Guidance for Prescription Security in Primary Care Information for General Dental Practices Pharmacy and Medicines Management Team October 2017
Contents 1. Introduction...3 2. Prescription Security Procedures and Protocols...4 3. Register of Prescriptions Forms.. 4 4. Ordering New Prescription Forms... 5 5. Receipt of Prescription Forms... 5 6. Issue of prescription Forms... 5 7. Storage of Prescription Forms.6 8 Stolen /missing prescriptions 7 9. Preventing the alteration of written prescriptions...8 10. Disposing of obsolete prescription forms...8 11. Audit of prescription security 9 12. Appendix 1 10 13. Appendix 2..11 14. Appendix 3..12 2
1. Introduction Theft and misuse of blank or legitimately completed HS21D prescriptions signed by an authorized practitioner is an area for concern as these forms can be used to obtain drugs, often controlled drugs, illegally for recreational use, unsupervised treatment of an illness or health condition, or for onward sale. Given current problems with drug misuse across Northern Ireland and potential adverse effects on the prescribing budget, it is essential that all prescribers and other staff who handle prescription forms are vigilant in adhering to procedures that reduce the risk of prescription theft and misuse. There are already a number of security measures that have been built into HS21D prescription forms to prevent theft and fraudulent use such as ultraviolet markings, coloured backgrounds and serial numbers. These are less effective if poor security measures allow theft of the forms in the first instance. The effective management of prescription forms e.g. how they are stored and accessed by authorized prescribing and non-prescribing staff is very important and there should be appropriate security policies, procedures and systems in place in each practice. This guidance has been designed to assist dental practices in developing their own procedures and systems to ensure the security of HS21D prescription forms held within the practice. While the detail of this guidance relates to health service prescriptions, the underlying principles should be considered as best practice for the security of private prescriptions in primary dental care 3
2. Prescription Security Procedures and Protocols The practice should have a written protocol signed up to by all staff outlining procedures for the management of prescription security. A log should be maintained in the surgery detailing information about prescriptions ordered, received and taken for use Nominated person(s) should be appointed to take responsibility for prescription security procedures e.g. Practice Manager (PM) All staff should be made aware of prescription security procedures through training. A list of those staff members trained and date of training must be kept. Processes must be in place to ensure that new staff and deputies are made aware of the procedures. Only appropriately trained staff should be allowed to generate prescriptions Passwords should not be shared. Computer generated prescriptions can be identified by an audit trail An annual review should be carried out to ensure appropriate systems are in place and are being adhered to. The following issues should be considered when developing procedures for HS21D prescription forms and in the day-to-day management of prescription forms 3. Register of Prescription Forms A register formally recording the ordering, receipt and issue of prescription forms must be kept. Serial numbers for prescriptions received and issued should be recorded. See Appendix 1 A register should include details of the following for each prescriber /cypher number: - Date of order and name of person placing the order - Number of prescriptions ordered 4
- Name of person who received and stored prescriptions and date received - Quantity/Serial numbers of prescriptions received - Name of prescriber on the prescription - Date, quantity and serial numbers issued for use - Person who removed the pads from store 4. Ordering New Prescription Forms All NHS prescriptions should be ordered from DLRS (NI) Ltd. Order forms can be downloaded from the Business Services website www.hscbusiness.hscni.net/services/1944.htm A copy of the order form should be kept in a designated file. If a delivery is not received, DLRS (NI) Ltd should be contacted via their helpdesk (Tel: 028 92622999). 5. Receipt of Prescription Forms Deliveries should be signed for by a nominated and trained member of practice staff. As this signature is obtained electronically by the courier and there is no paper delivery note, it is imperative that a check is carried out on each pack to ensure the delivery is for the correct practice and practitioner. The person signing for the delivery should ensure the person who placed the order is informed. Entries should be made on the prescription log sheet (Appendix 1) 6. Issue of prescription forms When a new supply of prescriptions is issued for use to a prescriber, entries should be made on the appropriate section of the prescription log sheet (Appendix 1). 5
