Checking the registration of healthcare professionals

Pharmacy teams may need to check whether a healthcare professional is registered, licensed or otherwise authorised to practise. This may be relevant when checking whether a prescription is valid, when investigating a suspicious prescription, or when deciding whether medicines may be supplied to another healthcare professional or organisation.

Registration checks may also be needed as part of due diligence when supplying medicines by way of wholesaling, or when supplying medicines to another healthcare provider for use in treating patients.

In many cases, checking the register is straightforward. However, pharmacy teams should remember that registration alone does not always answer every question. The relevant checks may include:

• whether the person is registered with the correct UK regulator;
• whether the registration is current;
• whether any licence to practise is required;
• whether the person has an independent or supplementary prescriber annotation;
• whether the person is prescribing within the legal scope of their profession;
• whether any controlled drug restrictions apply;
• whether the prescription or requisition appears genuine;
• whether the person is practising in the UK or overseas;
• whether the supply is for a lawful purpose.

Why registration checks matter

A prescription for a prescription only medicine must normally be issued by an “appropriate practitioner” under the Human Medicines Regulations 2012: https://www.legislation.gov.uk/uksi/2012/1916/part/12/chapter/2

In simple terms, this means that a pharmacist should be satisfied that the person issuing the prescription is legally able to prescribe that medicine. Doctors and dentists can prescribe by virtue of their professional registration and scope of practice. Other healthcare professionals, such as pharmacists, nurses, optometrists, physiotherapists, podiatrists, paramedics and therapeutic radiographers, may prescribe only if they hold the relevant prescribing qualification and this is annotated on their professional register.

A registration check may therefore be needed to answer two different questions:

1. Is the person currently registered as the type of healthcare professional they claim to be?
2. If they are prescribing, does the register show that they are an independent or supplementary prescriber where this is required?

For wholesaling or stock supply, the issue may be slightly different. Wholesalers and pharmacies must take reasonable steps to ensure that medicines are supplied only to persons who are authorised or entitled to receive them. MHRA guidance on customer qualification explains that wholesalers have a key role in ensuring medicines are only supplied to authorised organisations and qualified prescribers: https://mhrainspectorate.blog.gov.uk/2016/06/03/qualification-of-customers-what-wholesalers-need-to-know/

Registration checks and prescription validity

When a prescription is received, pharmacy teams should consider whether the prescriber is legally entitled to issue that prescription.

For UK prescribers, this usually means checking the relevant UK professional register. For non-medical prescribers, the register should usually show an annotation such as “independent prescriber” or “supplementary prescriber”.

The same general principle applies to other non-medical prescribers: the relevant professional register should show the prescribing annotation.

Registration checks and wholesaling

Where medicines are supplied to another healthcare professional or healthcare provider, the supplier should be satisfied that the recipient is authorised to receive the medicines.

Anyone who sells or supplies human medicines to anyone other than the patient may need a wholesale distribution authorisation. MHRA guidance explains that individuals or companies that sell or supply human medicines to anyone other than the patient must have a wholesale distribution licence, subject to limited circumstances where supply may be made without one: https://www.gov.uk/guidance/apply-for-manufacturer-or-wholesaler-of-medicines-licences

Even where a wholesale dealer’s licence is not required, pharmacy teams should still carry out appropriate due diligence. This may include checking the recipient’s professional registration, organisation details, business address, reason for the request and whether the medicines are required for patient care.

UK professional registers

The following links can be used to check the registration status of healthcare professionals in the UK.

Pharmacists and pharmacy technicians

General Pharmaceutical Council register: https://www.pharmacyregulation.org/registers

Pharmacist register: https://www.pharmacyregulation.org/registers/pharmacist

Pharmacy technician register: https://www.pharmacyregulation.org/registers/pharmacy-technician

Pharmacy premises register: https://www.pharmacyregulation.org/registers/pharmacy

Telephone: 020 3713 8000

The GPhC register can be used to check whether a pharmacist or pharmacy technician is registered in Great Britain. For pharmacists, the register can also show whether the person has an independent prescriber or supplementary prescriber annotation.

Pharmacy premises in Great Britain can also be checked on the GPhC premises register.

Pharmacists in Northern Ireland

Pharmaceutical Society of Northern Ireland register: https://registers.psni.org.uk/

Telephone: 028 9032 6927

The Pharmaceutical Society of Northern Ireland regulates pharmacists and pharmacy premises in Northern Ireland. The register can be used to check pharmacist registration status, pharmacy premises and prescribing annotations.

Pharmacy technicians are not currently registered by the Pharmaceutical Society of Northern Ireland. The PSNI explains this here: https://psni.org.uk/pharmacy-technicians/

Doctors

General Medical Council register: https://www.gmc-uk.org/registration-and-licensing/our-registers

Telephone: 0161 923 6602

Doctors practising medicine in the UK must be registered with the GMC and hold a licence to practise. The GMC explains that the licence to practise allows doctors to carry out certain activities, including prescribing medicines, and that a doctor’s register status will show whether they hold a licence: https://www.gmc-uk.org/registration-and-licensing/our-registers/a-guide-to-our-registers/the-licence-to-practise

When checking a doctor, pharmacy teams should check not only that the person is registered, but also whether they hold a licence to practise.

