Medicines and Medical Devices Bill

Written evidence submitted by the British Dietetic Association, the Royal College of Occupational Therapists, the British and Irish Orthoptic Society, the Society of Radiographers and the Royal College of Speech and Language Therapists (MMDB09)

Medicines and Medical Devices Bill

Public Bill Committee submission

Executive summary

Dietitians, occupational therapists, orthoptists, diagnostic radiographers and speech and language therapists are allied health professionals, regulated by the Health and Care Professions Council. These professions support people of all ages and stages of their life, improving their diagnosis, treatment and care and supporting them to have a better quality of life to achieve the outcomes they want. They work in a range of settings, including acute and community health services.

All of these professions currently hold some level of legal entitlement for supply and administration of medicines to patients.

Occupational therapists, orthoptists and speech and language therapists are legally barred from training to be either supplementary or independent prescribers. Diagnostic radiographers and dietitians are legally barred from training as independent prescribers.

Collectively, we think the Bill should be amended to enable:

supplementary prescribing rights training for occupational therapists; and

independent prescribing rights training for dietitians, occupational therapists, orthoptists, diagnostic radiographers and speech and language therapists.

With those prescribing rights we would be better able to support those services which can demonstrate a need to deliver the benefits of independent prescribing to patients. This would help to secure:

better support and more timely care;

improved patient safety;

reduced pressure on other professionals; and

improved system efficiency.

In response to a parliamentary question tabled by Geraint Davies MP in February 2020, the Government said that subject to parliamentary approval, the Bill will give it powers to extend prescribing responsibilities to new professional groups where it is safe and appropriate to do so. 1

We support that extension and our proposed amendment to the Bill would expedite it to help deliver better outcomes for patients and the system as we face a surge in demand on health services both now and in the future due to the COVID-19 pandemic.

This extension would also build on the ground work already undertaken by NHS England’s scoping exercise over the last few years on extending prescribing rights to our members and other professionals.

1. Proposed amendment to the Bill

1.1 The Explanatory Notes to the Bill state:

Regulations made under clause 1(1) and relying on clause 2(1)(i) could, for example, be used to allow additional healthcare professionals to be given appropriately restricted prescribing rights or to amend the exemptions to the requirement for a prescription.

1.2 Our amendment seeks to ensure that those regulations do give additional healthcare professionals those rights:

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(2) Regulations under section 1(1) made in relation to section (2)(i) must specify that (a) supplementary prescribing rights are granted to registered occupational therapists and (b) independent prescribing rights are granted to registered dietitians, registered occupational therapists, registered orthoptists, registered diagnostic radiographers and registered speech and language therapists.

2. Rationale for this amendment

2.1 Extending prescribing rights to additional healthcare professionals would help deliver:

better support and more timely care for the patients they work with, including enabling them to have more equitable access to treatment;

improved patient safety as we, as allied health professionals (AHPs), with appropriate expertise would be able to make decisions, rather than relying on junior clinicians signing off Clinical Management Plans (CMP);

decrease the number of Patient Group Directions needed, reducing time spent in developing, using and training for them;

bring prescribing expertise closer to the patient;

reduced pressure on other stretched professionals, including GPs; and

improved system efficiency, including through reducing the duplication of work amongst health professionals, potentially resulting in significant time and resource savings.

2.2 Extending prescribing rights to these professions will make a significant positive difference to those professionals’ and the wider health system’s ability to respond as swiftly and efficiently as possible to the predicted post-COVID-19 surge in demand on health services, including the rehabilitation and recovery of COVID-19 patients.

2.3 In addition, it would help support the many people in community settings with continuing, or newly diagnosed, conditions, not related to COVID-19. Many of these people may have lacked the support they need for weeks or months so there will be further significant demand on health services as they attempt to catch-up both in terms of diagnosis and treatment.

3. Why is this extension in prescribing rights needed?

3.1 Our members report to us that not having relevant prescribing rights currently results in less timely and poorer patient care, increased pressure on other professionals, including GPs, and inefficiencies in the use of time and precious resources, including financial ones.

3.2 Therefore, in addition to the positive benefits highlighted in the previous section, extending prescribing rights to dietitians, occupational therapists, orthoptists, diagnostic radiographers and speech and language therapists would help address some of the negative issues currently faced by them, their patients and the wider system.

3.3 Examples reported to us include:


Lacking independent prescribing rights, dietitians and clinicians are spending time developing Clinical Management Plans (CMP). Developing, continuously reviewing and ensuring CMPs are signed by both parties is a significant administrative time burden and costly as other clinicians’ unit costs are significantly higher than those of dietitians. It also delays patients access to treatment when clinicians are not available to sign these off.

Occupational therapists

Without supplementary and independent prescribing rights, occupational therapists currently have to pass their patients to other clinicians for the prescribing of medicines. Occupational therapists can then supply and administer that medicine. This duplicates work and is more time consuming and delays patients’ access to treatment.


Ophthalmology is the largest speciality in terms of outpatient attendances, resulting in recognised capacity issues. Orthoptists are ideally placed to address this, as they already have the skills and knowledge to work within extended practice in this area. However, they are limited by not having independent prescribing rights, prolonging the patient journey and adding pressure to the ophthalmologists and GPs required to prescribe the necessary medicines.

Diagnostic radiographers

Consultant diagnostic radiographers and advanced practitioner radiographers deliver an increasing number of independent interventions to patients. They rely heavily on Patient Group Directions (PGD) as they cannot currently independently prescribe medicines. Best practice supports medicines being prescribed as the safest way for patients to receive medicines. If no prescriber is available, where patients fall outside of a PGD, the patient may be rebooked or face significant delay. This increases the administrative burden and delays diagnosis or treatment for the patient.