Unused forms must be returned at the end of any employment period (e.g. day or week). The returned formed should be returned to secure storage and a record made in the prescription log sheet (Appendix 1). The prescription log for each pad should not be stored with unused forms/pads Deputies - only one working pad should be kept for use by deputies. When prescriptions are issued, all the details should be recorded on the locum prescription log sheet (Appendix 2) 7. Storage of Prescription Forms Unused forms should be kept in a secure locked area to which access is kept to a minimum number of nominated people A named person (e.g. practice manager) should be responsible for checking prescription storage and registers at regular intervals. This should include obtaining assurances from all practitioners working in the practice including deputies (locums) that unused forms in their possession are still secure. Forms should be stored in chronological order of delivery to facilitate audit/review It is good practice for only one working pad per practitioner to be in use at any one time Forms should not be left visible, unattended or unsecured at any time in the practice. All forms should be kept in a locked drawer/cabinet in the practice when not in use. Prescription forms should be secured when a practitioner leaves the room regardless of the reason or length of time. Domiciliary visits - When carrying out domiciliary visits, practitioners should only use an appropriate number of prescription forms for the visit. Serial numbers should be pre-recorded in the prescription log before departure and re-checked on arrival back at the practice. 6
8. Stolen/ Missing Prescriptions Theft of prescriptions can occur with either blank and/or completed prescriptions and as such prescription security requires constant vigilance. If a stolen prescription is presented for dispensing, this is a false representation and will become a fraud investigation. If prescriptions are stolen or missing, the practice should notify: Contact PSNI Call local police service on 101 Contact BSO Counter Fraud and Probity Services (CFPS) Contact via HSC Fraud Hotline 0800 096 3396 or online at https://cfps.hscni.net/report/ Contact HSCB Relevant Assistant Business Support Manager for your area: Belfast & South East Denise Taylor denise.taylor@hscni.net or Seán Woods sean.woods@hscni.net 028 95 363926 North Marlene Drummond marlene.drummond@hscni.net or 02895 362823 South Andy Gregg andrew.gregg@hscni.net or 02895 362084 West Tom Coyle tom.coyle@hscni.net or 02895 361052 Missing/Stolen prescriptions for Controlled Drugs must always be reported to the HSCB Accountable Officer by contacting your local medicines management office. Assume lost prescriptions are stolen until evidence is available to the contrary. There is an obligation on each prescriber to check if the volume of their pad is going down unexpectedly. The risk of forms being stolen or going missing can be reduced if they are taken out of store only a few at a time. 7
9. Preventing the alteration of written prescriptions Prescriptions obtained in good faith by members of the public can be fraudulently altered in two ways, the number associated with the medication to be dispensed is altered to increase the quantity or strength extra medication is added to the prescription. The patient may either be obtaining the medication to consume themselves or to sell onto others. In order to prevent the unauthorised addition of medication it is recommended that the unused section of the prescription form is endorsed with a large X. 10. Disposing of obsolete prescription forms In some circumstances, blank prescription forms will become obsolete and must be destroyed, for example: The prescriber leaves or retires from the practice Obsolete prescription forms should be destroyed according to the practice s confidential waste policy and records kept of the destruction. A record should be kept of forms destroyed (including start and end serial numbers), date and method of destruction, signature of authorising GDP and signature of person doing the destroying. 8
11. Audit of prescription security A nominated individual (e.g. Practice Manager) should carry out a monthly reconciliation of the prescription register. An annual audit of prescription security using the HSCB Audit Tool is also recommended (Appendix 3 Dental Prescription Security Audit Tool July 2017) Any adverse incident should be reviewed promptly by relevant members of the practice team and appropriate actions taken, including notification of other agencies as required (see section 8). A record of the adverse incident should be made and submitted to the HSCB to allow learning from incidents to be shared. 9
Appendix 1 Prescription Log Sheet Prescriber Cypher No. Date ordered Ordered by Method of order Date received Serial numbers Stored by Date taken for use Taken by Given to(dentist name) 10
Appendix 2 PRESCRIPTION LOG SHEET DEPUTY (LOCUM) PRESCRIPTIONS Date taken for use Taken by Given to: (Locum name) Session details Name of practitioner on form Number of scripts Serial numbers issued Serial numbers returned 11
APPENDIX 3 Dental Prescription Security Audit July 17 12
PRESCRIPTION SECURITY AUDIT INTRODUCTION Theft and misuse of blank or legitimately completed prescriptions signed by an authorized practitioner is an area for concern as these forms can be used to obtain drugs, often controlled drugs, illegally for recreational use, unsupervised treatment of an illness or health condition, or for onward sale. It is essential that all prescribers and other staff who handle prescription forms are vigilant in adhering to procedures that reduce the risk of prescription theft and misuse. AIMS OF THE AUDIT To ensure the effective secure management of prescription forms within the dental practice. CRITERIA The criteria questions have been divided up in to sections addressing various issues. 1. Procedures Criteria Method Comments/ Does the practice have a written protocol for the management of prescription security? Documentation Question staff Examples Is it signed up to by all staff? 13
