Prescribing by physiotherapists

DHSC proposals to extend controlled drug medicines responsibilities for physiotherapists (updated Jun 2026)

It is important to note that the current restrictions are not a CSP decision. The changes around medicines such as gabapentin and pregabalin in 2019 came from government and Home Office controlled drug legislation review following wider concerns about misuse and diversion. The CSP did raise concerns at the time about the impact on patient care and service delivery.

The wider review of controlled drug prescribing rights for physiotherapists sits within a broader DHSC medicines and prescribing programme, and  progress is unfortunately dependent on national policy and legislative processes rather than something the CSP can directly control. Political priorities and government capacity have also slowed things down considerably. We are continuing to engage with the process and push for progress where we can, but  we cannot give members unrealistic timelines at this stage.

The Department of Health and Social Care held a public consultation between August and October 2025 regarding extending the list of controlled drugs that physiotherapist independent prescribers are legally able to prescribe. DHSC is now analysing the results of that consultation to inform the official Government response. In additon, the Advisory Committee for Misuse of Drugs (ACMD), which advises the Home Office, heard the case for amending medicines legisltion for a number of AHP groups in June 2026. The CSP was present at that meeting. We await the decision of ACMD in due course.

The Government response is anticipated sometime in summer 2026, together with a timeline for any next steps.

Nuffield Trust Report

April 2026 Independent prescribing in the UK: Workforce ambitions and implementation challenges was published by the Nuffield Trust. The CSP was a core contributor.

Key findings include:

Physiotherapy prescribing is underutilised, despite a clear system need and proven value

• Independent prescribing is central to NHS priorities (community care, access, efficiency), yet only ~4% of physiotherapists are prescribers, with many not actively using the qualification.
• Strong patient satisfaction and clinical acceptability contrast with low public awareness of the role of physiotherapists in prescribing and inconsistent deployment across services.
• This represents a missed opportunity to improve access, reduce GP workload, and enhance pathway efficiency, particularly in community services, MSK care, urgent care, and neighbourhood teams.

Workforce, training and governance gaps are constraining scale and impact

• A fragile and inequitable training pipeline (limited funding, shortages of designated prescribing practitioners, delayed access post-registration) is restricting the growth of physiotherapy prescribers.
• Governance is fragmented with unclear accountability, limited national oversight, and no explicit HCPC revalidation of prescribing competence.
• Inconsistent CPD, supervision and service integration risks skill decay and variable quality, particularly across community and private sector settings.

Strategic issues risk widening the gap between policy ambition and delivery

• Government ambitions to expand prescribing are not matched by coherent workforce planning, legislative pace or service model integration.
• Physiotherapists face structural inequity compared to other professions (e.g. nurses), limiting full utilisation within multidisciplinary teams.
• Without alignment of policy, regulation and workforce strategy there is a real risk of continued underuse, loss of competence, and failure to realise prescribing’s role in managing multi-morbidity and delivering neighbourhood care.

Prescribing frameworks

Independent prescribing

This is an autonomous prescribing framework. You work within your own scope of practice to prescribe the medicines a patient needs for the management of their condition(s), for which you are treating them.

Independent prescriber physiotherapists can prescribe all licensed medicines, mixed medicines and a limited number of controlled drugs, which may change from time to time.

Some medicines may require an in-person consultation before prescribing occurs. If you are prescribing remotely, or on the recommendation of another healthcare professional, must ensure for yourself that you have sufficient information to make a safe prescribing decision.

If you are an independent prescriber, you may also work in settings that require you to use a Patient Group Direction (PGD). You cannot work outside the parameters of the PGD, even though you are also a prescriber. If the PGD parameters are not suitable for your patient, you should prescribe instead, if this is permitted by the service.

Supplementary prescribing

You work in partnership with a doctor to prescribe the medicines needed by an individual patient for the management of their condition using a written document called a Clinical Management Plan (CMP). The contents of a CMP are defined in law see Schedule 14 of HMRs

Supplementary prescriber physiotherapists can prescribe all licensed medicines, unlicensed medicines, mixed medicines and all controlled drugs provided they are listed within the written CMP that is created before prescribing starts.

Medicines formularies

The British National Formulary (BNF) is the UK’s primary reference book for safe, effective prescribing, dispensing and administration of medicines in clinical practice. The BNF includes medicines that are in regular clinical use in the NHS, considered relevant to all prescribers and pharmacists, supported by guidance, safety information and clinical evidence.

Most NHS organisations will have their own Local Formularies (LFs) that standardise the products that all prescriber employees can prescribe, to reduce unwarranted variation and manage prescribing costs. The LF may not include all medicines listed within the BNF, and instead identify a smaller number of medicines that it expects all its prescribers to use. You should always prescribe on the basis of personalised care, and if the optimal choice of medicine is listed in the BNF but restricted from your local formulary on cost grounds, you should discuss this as part of any prescribing practice review.

