Acting to stop harm: the FCA and Appointed Representatives
Fears of growing antibiotic resistance have been circulating for some time. These fears have recently peaked and the National Institute for Clinical Excellence (NICE) has, in response, published draft guidelines on the prescriptions of antibiotics. Antibiotics have been in circulation for roughly 60 years; the more antibiotics are used the more the diseases that they are designed to attack resist them. Resistance must be prevented so that antibiotics remain effective in the future.
One of the key recommendations from the new draft guidelines is that medical practitioners should review peers’ prescribing routines and habits in relation to antibiotics. The Chair of the Royal College of General Practitioners has been quoted as welcoming this ‘team approach’.
We hear from GP clients that patients will often refuse to leave their surgery without a prescription for antibiotics, nothing else will do.
We hear from GP clients that patients will often refuse to leave their surgery without a prescription for antibiotics, nothing else will do. After all, patient led medicine is encouraged. But ‘patient led’ does not mean that the patient simply ‘picks their pill’, rather it requires that a treatment package takes into account everything about an individual patient; it must be tailor-made.
The General Medical Council is already alert to the inappropriate prescription of antibiotics: many fitness to practise investigations already feature allegations of nonchalant, inappropriate or poor quality prescription of antibiotics by doctors. ‘Good practice in prescribing and managing medicines and devices’ is a piece of supplemental guidance to the most recent Good Medical Practice.
The new draft guidance now provides a standard that, if introduced, will be a further measure against which a doctor’s practice will be compared during GMC fitness to practise investigations. Practitioners may, in the future, be investigated by the GMC as a result of either failing to notice (perhaps by deliberately turning a blind eye) or failing to act on a colleague’s poor antibiotic prescribing habits.
The grave public health impact of the decreasing efficiency of antibiotics creates risks for the future medical treatment of patients.
The grave public health impact of the decreasing efficiency of antibiotics creates risks for the future medical treatment of patients. The draft NICE guidance coincides with the recent report by Sir Robert Francis QC into whistleblowing in the NHS. It will be necessary that practitioners feel able to make disclosures openly and safely and that they are well supported if they raise these concerns.
Whilst the new statutory duty of candour does not apply directly to this (it is unlikely that the mal-prescription of antibiotics to patients will fall within the definition of a notifiable safety incident), the cultural shift that the duty of candour is intended to facilitate will mean that practitioners should have at the forefront of their mind when treating a patient or reviewing treatment provided by others:
As ever, for the individual practitioner, accurate, full and contemporaneous record keeping will be key with a particular focus on ensuring that both the rationale for prescribing any antibiotics and any discussions between a practitioner and patient are detailed.
Kingsley Napley provides training on the duties and obligations of individual practitioners in relation to whistleblowing, candour and GMC regulatory proceedings. We are experienced in representing doctors before the General Medical Council. If you would like any further information about an issue or would like to discuss your training needs please contact Julie Norris.
Skip to content Home About Us Insights Services Contact Accessibility