Is there a nominated person(s) appointed to take responsibility for prescription security procedures? Does regular training on prescription security procedures occur with all staff members? Are registers recording the ordering, receipt and use of prescription forms kept? Documentation Question staff Question staff Documentation Do the registers include details of the following: Date, method and name of person placing the order? Documentation Number of prescriptions ordered? Quantity/Serial numbers of prescriptions received? Person who received and stored? Name of practitioner on the prescription Date and quantity/serial numbers issued for use? 14
Person who removed from store? Practitioner they will be used by? 2. Ordering Criteria Method Comments/ Examples When ordering new prescription forms Documentation are the following records kept, The name of the person who places the order? The date of the order? The number of prescriptions ordered? The name of the practitioner whose prescription pad was ordered? Are deliveries signed for by a nominated trained member of the practice staff? Are deliveries checked against the order to ensure it matches the original order including the correct address for the practice and practitioner name(s)? Documentation Question staff Question staff 15
3. Storage Criteria Method Comments/ Examples Are unused forms kept in a secure Documentation locked area to which access is kept to a minimum number of nominated Question staff people? Do regular checks occur on Question staff prescription storage and registers at regular intervals? Are forms left unattended or unsecured at any time in the practice Question staff 4. Missing / stolen prescriptions Criteria Method Comments/ Examples Does the practice have a procedure for Documentation dealing with missing prescriptions? Does the practice have a procedure for Documentation dealing with stolen prescriptions? 16
5. Disposal of obsolete prescriptions Criteria Method Comments/ Examples Does the practice have a procedure for Documentation dealing with disposing of obsolete prescription forms? 17
STANDARDS 100 for each criteria METHOD This audit should be carried out by the practice manager or clinical governance lead for the practice. The questions should be asked in relation to existing practice policies and procedures concerning all aspects of dealing with prescription forms including ordering and security. RESULTS When recording the results, Yes equates to 100 No equates to 0 For questions that have multiple parts then each part equates to a percentage e.g. for the question, Do the registers include the following details : Date, method and name of person placing the order? Number of prescriptions ordered? Quantity/Serial numbers of prescriptions received? 18
Person who received and stored? Name of practitioner on the prescription? Date and quantity/serial numbers issued for use? Person who removed from store? Practitioner they will be used by? Each yes / no answer is equivalent to 12.5 19
RESULTS SUMMARY SHEET Five Audit criteria 1.Procedures Does the practice have a written protocol for the management of prescription security? Percentage Standard set 50 Is it signed up to by all staff? 50 Is there a nominated person(s) appointed to take responsibility for prescription security procedures? Does regular training on prescription security procedures occur with all staff members? Are registers recording the ordering, receipt and use of prescription forms kept? Total Total 100 100 100 100 20
Do the registers include the following details Date, method and name of person placing the order? Number of prescriptions ordered? Quantity/Serial numbers of prescriptions received? Person who received and stored? Name of practitioner on the prescription? Date and quantity/serial numbers issued for use? Person who removed from store? Practitioner they will be used by? 12.5 12.5 12.5 12.5 12.5 12.5 12.5 12.5 Total Total 100 21
2. Ordering When ordering new prescription forms are the following records kept, The name of the person who places the order? The date of the order? The number of prescriptions ordered? 25 25 25 The name of the practitioner whose prescription pad was ordered? 25 Are deliveries signed for by a nominated and trained member of the practice staff? Are deliveries checked against the order to ensure it matches the original order including the correct address for the practice and practitioner name(s)? 3. Storage Are unused forms kept in a secure locked area to which access is kept to a minimum Total Total 100 100 100 22
number of nominated people? 100 Do checks occur on prescription storage and registers at regular intervals? 100 Are forms left unattended or unsecured at any time in the practice? 100 4. Missing /stolen Prescriptions Does the practice have a procedure for dealing with missing prescriptions? Does the practice have a procedure for dealing with stolen prescriptions? 50 50 Total Total 100 5. Disposal of obsolete prescriptions Does the practice have a procedure for disposing of obsolete prescription forms? 100 TOTAL 100 23
Grading System >90 achieved per section. LOW RISK Current system working well. Very minor changes / additions to existing security protocol 70-90 achieved per section MEDIUM RISK Standards broadly achieved but some sections need to be reviewed < 70 achieved per section HIGH RISK Standards not addressed, need for complete review of section ACTION PLAN What steps should you take to improve prescription security? Formulate a plan to modify the areas where current practice does not meet the standards set. Consider how to address all missing factors. Set a timescale for implementing change and reviewing your actions. Agree and document what needs to be done, by whom, and by when 24