Developing scope of practice guidance for new prescribers

In 2021, the General Pharmaceutical Council published new standards for the initial education and training of pharmacists^​1​. The new standards represented a significant shift in pharmacist training, incorporating independent prescribing education and assessment into the undergraduate degree and foundation training programme. 

Integration of prescribing at the point of registration marks a significant shift for the profession, creating substantial opportunities for patient care and service delivery, while also requiring thoughtful implementation, appropriate support and robust governance. 

The perspectives of stakeholders in relation to these changes have been researched^​2,3​ and the changes have been considered in the context of the Leng review^​4​ into medical associated professions, published in 2025^​5​. Across these reviews, it has become clear that guidance and resources are needed that:

• Support pharmacists, employers and the wider community to understand the prescribing role and scope of practice of newly qualified pharmacists who are independent prescribers (IPs);
• Articulate approaches to supervision;
• Empower newly qualified pharmacists to actively use their prescribing qualification.

Prior to 2022, all pharmacists were required to have a minimum of two years post-registration experience before they could undertake an independent prescribing programme. Following the removal of this requirement, universities are still required to assess applicants’ readiness to prescribe and be assured that they have relevant experience in a UK pharmacy setting and can recognise, understand and articulate the skills and attributes required by a prescriber^​6​.

In 2026, when pharmacists join the register with an IP annotation for the first time, we will have a completely new cohort of pharmacists, who are consolidating their prescribing and professional skills, while also navigating consolidation of their knowledge, competence and confidence across clinical areas and pharmacy practice. This represents an additional challenge for employers and supervisors, as the existing experience and infrastructure is based on the model of individuals consolidating their preregistration education and developing their competence to a more advanced level before introducing prescribing. Therefore, the traditional models of support offered to new registrants will need to evolve to include independent prescribing alongside traditional support for early-career development. 

This article will explore the rationale for developing specific scope of practice guidance for newly qualified pharmacists with an independent prescribing annotation, including the need to adopt a progressive approach that supports ongoing skill acquisition, as well as gradual development of competence, allowing IPs to safely expand their scope of practice. It will also consider the specific requirements of different sectors of practice, with outline examples provided for roles based in secondary care and general practice. The article is based on work recently carried out in NHS England — North West. The views expressed are the authors’ personal views and not the views of NHS England.

Development of competence

To support the implementation of the new standards, there has been significant reform in the delivery of undergraduate pharmacy programmes, with students now undertaking more experiential learning. This allows them to contribute to care delivery and begin developing their clinical skills^​7–9​. The foundation programme has also evolved with each of the statutory education bodies setting clear expectations for the assessment of clinical practice, including prescribing practice, in the workplace^​10,11​.

However, it is well established that pharmacists — like all healthcare professionals — undergo continued development and evolution as they progress in their professional journey beyond registration. It is now incumbent on employers, senior leaders and managers to ensure that this robust system of governance and support extends into the early stages of their career.

The Dreyfus Model of Skills Acquisition provides a helpful conceptual framework for understanding how professional competence develops over time in real-world practice^​12​. Rather than viewing expertise as something acquired at a single point, the model conceptualises development as a progression through distinct stages, from novice to expert. This aligns with current models for post-registration pharmacist development and helps contextualise the expected support needs of newly qualified pharmacists^{​13–15​}.

Figure 1: Graphical description of the Dreyfus Model of Skills Acquisition and how it aligns with evolving clinical practice

As individuals move through these stages, they demonstrate an increasing ability to interpret and respond to clinical situations in context, integrate multiple sources of information and take a more holistic view of decision-making. With experience, actions become less reliant on explicit rules and guidance. They become more intuitive, with reduced need for conscious monitoring of one’s own actions^​12​. 

The Dreyfus Model of Skills Acquisition emphasises that early-career practitioners may require structured support and supervision because their skills are still being actively developed and consolidated. This model of development reaffirms the findings described above and make it clear that newly qualified pharmacists will need opportunities to practice their prescribing skills and gain confidence and competence^​2,3​. They must first establish themselves as safe, proficient practitioners, before further developing their practice towards more autonomous and complex care delivery as expert practitioners. 

