsible pharmacist whose role is to secure the safe and effective running of the registered pharmacy when it’s operational. It’s the role of the responsible pharmacist to determine exactly how PGDs operate while they’re in control of a pharmacy.

Representative organisations agree that if the role of the pharmacist in the community pharmacy setting is to develop and flourish, an extended role for pharmacy technicians is necessary. However, it appears that there is more work to be done to ensure that grassroots pharmacists are on the same page — especially given that responsible pharmacists will be key to unlocking the use of PGDs by pharmacy technicians in the community. 

This a unique case of the law changing but practice not necessarily moving at the same pace.

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