Three’s not a crowd: CBPMs should be digitally prescribed, say The Home Office, NHS England, and The ACMD

Currently, when patients are issued a prescription for medical cannabis, a paper copy of this FP10 must be printed off and signed in ink by the prescriber. It must then be scanned in and uploaded to their systems for record keeping, and be sent to the dispenser in its physical copy, before the patient can access their medicine. 

This proposal seeks to remove this extra barrier or requirement, and allow prescribers to digitally sign and send these documents instead. 

NHS England and the ACMD are in agreement that making these alterations to EPS classifications would improve efficiency and convenience for both staff and patients, reduce the likelihood of human error, and loss of prescriptions, and benefit the environment. 

With this support from the Home Office in the form of MP and Minister of State for Crime, Policing and Fire, Chris Philp, this notion has become a three-fingered salute. 

Chris Philp agreed with their recommendations and stated the Home Office will work with the Department of Health and Social Care to find out if changes need to be made to the Misuse of Drugs Regulations 2001 to bring this into fruition. 

About the EPS: Electronic Prescription Service

The EPS was first introduced to NHS England in 2005, allowing prescribers to send prescriptions electronically, directly to a dispenser or pharmacy. Now this system is used by thousands of doctors on a daily basis, and was utilised to issue over 91% of prescriptions in January 2023 – equating to over 88 million prescribed items. 

This way, prescriptions cannot be miswritten or lost, less paper is wasted, and prescriptions can reach the dispensary faster, which saves time for the doctors, and allows patients to access their medication sooner.

In general, EPS allows for acute prescriptions, repeat prescriptions, and repeat dispensing prescriptions – however, there are exceptions.  

Although technically controlled schedule 2 and 3 drugs, like medical cannabis and cannabis based medicines, can be prescribed using the electronic prescription service – they cannot be prescribed through a repeat dispensing arrangement.

This means that every time a patient is reissued a medical cannabis prescription, their prescribing doctor has to physically print, sign, scan, upload and send the prescription again. 

On top of this, medical cannabis prescriptions only tend to be issued for a 28-days period. This means prescribers have to go through this process for each of their repeat patients on a monthly basis, even if no alterations to their prescription were made. 

The EPS also excludes private prescriptions, from private healthcare providers, and the prescription of items not listed on the Dictionary of Medicines and Devices. Although certain cannabis-based medicines such as Sativex and Epidiolex are featured on this list, medicinal cannabis is not, and so it is excluded from the EPS. 

Recommendations to alter the EPS

Suggestions to alter the rules surrounding controlled drugs (schedule 2 and 3) in the EPS were first made in 2013 by the Department of Health, who consolidated with the ACMD and found them in agreement that these rules should be revisited. 

Although when these recommendations were made medical cannabis and cannabis based medicines were not yet legal in the UK, they are now exempt from the EPS because of their status as Schedule 2 controlled substances. 

Over the last decade, several changes and alterations have been made to the Electronic Prescription Service, but the stance on the prescription of schedule 2 and 3 drugs has remained stable and pharmacies still require a physical prescription to dispense these medicines. 

In June this year, the issue resurfaced and the AMCD released further correspondence on the matter. Their letter, addressed to Chris Philp, the Minister of State, Crime, Policing and Fire, made two key recommendations.

The Advisory Council for the Misuse of Drugs key recommendations were:

• “ The ACMD recommends to the Home Office that the Misuse of Drugs Regulations 2001 are amended to allow electronic prescribing of Schedule 2 and 3 Controlled Drugs within secondary care and the Health & Justice System.”

• “The ACMD recommends NHS England evaluate the impact of the proposed changes to the Misuse of Drugs Regulations 2001 to allow electronic prescribing of Schedule 2 and 3 Controlled Drugs within secondary care and the Health & Justice System.”

Responses to the Recommendations

Chris Philp MP issued his official response to the ACMD, on behalf of the government, saying he was grateful for their advice on the 29th of September 2023. In his response, it was confirmed the government supports both recommendations. 

The Government response to recommendation 1 read:

“The Government accepts the recommendation that the electronic prescribing of Schedule 2 and 3 Controlled Drugs within secondary care and the Health & Justice System should be allowed, subject to further consideration with the Department of Health and Social Care (DHSC) of whether amending the Misuse of Drugs Regulations 2001 is the most appropriate legislative mechanism. 

Whilst in regard to recommendation 2, the government responded:

“This recommendation is led by NHS England and DHSC, who have confirmed they will conduct an evaluation of the impact of the proposed changes once implemented.”

The Cannabis Industry Council (CIC) also released a statement on the subject. Here, Dr Sunil Aurora, Co-Chair of the CIC Prescription Cannabis Working Group, commented:

“The Cannabis Industry Council is pleased to hear the Government will be making this sensible reform. This moves clinics into the digital age, and will enable more secure and efficient record-keeping, as well as speeding up patient access to their medication.”

Recently, online, members of the medical cannabis community also expressed their support for these changes. The main focus of these comments seem to centre on its potential to reduce the amount of time patients currently have to wait for their medication, and remove the likelihood of experiencing delays with courier services like Royal Mail.

Conclusion

In conclusion, the prospect of allowing digital prescriptions for cannabis-based medicines using the Electronic Prescription Service represents a progressive stride in healthcare efficiency, innovation, and patient care. 

The current cumbersome process prescribers have to go through, involving printing, signing, scanning, uploading and then physically sending the prescription to a dispenser, could potentially become a thing of the past if these government recommendations are followed.

By enabling prescribers to digitally sign and transmit these prescriptions, the process becomes much more streamlined, efficient, and convenient for everyone involved. Now with support from NHS England, the ACMD, and the Home Office, it appears this ten-year-old initiative could finally take place. 

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