Response to the Scottish Government consultation on safe prescribing in NHS Scotland

We welcome the opportunity to comment on the draft strategy.

Comments

In general we welcome the provision of a clear strategy to develop and manage NMAHP prescribing. We believe that nurse practitioners who are specialists in dementia care or older people’s care could be a more flexible use of professional skills, provided appropriate parameters were set on the scope of their prescribing.

However, there are three issues we would like to see addressed:

1. It is not clear whether nurses employed in care homes rather than by the NHS could become independent nurse prescribers. We would be concerned if this were so, as it could take the primary care system out of diagnosis and health management of a vulnerable group of people. Alzheimer Scotland’s recent report The Dementia Epidemic (http://www.alzscot.org/pages/policy/dementiaepidemic.htm) reported the very significant under-recognition and under-diagnosis of dementia in care homes. Among the report’s recommendations was a medical assessment for every person in a care home whom staff believe may have dementia and improved access to doctors and specialist services for care home residents. In addition, the inappropriate use of neuroleptics in care homes to manage the behaviour of people with dementia is often triggered by nurses. We would not support any provision which would further reduce primary care and specialist services for people with dementia living in care homes.

2. The strategy should examine the implications for Adults with Incapacity Act Part 5 Certificates, which nurses can sign for nursing procedures for patients who lack the mental capacity to consent, which is the case for many people with dementia. It is not clear if nurses’ power to sign part 5 certificates would cover nurse prescribing.

We are particularly concerned if this were to apply in care homes, where we would want external safeguards.

3. As dementia is a condition whose prevalence rises sharply with age, many of the increasing number of older people with other conditions will also have dementia, and will have special needs including with regard to communication and compliance. NMAHP prescriber courses should incorporate training on dementia, and on the assessment of capacity, as it is not only specialist nurses who will encounter people with dementia.

I hope this is helpful, and would be happy to provide any further information that you require.

Kate Fearnley
Health and Community Care Director
25 January 2008