Medicines use, prescribing and injection therapy are within the scope of the UK physiotherapy profession.
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Consultation on controlled drugs
The Department of Health has launched a public consultation regarding, amongst other things, the introduction of an additional four controlled drugs to the list that independent prescriber physiotherapists may prescribe.
We encourage members to respond to the consultation, and to share awareness of this consultation with their patients and colleagues.
Independent prescriber physiotherapists have been able to prescribe from a limited list of seven controlled drugs since 2015. This public consultation is the culmination of several years’ work to add to the existing list in order to keep it fit for purpose and in line with both clinical practice and current health policy.
NHS England has successfully set out the case for legislative reform of medicines legislation that has enabled this public consultation to take place and the CSP has been involved in developing the proposals.
In addition, NHS England will be holding a series of stakeholder engagement events to be held online during the course of the Public Consultation that you may wish to register for.
For further information on the proposals, read our Q&As on the proposals.
All physiotherapists can give medicines advice to their patients. This is an expectation of reasonable physiotherapy practice for many conditions. They can also supply and administer medicines to patients under either a Patient Specific Direction, or a Patient Group Direction.
Physiotherapists who have additional prescribing annotations to their HCPC registration may prescribe all licensed medicines - including seven controlled drugs - which are within the scope of physiotherapy prescribing practice.
Injection therapy is the administration of medicines, and other selected products, to intra- and extra-articular tissues and joint spaces by invasive injection. Injection therapy also includes aspiration of joint spaces.
- UK medicines law sets out the framework for how health professionals may use medicines in their work.
- The HCPC sets the regulatory and educational framework for prescribing by physiotherapists
- The CSP provides guidance to help members use medicines appropriately in their work
Our publication PD019 Medicines, Prescribing and Physiotherapy gives detailed information on using medicines in physiotherapy practice.
There are two types of prescribing for physiotherapists:
- Supplementary prescribing is the use of a written clinical management plan (CMP) to prescribe agreed medicines in partnership with a doctor. The CMP can include any licensed or unlicensed medicines and all controlled drugs.
- Independent prescribing is the use of your own clinical reasoning and professional judgment to determine the nature and extent of any medicines to be used in the management of diagnosed and undiagnosed conditions. Independent prescribers may prescribe any licensed medicine from the British National Formulary, within national and local guidelines, for any condition within their area of competence within the overarching framework of human movement, performance and function. Independent prescribers may also mix medicines prior to administration and prescribe from a restricted list of seven controlled drugs.
Our publication PD026 Practice Guidance for Physiotherapy Prescribers contains detailed information.
- Supplementary and independent prescribing by physiotherapists is legal in all parts of the UK.
- Prescribing by UK physiotherapists is not allowed overseas.
- Physiotherapists cannot prescribe medicines for purely cosmetic purposes.
- Prescribing courses for physiotherapists are validated and approved by the HCPC.
- The HCPC sets separate prescribing standards for those annotated as prescribers.
- Courses validated for independent prescribing will automatically provide you with a supplementary prescribing qualification as well.
- You must not prescribe until your prescribing qualifications are added to your HCPC registration.
Injection therapy for therapeutic purposes has been part of physiotherapy practice since 1997. It is used to treat:
- Inflammatory pain from a range of orthopaedic and rheumatological conditions.
- Spasticity and dystonia from a range of neurological conditions.
- Chronic headache of musculoskeletal or neurological origin.
- Some bladder disorders in women's health physiotherapy.
Vaccinations and other subcutaneous injections are not considered to be ‘injection-therapy’.
- CSP members must undertake injection therapy training that meets the CSP educational expectations.
- You must consider which medicines framework you will use when practising injection therapy.
- If you need to prescribe medicines for injection therapy you must also complete an HCPC approved prescribing course.
You do not need extra insurance to be a prescriber or use injection therapy. The CSP PLI scheme covers all activities within the scope of physiotherapy practice, including prescribing and injection therapy. If you wish to include prescribing within your scope of practice you must ensure you are an HCPC ‘annotated prescriber’.
Your HCPC registration must be updated to show you are a prescriber before you start prescribing. This is so that you can prove you’re practising lawfully.
The provision of regional and general anaesthesia is not ‘injection therapy’ and is outside the scope of physiotherapy practice. The use of Lipogems™, or any other adipose-tissue derived product, does not yet have a sufficient evidence base to justify use as part of physiotherapy practice. Members must be aware that these interventions and products are not covered by the CSP PLI scheme.
Can I deliver the flu vaccine as part of my physiotherapy role?
Yes. Delivery of a national flu vaccination programme, this year, is part of the UK’s response to managing the Covid-19 pandemic. This means that some physiotherapists may be asked to provide vaccination clinics for their local populations as part of the NHS planning for winter.
You do not need to be a prescriber or a qualified injection therapist to deliver vaccinations by subcutaneous and/or intramuscular injection. Patient Group Directions (PGDs) are normally used to deliver vaccination services. This means that your employer must have a PGD in place and you must be individually named on the PGD in order to work under it. You cannot delegate the administration of vaccines under a PGD to anyone else, for example a support worker. If you are unsure whether you are named within your organisation’s flu vaccine PGD, please contact your organisation’s Chief Pharmacist.
As with all activities you undertake, you must be educated, trained and competent to perform the activity. If you require training in how to deliver vaccinations, your employer must provide you with appropriate training before you undertake the task. If you have any concerns about the level of training you receive please raise this with your local CSP steward.
If you are employed in NHS services and you are asked to allocate working time to providing vaccination clinics, you should consider the interruption this may have on your physiotherapy workload. It is appropriate that physiotherapists use their capabilities to support the wider NHS workforce, but it is important that organisations take account of the impact this may have on patients accessing physiotherapy services. It will an organisational decision as to which service takes priority, and how staff are deployed to deliver services.
If you work in private practice, you may be approached by local Primary Care (GP) NHS services to support their delivery of vaccination services. If you choose to take up this opportunity you must ensure that you are either, directly employed by the Primary Care organisation or, have a clear contract for services with the Practice, that will enable you to work under their PGDs. You must also ensure that suitable training is provided.
If you work in private practice and do not deliver NHS services, it is unlikely that you will be able to offer vaccination services. This is because physiotherapists cannot legally obtain wholesale stocks of vaccine, nor can individual physiotherapy private practices create the PGDs required to administer vaccines. People choosing to have private vaccination should be directed to vaccination clinics that are widely available at local pharmacies.
Finally, you must consider your own obligations as a registered healthcare professional to have a flu vaccination to protect yourself and the people you work with. It may be a requirement of your employment to ensure that all vaccinations are up to date. You should see your own GP or occupational health adviser if you are unclear whether you need a flu vaccine.
- PD019 Medicines, Prescribing and Physiotherapy
- Medicines frameworks for the prescribing professions
- Medicines frameworks for UK health professionals
- PD026 Practice Guidance for Physiotherapy Prescribers
- PD071 CSP expectations of educational programmes in injection therapy
- PD003 Use of medicines in physiotherapy injection-therapy services
- Transdermal medicines and physiotherapy practice
The Health and Care Professions Council sets the proficiency standards for prescribing and lists all the approved prescribing courses available to physiotherapists in the UK.
The Allied Health Professions Federation hosts the curriculum framework for non-medical prescribing educational programmes.
The Royal Pharmaceutical Society publishes the competency framework for all prescribers. We have contributed to the creation of this framework and endorse its publication. We expect all our prescribers to follow it.
The Medicines and Healthcare Products Regulatory Agency is the UK-wide statutory regulator for medicines and advises on all aspects of compliance with UK medicines law.