Considering scope of practice for newly qualified prescribing pharmacists

As set out above, while changes have been made to the initial education and training of pharmacists to support the development of safe ‘day-one’ prescribing pharmacists, there is ongoing ambiguity on the potential scope of prescribing practice of a newly qualified pharmacist. 

Although the term ‘scope of practice’ is used widely when discussing the evolving roles of pharmacists, there are a variety of definitions used for this term in pharmacy and wider healthcare professions^​16,17​. 

In 2022, the Royal College of Pharmacy (RCPharm) published guidance on expanding scope of prescribing practice, which defines a prescribing scope of practice as follows^​18​:

“Prescribing scope of practice is defined as the prescribing activities a healthcare professional carries out within their professional role. The healthcare professional must have the required training, knowledge, skills and experience to deliver these activities lawfully, safely and effectively. They must also have appropriate indemnity cover for their prescribing role. Prescribing scope of practice may be informed by regulatory standards, the professional body’s policy, employer procedures, guidance from other relevant organisations and the individual’s professional judgement.”

This aligns closely with the definition used by some other professional groups in the UK, like that set out by the Health and Care Professions Council for Allied Health Professionals^​19​. Other regulators have used the term scope of practice to define activities that a professional group could be expected to undertake if appropriately trained and, therefore, introduced explicit limits of these activities, as is the case with the General Dental Council guidance for dental professions, published in 2013^​20​.    

The term scope of practice can relate to a specific element of a professional’s practice (e.g. prescribing) or to their practice more generally. It is not the same as a specialism or a level of practice (e.g. enhanced, advanced, consultant) but it is linked^​21​. 

The scope of practice occurs at two interdependent levels: a confluence of the expectations and permissions of a professional group (or specified subgroup, e.g. newly qualified pharmacists) and the individual’s capabilities and specific permissions. The individual’s scope of practice must sit within the professional scope of practice but does not necessarily include all elements of that professional scope of practice, although it may grow to encompass that full scope over time^​17​.  

An individual’s scope of practice is therefore dependent on a range of factors, including but not limited to their education, knowledge, skills, practice environment, indemnity and several other factors. An individual’s scope of practice will manifest in the level of autonomy with which they can practice and the level of clinical complexity they can appropriately manage.

When dealing with a fundamental change to professional practice or introduction of a new regulated profession (e.g. physician assistants), there is value in developing a commonly understood scope of practice for the new or changing role^​5​. While individuals have a professional requirement to assess and define their scope of practice, employers and supervisors also hold a responsibility and should proactively help set the expectations and boundaries of that scope. As the profession navigates the introduction of newly qualified pharmacists who are independent prescribers, there is an impetus to develop a common understanding of the expected scope and suggest appropriate boundaries for this cohort. 

Practical application for newly qualified pharmacists annotated as independent prescribers

At the time of writing, no national scope of practice guidance has been produced for newly qualified pharmacist prescribers, but there have been calls for support to be produced^​2,3​. In response, local and regional approaches will be required. In the case of the North West region of NHS England, stakeholder groups have set out to describe a scope of practice for this new cohort of prescribing pharmacists^​22,23​. The following section sets out learnings from this process and shares some suggested practical steps and underlying principles that can be followed when attempting to describe a new scope of practice, although, it will be for individual organisations, employers, senior leadership groups and managers to judge the most appropriate approach to take. 

Purpose of a scope of practice description

The first step when developing a scope of practice description is to clearly state the scale, remit and purpose of the proposed scope exercise. In this case, the scope of practice guidance, published in 2025 (log-in required) and developed by stakeholders in the North West of England, was specific to the independent prescribing role of newly qualified pharmacists and the purpose was to:

• Maximise the potential for pharmacists to safely utilise their prescribing capability as part of care delivery, to ensure they maintain and further develop their competence after registration; 
• Minimise the risk to patients and the public of inappropriate prescribing activities by newly qualified pharmacists;
• Establish common minimum expectations for a newly qualified pharmacist prescriber in secondary care and general practice; 
• Provide a framework for newly qualified pharmacist prescribers, preventing them from expanding their scope too rapidly or prematurely introducing activities that may present significant risk to the prescriber and/or the patient^​22,23​.

