- Suitably trained dental hygienists or therapists can now administer, sell or supply certain prescription-only medicines (POMs) without a dentist's prescription or a patient group direction (PGD).
- The changes do not give any prescribing powers to hygienists or therapists, or amend the POM status of the listed medicines.
From 26 June 2024, an amendment to the Human Medicines Regulations made it possible for dental hygienists and therapists to supply and administer certain prescription-only medicines (POMs) under exemptions, without the need for a prescription from a dentist or a patient group direction (PGD).
However, those wishing to do so must be trained and competent, and should undertake any education and training identified as being necessary before working in this way.
What has changed?
The changes do not give any prescribing powers to hygienists or therapists, or amend the POM status of the listed medicines. The amendments simply provide an exemption from the need for a prescription in certain circumstances.
A range of local anaesthetic and high strength fluoride preparations are included on the list of exemptions, which will appear under Schedule 17 of the Regulations.
Before this change, a dental hygienist or therapist could only administer POMs - such as local anaesthetic or high concentration fluoride - under a patient specific direction (PSD) from a dentist, or under a valid patient group direction (PGD).
From 26 June 2024, a suitably trained dental hygienist or therapist can now:
- administer certain POMs without the need for a PSD or PGD
- sell or supply certain POMs direct to patients (ie, to take away with them), without the need for a PSD or PGD.
The changes apply to registered dental hygienists and dental therapists in England, Wales, Scotland, and Northern Ireland.
What hasn't changed?
Dental hygienists and therapists still cannot prescribe. They cannot fill out an NHS prescription form or write a private prescription. Dentists remain the only member of the dental team who can independently prescribe.
By way of an example, a suitably trained dental hygienist or therapist can now supply a patient with high concentration fluoride toothpaste to take home, but they cannot write a prescription for it to be supplied by a pharmacy.
What training do hygienists and therapists need?
The GDC expects any registrant to work within their scope, and be trained, competent, and indemnified for the work they undertake. In a news release about these changes, the GDC said:
- "We expect all dental hygienists and dental therapists to be able to demonstrate successful completion of a training course. This is crucial to ensure they have the required knowledge and skills to be able to work safely under this new mechanism."
NHS England explains that the decision to work to exemptions should be, "reached collaboratively between dental hygienist and the NHS contractor or practice owner on whose behalf they are delivering services."
NHS England guidance strongly recommends that all current dental hygienists and therapists undertake further training that complies with the curriculum it has set out (see below).
It also acknowledges that hygienists and therapists undertaking this training might need additional in-practice support, which should be determined on an individual basis.
There is no requirement for hygienists and therapists to have been in practice for a certain time for them to undertake a specific training course.
What should the training curriculum cover?
NHS England has set out a curriculum and qualifying criteria for those taking part. It includes advice on patient management and using medicines responsibly and has been developed by NHS England, the Department of Health and Social Care (DHSC), the British Society of Dental Hygiene and Therapy and the British Association of Dental Therapists.
An e-learning module is also being developed that complies with the curriculum.
Some of the areas the curriculum covers are summarised below - but practitioners should familiarise themselves with the full list in Annex A of the guidance.
Assessing the patient - including the need to fully assess the patient and make sure you have relevant knowledge of the patient's health, medical history and their current medication (including over the counter medicines).
Considering the options - such as whether the patient needs to be referred to an appropriate prescriber if you do not fully understand the implications of the medicine's use, and making sure patients have a genuine clinical need for the medicine.
Consent - explain to the patient or their representative the role you play in their treatment and provide them with sufficient information on the risks, benefits, possible side effects, possible costs and outcomes of the medicines you are considering, as well as any alternatives.
Record-keeping - record details of the medicines supplied or administered, together with details of the consultation in the clinical records. This should be done at the time of the consultation, or shortly afterwards.
Communication - while not a legal requirement, it's good practice to inform the patient's medical practitioner when you supply a medicine to a patient.
Adverse events - if you discover you have made an error in supply or administration, take immediate action to prevent potential side effects to the patient, and report the error as soon as possible according to local policies.
Guidance on training requirements in Wales, Scotland and Northern Ireland is awaited.
Our advice
Hygienists and therapists should satisfy themselves that they have completed appropriate training and can evidence their competence before working under the new exemptions.
Before implementing any changes to working practices, dental practice owners should also satisfy themselves that the hygienists and therapists they engage are trained and competent to work under these exemptions.
This page was correct at publication on 09/10/2024. Any guidance is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.