Dentists

General Dental Council register: https://olr.gdc-uk.org/

Telephone: 020 7167 6000

The GDC register can be used to check whether a dentist or dental care professional is registered and able to practise in the UK. The GDC states that its registers are updated daily: https://olr.gdc-uk.org/

Dentists may prescribe medicines within their professional competence. Dental care professionals, such as dental hygienists or dental therapists, are registered with the GDC but are not generally independent prescribers.

Nurses, midwives and nursing associates

Nursing and Midwifery Council register: https://www.nmc.org.uk/registration/search-the-register/

Telephone: 020 7333 9333

The NMC register shows who can practise as a nurse or midwife in the UK, or as a nursing associate in England. The NMC advises that, where possible, searches should use the person’s PIN because more than one person may have the same name: https://www.nmc.org.uk/registration/search-the-register/

For prescribing, check whether the nurse or midwife has the appropriate prescribing qualification or annotation. Nurse independent prescribers and supplementary prescribers may prescribe within their legal authority and competence.

Optometrists and dispensing opticians

General Optical Council register: https://str.optical.org/

Telephone: 020 7580 3898

The GOC register can be used to check optometrists, dispensing opticians, student registrants and registered body corporates. The GOC explains that its online register gives up-to-date information on an optical professional’s registration details and current registration status: https://optical.org/registration/how-an-employer-can-check-if-an-optical-profession.html

Optometrist independent prescribers should have the relevant specialty or prescribing annotation on the GOC register.

Dietitians, orthoptists, paramedics, physiotherapists, podiatrists and radiographers

Health and Care Professions Council register: https://www.hcpc-uk.org/check-the-register/

Telephone: 0300 500 6184

The HCPC register covers a range of health and care professions, including:

• dietitians;
• orthoptists;
• paramedics;
• physiotherapists;
• podiatrists and chiropodists;
• radiographers;
• occupational therapists;
• operating department practitioners;
• speech and language therapists;
• practitioner psychologists;
• clinical scientists;
• biomedical scientists;
• hearing aid dispensers;
• prosthetists and orthotists;
• arts therapists.

The HCPC explains that to check someone’s registration status you need to enter their surname or registration number and select their profession from the drop-down list: https://www.hcpc-uk.org/check-the-register/how-to-check/

For prescribing, the HCPC register should be checked for the relevant annotation, such as independent prescribing or supplementary prescribing. The HCPC explains that some professions have annotations, including independent prescribing and supplementary prescribing: https://www.hcpc-uk.org/public/which-professions-do-hcpc-regulate/

Veterinary surgeons and veterinary nurses

Royal College of Veterinary Surgeons register: https://findavet.rcvs.org.uk/find-a-vet-surgeon/

Telephone: 020 7222 2001

The RCVS Find a Vet Surgeon service can be used to check whether a veterinary surgeon is registered and to find their RCVS registration number: https://findavet.rcvs.org.uk/find-a-vet-surgeon/

RCVS also provides a register search page for veterinary surgeons and veterinary nurses eligible to practise in the UK: https://www.rcvs.org.uk/veterinary-professionals/registration/check-our-registers

Veterinary prescriptions are subject to a different legal framework from human medicines. If supplying veterinary medicines, pharmacy teams should ensure that the prescription and medicine are appropriate under the Veterinary Medicines Regulations and relevant veterinary medicines guidance.

Checking whether a healthcare professional is a prescriber

A person may be registered as a healthcare professional but not be authorised to prescribe. This is particularly important for non-medical prescribers.

The register should be checked for an annotation such as:

• independent prescriber;
• supplementary prescriber;
• community practitioner nurse prescriber;
• specialist or prescribing specialty annotation.

The exact wording varies between regulators.

If the annotation is missing, unclear or inconsistent with the prescription, the pharmacist should contact the prescriber or relevant regulator before supply. It is not enough to assume that a registered healthcare professional is a prescriber simply because they work in a clinical setting.

Pharmacy teams should also remember that a prescribing annotation does not mean the prescriber can prescribe every medicine in every situation. Prescribing must still be within the prescriber’s professional competence and any legal restrictions, including controlled drug restrictions.

Controlled drugs

Controlled drugs require additional caution. A prescriber may be able to prescribe ordinary prescription only medicines but have more limited authority for controlled drugs.

For example, some independent prescribers can prescribe controlled drugs only within certain legal limits. The Misuse of Drugs Regulations 2001 contain separate rules on controlled drugs: https://www.legislation.gov.uk/uksi/2001/3998/contents

Where a controlled drug prescription is unusual, high-risk or issued by a non-medical prescriber, pharmacy teams should consider checking both the professional register and the relevant controlled drug prescribing authority.

What information should be recorded?