Individual prescribers should identify their own Personal Formulary (PF). This is the range of medicines that the individual is educated, trained and competent to prescribe within their role and is within their current personal scope of practice. When a prescribing physiotherapist moves roles, employers or area of practice, they will need to update their PF, including undertaking any additional training that may be required. Your PF cannot include anything that is not in your organisation's LF, or not listed in the BNF.

Scope of physiotherapist prescribing

A physiotherapist independent prescriber may prescribe any licensed medicine from the BNF, within national and local guidelines for any condition within the practitioner’s area of expertise and competence within the overarching framework of human movement, performance and function. They may also mix medicines prior to administration and may prescribe from a restricted list of controlled drugs as set out in Regulations (CSP 2013).

The purpose of physiotherapy prescribing is to support physiotherapy interventions and improve patient movement, performance and function in its widest sense. It can be utilised in any clinical setting where physiotherapists work. For most physiotherapists, the prescribing activities are usually focused within their specific area of expertise.

The CSP definition should be interpreted broadly, avoiding unnecessary local restrictions. It should be interpreted considering all the words in the definition, not selected parts, and should facilitate physiotherapist prescribing where the law and regulations permit it.

While local formularies may limit prescribing for governance reasons, they should not be used to prevent physiotherapist prescribers from maximising their clinical capabilities in any setting, unless prevented by law. 

Training for physiotherapist prescribers

Prescribing is a post-registration activity. The Health and Care Professions Council (HCPC) lists all the HCPC approved prescribing courses available to physiotherapists in the UK.

Courses are at Level 6 (10) or level 7 (11) and all meet the curriculum framework for non-medical prescribing.

Training providers must meet the HCPC Standards for education providers.

Training providers must be approved by each regulator whose registrants it wishes to train. For example, a V300 course is a Nursing and Midwifery Council course approval code, and does not indicate a course is also approved by the HCPC. 

Standards and competency assurance for prescribers

The regulatory standards for physiotherapist prescribers are “The Competency Framework for All Prescribers”.

Physiotherapist prescribers in Wales who need to evidence and review ongoing competence in prescribing must use the “Standards for Competency Assurance of Independent & Supplementary Prescribers in Wales”

The Prescribing and Support Assurance Framework can be used by organisations and individuals to demonstrate the resources, governance measures, considerations and responsibilities in place to ensure and assure safe prescribing.  

Practice guidance for physiotherapist prescribers

Each allied health profession (AHP) that has prescribing rights is required to produce a Practice Guidance document to support its registrant prescribers. These documents must align across all the AHP prescribing professions.

Periodic reviews of the documents are overseen by DHSC and done in partnership with all the professional bodies to ensure consistency where required and individuality where needed.

• Read the current full Practice Guidance for Physiotherapist Prescribers. 

Controlled drugs

Some medicines are also regulated by the Misuse of Drugs regulations 2001 because they are known to be particularly potent and/or open to abuse or misuse. Controlled drugs (CD) are categorised into classes and schedules according to the risk they pose to the public.

Physiotherapist independent prescribers may currently only prescribe the following seven controlled drugs by the route defined. The CDs cannot be mixed prior to administration, nor can they be administered by infusion.

• Morphine, oral and injectable
• Fentanyl, transdermal
• Oxycodone, oral
• Dihydrocodeine, oral
• Temazepam, oral
• Diazepam, oral
• Lorazepam, oral

Physiotherapist supplementary prescribers may prescribe any CD that is listed within a patient’s written clinical management plan.

The government recently consulted on plans to expand the list of physiotherapist-controlled drugs. We are awaiting the results of the public consultation and we will let members know when we have further news.

Advanced clinical practice and prescribing

Some members may work within Advanced Practice or Advanced Clinical Practitioner roles where their employer requires them to undertake some activities that are beyond the scope of physiotherapy practice. This is acceptable as long as the individual is working within, among other things, a recognised advanced practice framework.

However, with prescribing, a practitioner must only prescribe within the permissions granted for their primary registration profession. This means that currently, there are limitations to the range of controlled drugs that physiotherapist ACP’s may prescribe. There is no legal way round this and members must work within the law. 

The Prescribing & Support Assurance Framework has more information.

Nitrous Oxide (Entonox)

Nitrous Oxide is a Schedule 5 controlled drug throughout the UK. However, the Misuse of Drugs Regulations permit registered healthcare professionals, including physiotherapists to lawfully supply, possess and administer nitrous oxide for medical purposes including medical care and treatment, subject to all other MODR requirements.

What about deprescribing?

Deprescribing is the planned process of reducing or stopping a Prescription Only Medicine (POM) that may no longer be beneficial to a patient. 

It is an act of ‘prescribing’ because it involves clinical decision-making about the initiation, continuation or cessation of a POM, and under Human Medicines Regulations can only be done by an ‘appropriate practitioner’.

