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Section 4 – Clinical Governance

Patient safety is of paramount importance within all aspects of prescribing, supply and administration of medicines. Radiographers must practise within the law, to a high professional standard, and ensure that they strive continuously to improve the quality of care that they offer to patients. Poor professional performance needs to be identified and rectified at an early stage.  The guidance in this section will apply alongside any organisational policies and/or procedures that the organisation may have in place.

Employing authorities, both within the NHS and private/independent sector have clinical governance arrangements in place including protocols,   procedures and clinical audits. Radiographers must ensure that clinical governance is appropriate and work within them.

Practice Guidance 35: Governance structures  

35.1 You must follow the governance arrangements that are in place. Arrangements should be in place for: 

  • clear lines of responsibility and accountability for overall quality of clinical care 
  • development of quality improvement programmes such as clinical audit, supporting evidence-based practice, implementation of clinical standards, monitoring of clinical care, access to appropriate CPD programmes 
  • management of risk 
  • procedures to identify and remedy poor performance 
  • Competency frameworks for prescribing.

Practice Guidance 36: Clinical audit 

36.1 Clinical audit is an important part of clinical governance and independent and supplementary prescribing activities should be audited separately. 

36.2 You should audit how many of the patients you prescribed medication for. You should also audit the patients you took an active decision not to prescribe for. You should monitor how patients respond to treatment and how many follow-up visits are taking place. Systems should be put in place to ensure that patients who do not attend (DNA) for their appointments are followed up (eg by telephone, letter, text message or email).

36.3 If you are working outside NHS settings, where clinical governance systems may be different or may not be applied in the same way, you must ensure you comply with requirements to demonstrate your competence to practice. For example, that you are able to show how you audit your practice, keep up-to-date with current guidance and how you safeguard the patients in your care. 

36.4 You should ensure that the prescriptions you write are clear and legible. You should audit how many times a pharmacist contacts you to query what was written. 

36.5 You should seek your patients’ experiences of your prescribing where possible. 

Practice Guidance 37: Prescribing analysis 

37.1 You should ensure that you have information about national guidelines (e.g. NICE guidelines, National Service Framework documents), local guidelines, local agreements and formularies to ensure you make the best prescribing decision for your patients.

37.2 If you are prescribing within the NHS, your activity should be included in the reports on the quality of clinical care to the local Medicines Management Committee (or its equivalent).

Practice Guidance 38: Learning from incidents and errors 

38.1 You should record all incidents and/or errors with your local reporting systems to facilitate national reporting where required.

38.2 You should review incidents within your local team and/or medicines management committee (or equivalent) to enable learning and, where necessary, change practice.

Practice Guidance 39: Risk management 

39.1 You should ensure that you have an appropriate risk management programme in place. This should include clinical risk management and patient safety (including the National Reporting and Learning Service ), confidentiality, safety of prescription pads and a system for handling errors and complaints. 

Practice Guidance 40: Continuing professional development 

40.1 You must remain up-to-date with appropriate knowledge and skills to enable you to prescribe competently and safely within your scope of practice.

40.2 You should ensure that your prescribing CPD is in line with your current or future practice, including your role as a prescriber.

40.3 You should record your CPD in a format that easily enables you to demonstrate your fitness to practise as a prescriber.

40.4 You should ensure that you set aside sufficient time to access programmes and resources to meet your prescribing CPD needs. This may include Peer Review sessions. You should include reflective learning in your CPD portfolio and feedback from multiple sources and professions. 

Practice Guidance 41: Poor performance 

41.1 You should be aware of the procedures place for identifying poor prescribing practice.

Practice Guidance 42: Safety of NHS prescription pads 

42.1 NHS FP10’s are classed as secure stationery. Each prescription has a serial number, and has specific anti-theft and anti-forgery features. Prescription pads will be ordered by the Trusts via a secure ordering system and supplied to the named professional they relate to. You are responsible for the safety of your named prescription pad. You must take all reasonable and responsible steps to prevent its loss or inappropriate use. You should only use one prescription pad at a time. 

42.2 You should keep a record of the first and last serial number of the prescriptions in the pads issued to you. If a whole prescription pad is lost or stolen you must report the serial numbers of the missing prescriptions.

42.3 At the end of each working day you should record the serial number of the first remaining prescription in your current pad. If your current pad is lost or stolen after you last used it, the relevant serial number of unused prescriptions must be reported.

42.4 Prescription pads should be stored in locked areas when not in use. You should not store prescription pads away from your place of work. In particular you should not store pads at home or in your vehicle except when travelling between places of work.

42.5 You must never print off blank prescriptions in advance and then store them for future use.

43.1 If you have a commercial or financial interest in any pharmaceutical product or company then you should ensure that your patients have access to this information where relevant, and you should ensure that your interest does not affect your ability to prescribe in the patient’s best interest alone.

43.2 You must not allow your own, or your employer’s (if applicable) commercial or financial interests in a pharmaceutical company or product influence the way you advise your patients.

43.3 You must declare any conflict of interest in a ‘register of interests’ either within your personal portfolio, or within your employers Hospitality Register which should be produced on request for audit purposes.

Practice Guidance 44: Gifts and benefits 

44.1 Your prescribing choice for your patient must be based solely on clinical suitability and cost effectiveness, working within any local formulary that you may be obliged to follow.

44.2 The advertising and promotion of medicines is strictly regulated. You must not accept personal gifts that are given to influence your prescribing activity, nor must you solicit or accept a gift or inducement to influence your prescribing patterns. 

44.3 You may accept hospitality for a professional or scientific meeting, but such hospitality must be reasonable in level, and subordinate to, the main purpose of the meeting. This should be declared in the register of interests. Guidelines are provided by The Association of the British Pharmaceutical Industry9

44.4 You may accept awards and/or grants to attend educational events offered by pharmaceutical companies that enable you to undertake CPD relevant to your practice.

44.5 You must follow your employer’s policy on receiving gifts and hospitality. If you do not have an employer you must consider whether it is appropriate to accept gifts or hospitality in response to your prescribing activities.

Practice Guidance 45: NHS/ Private Practice prescribing boundaries 

45.1 You must not ask the patient’s GP to prescribe medicines at NHS expense which are subsequently to be administered as part of private healthcare provision. If you do ask a GP to do this, they are within their rights to refuse to do this.

Practice Guidance 46: Checking registrations and annotations 

46.1 You must provide evidence of your valid registration as a Radiographer with the HCPC to your employer / those using your prescribing services

46.2 You should provide evidence of your valid status as an independent and/or supplementary prescriber annually to your employer / those using your prescribing services.

46.3 You must only prescribe in accordance with the type of annotation awarded to you.

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