Patient Group Directions (PGD) Audit for GP Practice

Audit and Patient Group DirectionsSandra Wolper Associate DirectorMedicines Use and SafetyFebruary 2019

Could this be a GP Practice in your CCG? • Two of the PGDs, we looked at, had been signed by the practice manager. National guidance state that a PGD must be adopted in the practice by a GP. • CQC Report GP Practice • Published Oct 2015

Could this be your Organisation? PGDs had been highlighted as a risk for the department as it had been identified that these had gone out of date. Authorisation had been given for an extension on the current PGDs and new ones were being re-written. Some had been authorised by the PGD committee and were waiting allocation and it was aimed that the remainder would be completed by September 2016. The tests for those who were using PGDs were under review and once they had been completed all eligible staff would retake them. • CQC Report Urgent & Emergency Services, • Acute Trust July 2016

Could this be your Organisation? • Staff generally followed established patient pathways and national guidance for care and treatment. However, they did not always complete pain assessments and band five nurses were not authorised to administer oral pain relief under the trust’s patient group directions (PGD). This meant patients sometimes experienced a delay in pain relief. • CQC Report • Acute Trust April 2017

Could this be your Organisation? • In ophthalmology, a patient specific direction was developed under a patient group direction and healthcare assistants were administering eye drops. This was not in line with the medicines legislation and best practice guidance. • CQC Report • Acute Organisation • Published Apr 2015

Could this be your Organisation? • The service had introduced a Patient Group Direction (PGD) for Buccal midazolam since our last inspection. However, we were unable to locate records to demonstrate that each nurse had agreed to working within the terms of the PGD. • CQC Report • Substance misuse and eating disorder service • July 2017

Could this be your Organisation? • Staff in the XX town service could not produce a signed copy of patient group directions (PGD) form for staff to administer Hepatitis B vaccines. • CQC Report • Substance misuse service • July 2016

Could this be your Organisation? • The service had introduced a Patient Group Direction (PGD) for Buccal midazolam since our last inspection. However, we were unable to locate records to demonstrate that each nurse had agreed to working within the terms of the PGD. • July 2017 • Substance misuse and eating disorder service

What could you audit?

Group Activity • Individual • Service • Organisation • Audit Offers

Discussion

Individual (1) • Is the audit in real time or retrospective ? • Is the PGD the most recent, approved and in date? • Is the individual authorised? (professional registration) • Is clinical knowledge current / PGD within scope of practice? • Have they demonstrated competency/attended required training? • Have appropriate competencies been assessed and recorded?

Individual (2) • Has the patient been treated correctly under the PGD? • (E.g. adherence to inclusions/exclusions/referral criteria/correct dosage calculations.) • Is any observing of practice undertaken? Are they fulfilling all required steps (including issuing PIL/obtaining consent) • Do they know how and where to refer to relevant resources for more information?

Individual (3) • Is record keeping in line with requirements? • Are supporting SOPs/procedures followed? • Are storage requirements adhered to? • Is there evidence of delegation? • Is there any patient feedback? • Career / service development consider NMP training

Service (1) • Is the PGD the most recent, approved in date accessible ? • Are all the individuals authorised? (professional registration) • How many individuals are authorised? • Are lists of authorised staff maintained and if so who by? • Does service review and maintain training and competency requirements? • Are there prescribers in the service or planned? • Benchmark with other services

Service (2) • How many times has PGD been used? • Is PGD still required/ relevant? • Are there any PGD related risks on the register? • Have there been any PGD related incidents? • Are correct appropriately labelled products available? • Is storage monitored and correct conditions maintained? • Is there product awareness?(varying brands/generics,).

Service (3) • Are supporting SOPs/protocols in place (valid), accessible and being used? • Is there a clear consent policy? • Is the service managing prescription charges if required? • Do staff have access to supporting resources which are in date? (e.g. BNF) • Observation of practice

Organisation (1) • Is there a PGD policy? (Does it reflect most recent guidance and legislation) • Are there PGD working groups (with terms of reference defined responsibilities, minutes etc.) • Are PGDs processes being followed and working efficiently? • Is there a register of all PGDs authorised and in date? • Are PGDs owned reviewed audited and still required?

Organisation (2) • Is there an audit process timetable? • Are there any PGD related risks on the register? • How many times has PGD been used? • Is PGD still required/ relevant? • Have there been any PGD related incidents? • Are there any commissioned or subcontracted services? • Is training provided and competencies assessed?

Useful Links • NICE baseline assessment tool • https://www.nice.org.uk/guidance/mpg2/resources • SPS website PGD Audit tool examples • https://www.sps.nhs.uk/?s=&cat[]=4&cat[]=3238&cat[]=8 • HQIP Quality improvement methods tools • http://www.hqip.org.uk/public/cms/253/625/19/38/Guide-to-quality-improvement-methods-2015-7-1.pdf?realName=3hoUed.pdf

Patient Group Directions (PGD) Audit for GP Practice