Where a registration check is carried out, it may be sensible to record:

• the name of the professional;
• registration number or PIN;
• regulator checked;
• date and time of the check;
• registration status;
• prescribing annotation, if relevant;
• whether a licence to practise was shown, if relevant;
• any concerns or follow-up action;
• the name of the person who carried out the check.

For routine prescriptions, it will not always be necessary to record every register search. However, where a prescription is suspicious, unusual, private, high-risk, for a controlled drug, or linked to a wholesale supply request, a clear record may help demonstrate that appropriate checks were made.

Non-UK healthcare professionals

Checks involving non-UK healthcare professionals require extra care.

A person who is registered overseas is not automatically authorised to practise or prescribe in the UK. In general, if a person is practising in the UK, they should be registered with the relevant UK regulator.

For example, an overseas-qualified doctor practising medicine in the UK must be registered with the GMC and hold a licence to practise. An overseas-qualified pharmacist practising as a pharmacist in Great Britain must be registered with the GPhC. An overseas-qualified pharmacist practising in Northern Ireland must be registered with the Pharmaceutical Society of Northern Ireland.

Overseas professional registers may be useful to confirm identity or professional status, but they do not usually replace the need for UK registration where the person is practising in the UK.

Prescriptions issued in the EEA or Switzerland

There are specific rules for some prescriptions issued in the European Economic Area or Switzerland.

UK government guidance states that, from 1 January 2021, a prescription issued in an EEA member state or Switzerland can be dispensed in the UK if the prescriber is from a profession recognised by the guidance and is legally entitled to issue that kind of prescription in the country where it was issued: https://www.gov.uk/guidance/prescriptions-issued-in-the-eea-and-switzerland-guidance-for-pharmacists

The guidance says that pharmacists should:

• identify the prescriber;
• check that the prescription was issued in an approved country;
• check that the prescriber is practising in a recognised profession for that country;
• consider contacting the competent authority in the country of issue to check the prescriber’s registration and authority to prescribe;
• refuse to dispense where the country or prescriber is not on the approved list.

The prescription should contain the prescriber’s name, professional qualifications, direct contact details, work address and the country in which it was issued.

Pharmacy teams should also remember that there are restrictions. For example, prescriptions from EEA or Swiss prescribers cannot be used for all medicines or all circumstances, and controlled drugs and special categories of medicine may be subject to additional restrictions. The government guidance should be checked before supply: https://www.gov.uk/guidance/prescriptions-issued-in-the-eea-and-switzerland-guidance-for-pharmacists

Prescriptions from outside the EEA and Switzerland

A prescription issued by a healthcare professional outside the UK, EEA or Switzerland will usually not be valid for dispensing as a UK prescription.

In these cases, the patient should usually be referred to a UK prescriber or appropriate healthcare service. Pharmacy teams should not rely on an overseas registration alone unless there is a clear legal basis for recognising the prescription.

Where the request is connected to wholesaling rather than patient dispensing, the supplier should carry out due diligence on the overseas customer, including professional registration, organisation status, import/export permissions, wholesale authorisations and whether the supply is lawful in both countries.

Practical approach to overseas register checks

If it is necessary to check an overseas healthcare professional, the safest approach is:

1. Ask for the prescriber’s full name, registration number, professional title, work address and country of practice.
2. Identify the competent authority or regulator for that profession in that country.
3. Use the regulator’s official online register where available.
4. Check whether the person is currently registered and whether their registration allows prescribing.
5. Check whether the prescription is legally recognised in the UK.
6. Contact the regulator or prescriber’s organisation if the online register is unclear.
7. Record the check and any decision made.

The UK government guidance on EEA and Swiss prescriptions specifically says that pharmacists may contact the competent authority in the country where the prescription was issued to check registration and prescribing authority: https://www.gov.uk/guidance/prescriptions-issued-in-the-eea-and-switzerland-guidance-for-pharmacists

Practical checklist for pharmacy teams

When checking a healthcare professional’s registration, consider the following:

1. What profession does the person claim to belong to?
2. Which regulator holds the register for that profession?
3. Is the person currently registered?
4. Is a licence to practise required?
5. If prescribing, does the person have the correct prescribing annotation?
6. Is the medicine within the legal scope of that prescriber?
7. Are controlled drugs involved?
8. Does the prescription or request include full contact details?
9. Does the prescription or requisition appear genuine?
10. Has the check been recorded where appropriate?

Summary

Checking professional registration is an important part of prescription validity checks, fraud prevention and medicines supply governance.

For UK professionals, the relevant professional register should be checked directly. For non-medical prescribers, the prescribing annotation is particularly important. For doctors, the GMC register should show that the doctor holds a licence to practise. For EEA or Swiss prescriptions, pharmacy teams should follow the UK government guidance and may need to contact the competent authority in the country of issue. For prescriptions from outside the UK, EEA and Switzerland, the prescription will usually need to be referred to a UK prescriber.

A register check does not replace professional judgement, but it provides an important safeguard when a prescription or supply request depends on the professional status of the person making it.