Only HCPC annotated physiotherapist prescribers can deprescribe within the limits of their prescribing framework (supplementary or independent) and existing regulations. 

Non-prescribers cannot undertake acts of deprescribing. Instead they should instead identify concerns, discuss with the patient, and refer to an appropriate prescriber to ensure safe, lawful and appropriate deprescribing of POMs.

What about transcribing?

Transcribing is the non-clinical, administrative act of accurately copying previously prescribed medication details onto a medication administration record (MAR) to enable other staff to administer medicine. It is not a prescribing activity.

It cannot be used in place of prescribing, to supply or dispense medicines, to add new medicines, to alter or change original prescriptions.

It can be done by any competent person.

What about 'mixing' and unlicensed medicines?

Physiotherapist independent prescribers cannot prescribe unlicensed medicines unless it’s something that has been created by mixing together two already licensed medicines to create something new at the point of care with a patient, e.g. injection therapy corticosteroid and local anaesthetic.

Physiotherapist independent prescribers are specifically permitted to mix licensed medicines (but not controlled drugs) together prior to administration to a patient.

A more detailed explanation is given within our Practice Guidance for Prescribers (pages 19 and 20).

Where do I find my prescriber number?

Physiotherapists who are HCPC-annotated prescribers do not have a separate prescriber number. Your prescriptions should include your name as held with the HCPC and your HCPC number. This way, any pharmacist issuing your prescriptions can verify you are an appropriate prescriber by checking the public HCPC register. 

Can I prescribe controlled drugs to be administered by infusion?

No. The Medicines and Healthcare Products Regulatory Agency (MHRA) has confirmed that legal advice is that controlled drugs may only be prescribed to be administered by the route set out in Misuse of Drugs Regulations (MDRs). For morphine this is 'oral' and 'injectable' routes only. An 'injection' involves a breach of the skin and the administration of a single dose, or series of doses, of the medicine. Legal advice is that an 'injection' would also include a Patient Controlled Analgesia (PCA) pump device whereby the patient controls, on demand within the limits of the prescription, the individual injection boluses provided.

An 'infusion' has a different legal meaning to an injection in that it involves continuous administration of a controlled drug, whether by intravenous, intrathecal, intraspinal, continuous syringe driver or epidural routes. Under MDRs, physiotherapists are not permitted to prescribe CDs to be administered by infusion.

The MHRA recognises that the wording of the MDRs is more restrictive than the wording of the Human Medicine Regulations (TMRs) which govern non-controlled drugs. We recognise that this clarification may affect physiotherapist prescribers working in End of Life (EOL) care pathways, however, it is essential that our members work within the law at all times, and this legal advice finally provides clarity.

Can I use nitrous oxide in pitch-side sports physiotherapy? 

Yes. Nitrous oxide is a Schedule 5 controlled drug throughout the UK. However, physiotherapists can lawfully supply, possess and administer nitrous oxide for medical purposes, including medical care and treatment, in line with specific provision within Misuse Of Drug Regulations. You must also ensure you are educated, trained and competent in its use.

Can I set up a patient on oxygen, and can I adjust it? 

Oxygen is classed as a medicinal product and is regulated by the MHRA, and although it is a medical gas, it should be treated as a drug, and is often handled as a prescription medicine. Physiotherapist prescribers can prescribe oxygen.

Any registered healthcare professional can administer oxygen if there is a prescription in place (e.g. 2 L/min via nasal cannula, titrate to keep SpO₂ 94–98%). Adjusting the flow rate is allowed if it’s part of the prescription (e.g. “titrate to target sats”). If no prescription is written, you should follow local policy.

Can I prescribe (provide a PSD) for my colleague to administer the medicines? 

A physiotherapist independent prescriber may provide a prescription for another person to administer.

However, you must consider the professional relationship/proximity of the prescriber and administrator to the patient to ensure the act of prescribing occurs before the medicines are administered and patient safety.

The prescriber must also have the ability to access the patient’s medical record if needed, ensuring the safely of any remote prescribing.

Any charges you make for private prescribing should not adversely influence either the relationship between patient and treating physiotherapist, or patient safety.

Can I transcribe medicines already prescribed into other patient-care documents?  

Transcribing should not be a routine or regular occurrence. Transcribing of controlled drugs can only take place in limited circumstances. You should contact your chief pharmacist for advice. Further information is in Practice Guidance

Physiotherapists may be asked to transcribe medicines onto a community MAR, particularly as part of early discharge schemes and/or continuity of care in community settings. Delays in giving medication may have serious consequences.

The risk created by not administering prescribed medication may outweigh the risks of errors in transcribing. To reduce the risk of transcribing errors, the transcribed medicines sheet should be double-checked.

Transcribing of controlled drugs can only take place in limited circumstances and you must contact your community pharmacist for advice.