Speech and language therapists

Without independent prescribing rights, speech and language therapists have to ‘hand-off’ a prescription to a different prescriber, for example a GP. A conservative estimate if the speech and language therapist is on-site with the clinician suggests that this action adds 10 minutes to the prescribing process. If this happens daily to one speech and language therapist, this equates to 50 minutes per week per therapist, as well as the time to the prescriber with the patient taking longer to receive treatment. If the other clinician is off-site, for example a GP, it can sometimes take days. In addition, for those patients with eating and drinking difficulties (dysphagia), the current situation increases risks to their safety, including adverse effects such as aspiration pneumonia or reflux and the risk of increased hospital admissions.

4. Which medicines would extending prescribing rights enable us to prescribe?

4.1 Extending prescribing rights to us would enable us to provide our patients with a range of medicines or interventions which currently have to be prescribed by other professionals.


Medicines and interventions that dietitians with supplementary prescribing are currently prescribing include, but are not limited to, phosphate binders, diabetes medication, pancreatic enzyme replacement therapy and parenteral nutrition.

Occupational therapists

If occupational therapists had independent prescribing rights, the medicines they would be able to prescribe would include botulinum toxin, anti-inflammatory, pain relief, steroid injections and anti-depressants.


Independent prescribing rights would enable orthoptists to prescribe medicines for a range of ocular conditions, including in the treatment of glaucoma and patients presenting in emergency eye clinics.

Diagnostic radiographers

With independent prescribing rights, appropriately educated and trained diagnostic radiographers, would prescribe according to their scope of practice. This w ould include amongst other medicines intravenous or oral contrast agents for diagnostic examinations, local anaesthesia for interventional procedures such as biopsies, steroids for intra articular joint injections and beta blockers for cardiac examinations.

Speech and language therapists

With independent prescribing rights, the medicines speech and language therapists would be able prescribe include medication for swallowing difficulties (dysphagia) and reflux management – for example, Omeprazole , anti-fungal medication in laryngectomy , medication for pain , creams for on-treatment radiotherapy skin , medication for mouth of gut soreness and inflammation (mucositis) which is a common side effect of chemotherapy and radiotherapy and prescription items such as Therabite – a hand held device to stretch a user’s jaw.

5. Who has prescribing rights now?

5.1 Supplementary prescribing is a voluntary prescribing partnership between the independent prescriber and the supplementary prescriber , and in order to implement, requires a patient specific Clinical Management Plan with the patient’s agreement. Supplementary prescribers are required to take the same masters-level education as independent prescribers.

5.2 Currently, dietitians and diagnostic radiographers are able to train to be supplementary prescribers.

5.3 An independent prescriber is a health professional responsible and accountable for the assessment of patients with undiagnosed and diagnosed conditions and for decisions about clinical management, including the prescription of medicines.

5.4 Currently, the following professionals are able to train to be independent prescribers: nurses, pharmacists, optometrists, physiotherapists, podiatrists, therapeutic radiographers and paramedics.

5.5 Some health professionals have supply and administration rights through the Patient Specific Direction and/or the Patient Group Direction process. These include occupational therapists, orthoptists, diagnostic radiographers and speech and language therapists who are able to supply and administer a medicine or intervention prescribed by another clinician.

6. Which people will be better able to support with prescribing rights?

6.1 As allied health professionals, we have the expertise and experience of working with people of all ages and with a range of conditions. Having prescribing rights will enable safer, more efficient patient care. This table highlights our role and some of the care pathways we work in.


Dietitians advise people and help them make informed and practical choices about their food and nutrition. They assess, diagnose and treat dietary and nutritional problems. They also teach and inform the public and health professionals about diet and nutrition.

Relevant key pathways that dietitians are involved in include diabetes, cystic fibrosis, gastrointestinal disorders, renal disease and cancer.

Occupational therapists

Occupational therapists work with people who have difficulties carrying out daily activities because of disability, illness, trauma, ageing, and a range of long - term conditions.

Relevant key pathways that occupational therapists are involved in include stroke, mental health, progressive neurological conditions (such as dementia, motor neurone disease, multiple sclerosis and Parkinson’s disease) and musculoskeletal pain.


Orthoptists investigate, diagnose and treat defects of binocular vision and abnormalities of eye movement.

Relevant key pathways that orthoptists are involved in include paediatric ophthalmology, neuro ophthalmology, oculoplastics, cataract, glaucoma, emergency medical retina and vitreo-retinal and low vision, stroke, neurological or endocrine impairment or patients who frail and/or at risk from falls.

Diagnostic Radiographers

Diagnostic radiographers use the latest technology to look inside the body in different ways to work out what disease or condition is causing a patient’s illness. Advanced and Consultant radiographers may provide minimally invasive interventions. They work across all body systems, patient demographics and care pathways.

Relevant key pathways that diagnostic radiographers are involve d in include breast screening, assessment, diagnosis and follow up including biopsies , cardiac CT diagnostic services , minimally invasive procedures including line insertions and vascular access devices , intra articular joint injections under Ultrasound control , CT and MRI examinations using intravascular and oral contrast agents for cancer and other pathways.

Speech and language therapists

Speech and language therapists provide life-changing treatment, support and care for children and adults who have difficulties with communication, or with eating, drinking and swallowing.

Relevant key pathways that speech and language therapists are involved in include cancer, particularly head and neck cancer, voice, Ear, Nose and Throat, learning disability, brain injury, stroke, and progressive neurological conditions (such as dementia, motor neurone disease, multiple sclerosis and Parkinson’s disease).


1 Speech and Language Therapy: Prescriptions: Written question – 18438:

May 2020


Prepared 10th June 2020