What is a PGD?

PGDs are a written instruction, which 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 is a common misconception but PGDs are not 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.

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Those who require treatment, but who fall outside of the pre-defined patient group within the PGD, are referred to an independent prescriber for an individual assessment. Developed by multi-professional groups with extensive expertise, once implemented they are subject to ongoing monitoring. Training requirements for the healthcare professional are defined in the PGD.

Legal changes

Following a UK-wide public consultation that was held from 18 August to 29 September 2023, these Amendments to the HMRs came into effect from 26 June 2024. The amended provisions cover registered pharmacy technicians across England, Wales and Scotland. In Northern Ireland however, pharmacy technicians are not a registered healthcare profession. Should they become so, a further amendment to the HMRs may be made so they can also use PGDs.

Practicalities

To practise using a PGD, healthcare professionals must have completed any training outlined in the PGD and have been deemed competent and authorised by the provider organisation. The individual should also determine whether they have the appropriate knowledge and skills to use a relevant PGD. However, whilst the law will change, there will be no immediate change in the provision of community pharmacy services.

Any updates to services would first need to be considered in negotiations between national negotiating bodies, Government and the NHS and, where agreed, the relevant service directions and specifications would then be amended.

Read more: Private services steam ahead with pharmacy technician PGD use

Despite the legislation having been introduced, there does continue to be debate within the profession about this legislation and the impact it will have. As a starting point, pharmacy technicians in Great Britain are regulated by the GPhC and accountable to them.

The GPhC has the power to set standards, maintain a register, quality assure education and investigate complaints regarding pharmacy technicians, just like pharmacists. Pharmacy technicians are also required to revalidate yearly.

PGDs are developed by multi-professional groups with extensive expertise and require a significant amount of time and resource to develop and implement. It does appear incongruous that pharmacy technicians have been able to author PGDs but not be able to follow them. However, it will be for 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 is operational. It is the role of the responsible pharmacist to determine exactly how PGDs operate whilst they are in control of a pharmacy.

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Representative organisations agree that if the role of the pharmacist in the community pharmacy setting is to develop and flourish, then an extended role for pharmacy technicians is necessary. However, it appears that there is much work to be done in this instance to ensure that grassroots pharmacists are on the same page. Particularly 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.