Any attempt to define a scope of practice should be based on the best available evidence. In the case of newly qualified pharmacist prescribing, which is a novel situation in the UK, scopes will need to be developed by consensus, considering the existing literature and aligned to early-career practice in the context of the existing continuum of practice for pharmacists. 

Considerations in describing a scope of practice for newly qualified pharmacist prescribers 

Scope of practice guidance should adopt a clear structure providing clarity on things such as:

• Underpinning principles, setting out inclusions and exclusions within the term prescribing, contextualising prescribing in practice, limitations, etc.;
• The scale, range and type of activity (e.g. a continuum of practice that describes how newly qualified pharmacists can engage in prescribing and how this can develop over time);
• An approach to supervision and monitoring of practice which accounts for local contexts of different practice settings;
• Considerations for implementation.

It is important that prescribing is considered as an integrated element of a pharmacist’s practice. As experience grows, this will become easier for the profession to do and will be further aided by the forthcoming publication of the RCPharm enhanced curriculum^​24​.

Sector-specific factors

Owing to the main differences in the services, models of practice, governance, employment model and approach to supervision across the diverse sectors of pharmacy practice, approaches are required that allow sufficient specificity to be useful. In the case of the NHS England — North West scope of practice guidance, this meant creating sector specific scope of practice documents for secondary care and general practice. These sectors were identified as being particularly well-suited for guidance development as prescribing is already embedded within service models and organisational governance arrangements. These settings provide immediate, real‑world contexts in which newly qualified pharmacist prescribers are expected to apply, consolidate and expand their prescribing skills, making them appropriate early priorities for structured scope development.

Community pharmacy operates in a very different context with specific opportunities and challenges for the integration of newly qualified IP pharmacists. This was described in a scoping exercise, published by The Pharmaceutical Journal on 15 May 2026, which summarised the state of readiness for large-scale community pharmacy prescribing^​25​. While there are currently no nationally commissioned prescribing services in community pharmacy in England, early work is underway to consider how newly qualified pharmacist prescribers can be supported to maintain and consolidate their prescribing competence. This work builds on the principles and learning from the secondary care and general practice scopes, as well as the evaluation of the NHS England ‘Independent prescribing in community pharmacy pathfinder programme’^​26​, and offers a valuable foundation for this work, helping to avoid deskilling during the early years of practice and supporting readiness for future service development as commissioning and models of care evolve.

Features of a secondary care scope of practice for newly qualified pharmacist prescribers

Developing a scope of practice for secondary care should take account of current models of service delivery and support, which should consider and describe the types of providers (e.g. teaching hospitals, district generals, specialist and mental health trusts). 

The NHS England — North West secondary care scope of practice guidance covered all hospital settings and was designed to be structured and progressive with prescribing activity described as a continuum that reflects increasing levels of responsibility, complexity and autonomy (see Table^​22​). In the earlier post-registration phases, prescribing is focused on activities that are closely aligned to established early-career pharmacist practice (category 1 and 2a activities), such as medicines reconciliation, optimisation of existing therapy, dose adjustment in response to clinical parameters and correcting prescribing errors. These activities allow newly qualified pharmacist prescribers to apply prescribing skills in more controlled, guideline-driven and supervised contexts while building familiarity with local systems and multidisciplinary working^​22​.

Table: Continuum of prescribing practice for newly qualified pharmacist prescribers in secondary care

As competence and confidence develop, the continuum supports progression to initiating treatment in line with clearly defined local protocols and guidelines (category 2b activities) and prescribing following multidisciplinary discussions or ward rounds based on diagnoses made by other clinicians (category 3 activities). At later stages, pharmacists may begin to develop an individualised scope of prescribing practice within a defined clinical area, taking responsibility for diagnosis and initiation of treatment where this is supported by training, experience and service need (category 4 activities). Importantly, the scope emphasises that progression through the continuum is not time-based alone, but dependent on demonstrated competence, supervision and organisational assurance^​22​.

