Private prescribing: a workflow and governance checklist

What a private prescription must contain

A private prescription for a prescription-only medicine (POM) falls under regulation 217 of the Human Medicines Regulations 2012. A paper prescription must be written indelibly and signed in ink by you. It must include:

• your address
• the date
• the kind of prescriber you are (a doctor)
• the patient’s name and address
• the patient’s age, if they are under 12

It cannot be dispensed more than six months after the date. If you mark it as repeatable without saying how many times, it can be dispensed no more than twice (oral contraceptives are the exception).

Most GPs also add the medicine, strength, form, dose and quantity, and their GMC number and a contact phone number. This helps the pharmacist check the prescription is genuine.

Paper or private e-prescribing

The NHS Electronic Prescription Service (EPS) cannot carry private prescriptions. That holds even if your service has an NHS organisation code. See private prescribing and EPS.

A private prescription can still be electronic. Regulation 219 allows one that is created electronically, signed with an advanced electronic signature and sent electronically. Private e-prescribing services such as SignatureRx do this and send the prescription to a pharmacy that delivers it or has it ready for collection.

Route	Suits	Watch out for
Signed paper prescription	Low volumes, and patients who want to choose their own pharmacy	Lost or forged scripts, and pharmacies phoning to check. Keep a copy in the record.
Private e-prescribing service	Remote consultations and home delivery	Per-item fees, which pharmacies take part, and how it links to your record system
Private CD form (Schedule 2 and 3)	Controlled drugs	This must be paper, wet-signed and on the official form. The pharmacy must receive the original.

Controlled drugs

Regulation 15 of the Misuse of Drugs Regulations 2001 sets extra rules for private prescriptions of Schedule 2 and 3 controlled drugs:

• They go on the standard private CD form for your nation, not your own headed paper.
• They must show your six-digit private prescriber identification number. This is separate from any NHS prescriber number you hold.
• Prescriptions for Schedule 2, 3 and 4 drugs are valid for 28 days.
• NHSBSA strongly recommends no more than 30 days’ supply of Schedule 2, 3 and 4 drugs.

The electronic route in regulation 219 requires Schedule 2 and 3 drugs to go through EPS, which is NHS-only. In practice, a private Schedule 2 or 3 prescription is always on paper. SignatureRx says the same: these prescriptions must be printed on the private CD form and wet-signed, and the pharmacy needs the original before it dispenses.

Nation	Private CD form	Where to get a prescriber number and pads
England	FP10PCD	Your local NHS England controlled drugs team (NHSBSA’s guidance calls it the Area Team)
Wales	WP10PCD	Check with your health board’s controlled drugs lead
Scotland	PPCD(1)	Your NHS board. Forms are ordered through Practitioner Services.
Northern Ireland	PCD1	The Business Services Organisation, by application form

Some local teams ask private prescribers to complete a self-assessment before they issue pads, so apply well before you need them. Store the pads securely and keep a log of serial numbers.

Prescribing safely

• Use a UK drug dictionary. The Dictionary of Medicines and Devices (dm+d), maintained by NHSBSA, is the NHS standard for identifying medicines in clinical systems. A record system that checks prescriptions against dm+d or a similar database helps you catch interactions, allergies and dosing errors.
• Know the history. GMC guidance says that if you cannot see relevant information from the patient’s records, you must not prescribe controlled drugs or medicines liable to misuse, apart from narrow exceptions.
• Remote consultations. Tell the patient your name and role, and your GMC number if you are online. Stop and consider whether a remote consultation is safe, especially if the patient won’t let you share information with their GP.
• Yourself and people close to you. Avoid prescribing for them wherever possible. Never prescribe controlled drugs for them except in the narrow circumstances the GMC sets out.
• Report adverse reactions. The Yellow Card Scheme applies to private prescribers exactly as it does in the NHS.

Telling the patient’s NHS GP

The GMC expects you to ask for consent to contact the patient’s GP. When an episode of care ends, you must tell the GP about:

• changes to medicines, and the reasons for them
• how long treatment is intended to last
• monitoring, and who will carry it out
• new allergies or adverse reactions

If the patient refuses, explain the risks and record the conversation. If not sharing would be unsafe, don’t prescribe, and signpost them elsewhere. Some services, such as sexual health, can justify more privacy. See sending notes to the NHS GP.

Agree before you start who monitors high-risk medicines. NHS GPs are not obliged to take over private prescribing or monitoring.

Records and pharmacy liaison

Record what you prescribed, the dose and quantity, the indication, the risks you discussed and whether the patient agreed to share information with their GP. Pharmacies must keep their own record of private POM supplies and keep the prescriptions for two years, but your clinical record is what you will rely on in a complaint or inspection.

Introduce yourself to the pharmacies your patients use most. Give them a number to check a prescription, and ask how they prefer to receive private and CD prescriptions. For CDs, ask in advance whether they hold stock.

Governance checklist

• A written prescribing policy covering your scope, remote prescribing, controlled drugs, high-risk medicines, repeat prescribing and prescribing for people you know
• Private CD prescriber number and pads in place, stored securely and logged
• A record system with drug-dictionary checks, and allergies recorded at every first consultation
• A consent-to-share step built into the consultation, and letters sent to NHS GPs
• A repeat prescribing process with review dates
• A prescribing audit each year, such as antibiotics, controlled drugs or monitoring of high-risk medicines. See running a clinical audit.
• Significant events and Yellow Card reports logged and reviewed
• Your indemnity provider told about any prescribing that is remote, controlled or outside usual GP scope

Systems that help

The workflow is easier when prescribing sits inside the clinical record. Then the prescription, the safety checks and the letter to the NHS GP all come from one place. A good example is Jump, which checks prescriptions against dm+d, issues private e-prescriptions through SignatureRx and sends letters to the NHS GP via MESH. Hero Health also offers private e-prescribing through SignatureRx alongside EMIS Web. Meddbase has a built-in drug database from First Data Bank. Check how each one handles controlled drugs, which still need the paper form.