I think there is some confusion regarding ‘off-label' prescribing and ‘off-licence' dispensing. (GPs face clampdown on off-label prescribing after pharma company challenge)
Doctors can prescribe whatever they feel is necessary for the patient, especially if they do so generically, because that does not necessarily identify an actual product with or without a licence. For free supply in the NHS, we are more restricted, since we can essentially only pick what will be available for supply from the pharmacist – which the pharmacist decides, but they only get reimbursed what the NHS will allow.
Quite often a proprietary product used to exist, but the manufacturer who held the licence stopped producing it for financial reasons. This does not stop us ‘prescribing' it if an alternative ‘unlicensed' product is available – possibly as a licensed dietary supplement or over-the-counter treatment – but it may prevent us giving NHS prescriptions for it.
We need to clarify the difference between a doctor's prescription and an FP10 NHS medicines reimbursement claim form, which is a financial authorisation for reimbursement of the supplying dispenser, not an actual prescription. Look at
‘pre-scription' – it must be written before the drug is administered or supplied.
Does that always happen in respect of an FP10?
Someone needs to look at the translation of European directives and how other countries apply and interpret them, and whether this misinterpretation is causing threats to national sovereignty and patient autonomy – which are enshrined in European directives on human rights that the EU cannot countermand through a drug supply review.
From Dr David Church
Machynlleth, Wales