Supervision is a core enabler of safe prescribing practice in secondary care and should be reflected in the guidance accompanying a scope of practice. Rather than introducing separate or parallel prescribing supervision structures, seamless approaches to prescribing oversight should be embedded within existing educational, clinical and governance processes wherever possible. Newly qualified pharmacist prescribers should have regular access to experienced pharmacist prescribers and the wider multidisciplinary team, with prescribing decisions discussed regularly. Levels of oversight are expected to reduce gradually over time as competence is demonstrated, while maintaining clear routes for escalation, review and shared decision-making^​22​.

Resources should be developed to support implementation. In the NHS England — North West example, a practical toolkit was designed to prompt organisations to consider how the principles can be operationalised within local governance arrangements^​22​. The implementation resources encourage early engagement with senior clinical and managerial stakeholders, alignment with non-medical prescribing policies, clarity around accountability and assurance, as well as explicit consideration of professional indemnity arrangements. It also highlights the need to prepare supervisors, line managers and teams for prescribing at the point of registration, ensuring that expectations are shared and that newly qualified pharmacist prescribers are supported to practise safely within agreed boundaries.

Features of a general practice scope of practice for newly qualified pharmacist prescribers

Guidance for a general practice scope of practice for newly qualified pharmacists who are independent prescribers needs to be explicitly tailored to the distinctive clinical, organisational and supervisory environment of general practice. Guidance should recognise that prescribing in general practice often occurs with a high degree of autonomy — across a wide range of conditions — and within varied employment and supervision models, necessitating additional clarity around boundaries, support and progression for newly qualified pharmacist prescribers.

In the NHS England — North West example, the general practice prescribing continuum describes how newly qualified pharmacists can begin prescribing within clearly defined activities that are embedded within existing general practice workflows (see Figure 2^​23​). In the earlier postregistration phases, recommended activity includes medicines reconciliation, repeat prescription authorisation within agreed parameters and prescribing as part of structured medicines reviews or long-term condition management for less complex, stable patients with clear treatment protocols. These activities allow prescribing to be integrated into routine care, managing exposure to high clinical complexity or risk while acknowledging that any consultation can introduce unexpected complexity^​23​.

Figure 2: Continuum of prescribing practice for newly qualified pharmacist prescribers in general practice

As consolidation progresses, the described continuum supports expansion to more complex activities (e.g. complex medicines reviews, a broader range of long‑term conditions, greater autonomy in clinical decision‑making). However, boundaries of practice will remain important and the NHS England — North West guidance is explicit that not all prescribing activities are appropriate for early‑career pharmacists. Specific areas are identified — such as acute, undifferentiated presentations or highly complex cases — as out of scope during the early stages of progression^​24​.

Supervision arrangements are also a defining feature of a general practice scope. Strong emphasis should be placed on embedding newly qualified pharmacist prescribers within established pharmacy and practice infrastructure, rather than deploying them as isolated prescribers. Regular, structured supervision from experienced general practice pharmacist prescribers is recommended, alongside access to wider clinical support from the multidisciplinary team. Supervision should be framed as developmental rather than restrictive, incorporating direct observation of practice, review of prescribing data, case‑based discussion and reflective portfolio evidence to support progression through the continuum.

As with secondary care, implementation recommendations are needed. In the NHS England — North West example, these include considerations prior to recruitment, such as readiness of the practice to support early-career prescribers, supervision capacity and alignment of the role with the initial prescribing scope^​23​. Guidance should also address induction and onboarding, supporting the explicit inclusion of prescribing, including recommendations that job descriptions reflect prescribing responsibility and non-medical prescribing policies are reviewed to avoid inappropriate restriction. Ongoing considerations include agreeing escalation routes, defining supervision plans and milestones for progression, as well as ensuring prescribing activity is reviewed and assured as part of routine governance and appraisal processes^​23​.