Prescription only medicine law change for hygienists and therapists

In a move designed to improve access to dental care and make better use of the skills within the dental team, trained and competent dental hygienists and therapists can now supply and administer certain prescription-only medications (POMs) without sign-off from a dentist.

This is good news if you want greater independence to work within your scope of practice, but there are some things you need to know first.

1. You no longer need a patient group direction

Before June 2024, you needed a valid prescription, patient specific direction (PSD) or patient group direction (PGD) before you could give patients medication such as high-strength fluoride treatment or a local anaesthetic.

However, an amendment to the Human Medicines Regulations 2012 introduced exemptions for suitably trained dental hygienists and therapists to supply or administer specific prescription-only medicines, including high-strength fluoride and local anaesthetics. You can find a full list in Schedule 17 of the regulations (part 2, para 13).

PGDs are now being phased out for the supply or administration of these listed medications, and NHS England says that existing PGDs won’t be renewed or replaced after they’ve expired.

Instead, practices should transition to working under exemptions or PSDs (written instructions from a dentist to administer a specific medicine to the individual patient).

2. You still can’t prescribe

While the new rules allow suitably trained dental hygienists or therapists to supply or administer a listed medication without a PGD or PSD, they don’t change its POM status, nor do they give you prescribing powers.

For instance, you  can’t write an NHS or private prescription for high concentration fluoride toothpaste  to be supplied by a pharmacy. That can only be done by a dentist or another prescriber.

3. Check with your dental school about training

The ‘Standards for the dental team’ says you must be “appropriately trained, competent, confident and indemnified” before carrying out any task or treatment and the GDC expects, “dental hygienists and dental therapists to be able to demonstrate successful completion of a training course” to work under exemptions.

Meanwhile, NHS England has set out a curriculum and qualifying criteria for hygienists and therapists covering areas such as assessing patients, the responsible use of medicines, obtaining valid consent, and record-keeping. There’s also an NHS e-learning training module.

The training and learning outcomes should be integrated into dental school curriculums for hygienists and therapists to eliminate the need for post-graduate training. However, it might take time for your school to amend the curriculum to incorporate this.

If you’re about to qualify, check with your dental school if they can provide written confirmation that you are safe, effective, and competent in the supply and administration of specific medicines within the legal framework. You can then show this to a practice owner if you both agree that you can work under the exemptions.

If your school has not been able to train you to work under these exemptions, you will need to do a course that meets the curriculum set out by NHS England.

4. Work with your practice owner and colleagues

It’s not compulsory for you to work under exemptions if you don’t feel comfortable with this. NHS England says that the decision should be “reached collaboratively” with the NHS contractor or practice owner.

In earlier guidance on supporting the use of the skill mix in dental practice, NHS England accepts that the role of dental care professionals (DCPs) will vary depending on factors like confidence, professional development, and experience.

It says: “DCPs should be supported to work within their scope of practice in a way that enables them to use their training and advance their knowledge and skills,” and recommends regular and frequent opportunities for team and one-to-one meetings and developing practice treatment protocols with the clinical team.

It adds: “the GDC, the British Society of Dental Hygiene and Therapy (BSDHT) and the British Association of Dental Therapists (BADT) consider it good practice for newly qualified DCPs to work according to the treatment plan provided by a dentist while they build up their experience and confidence.”

If you want to supply or administer medication under exemptions, we recommend talking to your practice about the additional support you might need, at least initially.

In addition, the GDC expects you to “work with colleagues in a way that serves the interests of patients” (principle 6 of ‘Standards for the dental team’). This includes referring patients when something is outside your scope or competence and communicating clearly and effectively with other team members.

It's also important that practices that offer direct access to dental hygienists and therapists provide information to patients about what treatment and care can be done by each member of the dental team.

5. You don’t need to tell the DDU

You won’t need to tell us that you’re working under exemptions or update your membership – we consider this part of your work once you have been trained to do it.

If your practice owner wants to check that you have appropriate indemnity, you can simply show them your proof of DDU membership.

To learn more about the training required for hygienists and therapists, including the proposed course content and curriculum, continue reading.

 

Not a DDU member?

The DDU is here for you as a student and throughout your dental career. Visit the join DDU pages to explore the benefits of membership now and beyond graduation.  

This page was correct at publication on 30/04/2025. Any guidance is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.