Unvarnished: Newest Regs Don't Simplify Prescribing for DCPs

Unvarnished: Newest Regs Don’t Simplify Prescribing for DCPs

When the last government were talking up their dental recovery plan, the Under-Secretary of State for Primary Care, Andrea Leadsom, said that it would make dentistry, “Faster, simpler and fairer.”

A major part of the plan depends upon dental hygienists and therapists making better use of their full scope of practice. There are a variety of impediments to this, one of which has been their inability to independently supply and administer some fairly fundamental products. If skill mix was to be any more than an empty slogan this anomaly needed to be rectified. NHS England have now issued their guidance on a potential workaround. At first sight it looks like a rather circuitous short-cut.

The Human Medicines Regulations 2012 had left a situation where key groups of dental professionals could not personally supply and administer specified medicines without requiring a patient specific direction (PSD) from a dentist, or a patient group direction (PGD). Restricted products included the most commonly used local anaesthetics, fluoride varnish and the 2800ppm and 5000ppm fluoride toothpastes.

Despite lobbying for legislative changes to deal with this anomaly, there was little progress for over a decade. The complexities of setting up a PGD in practice meant that in most cases it fell upon a dentist to provide a PSD.

The problematic 2012 regulations were finally amended in June 2024. The good news is that this provides a route for dental hygienists and dental therapists to personally supply and administer specified medicines without requiring a PSD from a dentist, or a PGD. The not quite so good news is that the NHS England guidance runs to over 4000 words.

It is immediately made clear that, “the amendments do not allow independent prescribing.” Delegation of the administration or supply under these exemptions to another member of the dental team is not permittedThe example is given that, asking a dental nurse or a dental practice receptionist to give a pack of sodium fluoride toothpaste to a patient is not allowed.

The guidance states that practices may continue to use PSDs, however the use of PGDs will need to be phased out within their 3 year life. Some form of formal risk assessment would appear to be required to meet the expectation that there has been, “an assessment of intended and unintended consequences, (and that) the benefits to patient care outweigh any risks.”

There is a requirement that those wishing to use the exemptions undertake further training and details of this are provided later in the guidance.  An e-learning module that will meet this need is promised, but not expected until November.

DCP’s are reminded that they will need to check that their indemnity specifically has arrangements in place to cover the use of exemptions for their practice.

There is a good deal more covering amongst other areas, labelling, patient management, record keeping, consent and storage.

Dental hygienists and therapists, reading this guidance will come to their own conclusions of whether it is “faster, simpler and fairer.”

NHS England » Supply and administration of medicines by dental hygienists and dental therapists

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Tony Smith
Unvarnished: newest regs
Another excellent article pointing out the lack of joined up thinking in helping to improve access to dental health. While on the one hand the oral health apprenticeship allow applying a varnish (SDF?) and taking radiographs as well as scanning with advances in AI can provide an assessment for children and the elderly, and the trained nurse apply to palliative care as well as or hygiene instruction.
The dental team could be central to delivering care, we just need to be proactive. No rush, while level 4 funded oral health apprenticeships are available, the awareness and take up is minimal in the 7 training centres available for our 60,000+ dental nurses.

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Gravatar
Tony Smith
Another excellent article pointing out the lack of joined up thinking in helping to improve access to dental health. While on the one hand the oral health apprenticeship allow applying a varnish (SDF?) and taking radiographs as well as scanning with advances in AI can provide an assessment for children and the elderly, and the trained nurse apply to palliative care as well as or hygiene instruction.
The dental team could be central to delivering care, we just need to be proactive. No rush, while level 4 funded oral health apprenticeships are available, the awareness and take up is minimal in the 7 training centres available for our 60,000+ dental nurses.

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