Guidance on Dispensing Prescriptions Issued in Another EEA Member State
The PSI has received a number of queries in relation to dispensing prescriptions issued in another EEA Member State. To address this, we have prepared the following information for pharmacists.
Pharmacists in Ireland are authorised to dispense from a prescription that is issued by a registered practitioner practising in another European Economic Area (EEA)* Member State provided certain conditions are met, and the prescribed medicine is authorised for use in Ireland and is not a controlled drug.
Legislative basis
The legislative basis in Ireland for dispensing prescriptions issued in the EEA is primarily governed by the Medicinal Products (Prescription and Control of Supply) Regulations 2003 (as amended), in particular Regulation 7(1A). These regulations outline the requirements for the dispensing of a prescription issued by a registered medical practitioner, a registered dentist or a registered nurse practising in an EEA State other than Ireland or the UK, which is presented by a patient for dispensing in Ireland.
The intention of the legislation is to ensure EU patients’ rights to access cross-border healthcare and medicines.
Electronic prescribing system
While a registered practitioner in Ireland can email prescriptions to a pharmacy using Healthmail in Ireland, there is no domestically approved electronic prescribing system to receive and dispense e-prescriptions issued in another EEA Member State.
It is worth noting that ePrescription services are being introduced across the EU but are not currently available in all countries. You can refer to the National ePrescribing Project - eHealth Ireland for up to date information and developments in this area also.
Guiding principles to consider prior to dispensing prescriptions issued in another EEA Member State
Before dispensing a prescription issued in another EEA Member State, you should consider the following five guiding principles to effectively mitigate risks and prioritise patient-centred safety and care:
1.1 You verify the authenticity of the prescription to ensure it is issued by a registered practitioner/qualified healthcare professional in an EEA country. It is important that you only dispense prescriptions where you can verify the registration status and authorisation of the prescriber.
1.2 The prescription must be traceable back to a prescriber so there is a clear and documented record linking the prescription to the prescriber who issued it. For example, this may include a direct email from the prescriber in an EEA Member State to the pharmacy, or the prescriber may issue a paper copy of the prescription. A prescription presented on a patient’s phone/electronic device would not be considered appropriate as it is not traceable back to the prescriber, making it difficult to confirm its legitimacy or authenticity.
1.3 You can check the regulated professions database on the Europa website. This contains lists of regulated professions by Country, with Competent Authorities.
2.1 While there is no specific form or format for an EEA prescription, it must, at a minimum, contain the following information:
(a) Be in ink or permanent and unalterable electronic form and be signed and dated by the person issuing the prescription with his or her usual signature, either in handwriting or by electronic signature;
(b) Clearly indicate the full name, including the full first name of the person issuing the prescription and specify his or her professional qualification;
(c) Specify the work address, including the name of the relevant state, of the person issuing the prescription;
(d) Specify the email address, and telephone or fax number (with the appropriate international prefix) of the person issuing the prescription;
(e) Specify the full name, including the full first name, and date of birth of the person for whose treatment the prescription is issued; and
(f) Specify the following details, where applicable, of the product to be supplied on foot of the prescription:
i. The common name of the medicinal product;
ii. The brand name of the medicinal product if:
- The medicinal product prescribed is a biological medicinal product, or
- The person issuing the prescription has deemed it medically necessary to include the brand name on the prescription and has stated on the prescription the reasons justifying the use of the brand name;
iii. The pharmaceutical form;
iv. The quantity
v. The strength of the medicinal product; and
vi. The dosage regime
3.1 You review and evaluate the prescription with respect to its suitability, safety, and the appropriateness of the prescribed medicine for the patient, using your professional judgement and considering individual patient circumstances.
While electronic prescriptions may be endorsed digitally in some Member States, this is not available in Ireland. Therefore, you must print a copy of the EEA prescription as transmitted and treat it as an original prescription for record-keeping and to assist with dispensing preparation and checking.
5.1 You should be able to verify the validity and contents of any prescription which is being presented for dispensing and also have the facility to easily contact the prescriber to seek clarification when needed. In certain cases, you will have to consider language barriers and take appropriate measures to ensure accurate interpretation and communication.
Using professional judgement
By considering the guiding principles above and applying the Code of Conduct for pharmacists, you should use your competence and expertise to make informed decisions regarding the safety and appropriateness of supplying medicines to patients based on prescriptions issued in another EEA member state. You must still be satisfied that, in your professional judgement, it is safe to make any supply in the context of the information received.
However, if, based on your professional judgement, you consider it unsafe or inappropriate following a medicine therapy review and/or if you are not satisfied that the prescription is legally valid to dispense, it is important that you communicate the reasons for not dispensing the prescription to the patient and refer the patient to another healthcare professional, as appropriate. It is also important that you record any decision made in the exercise of your professional judgement not to dispense the prescription on the patient’s medication record.
Limitations/exclusions for dispensing prescriptions issued in another EEA Member State
Pharmacists in Ireland are not authorised to supply:
- Controlled drugs from a prescription issued by a registered practitioner practising in another EEA member state. A controlled drug is a medicinal product listed in schedules 1, 2, 3, and 4 to the Misuse of Drugs Regulations 2017 (as amended).
- Unlicenced medicines from a prescription that is written by a registered practitioner practising in another EEA member state.
Emergency supply
The ‘emergency supply’ provisions of Regulation 8 of the Medicinal Products (Prescription and Control of Supply) Regulations 2003 (as amended) permit pharmacists, in emergency circumstances, to supply certain prescription-only medicines without a prescription.
Please note that the emergency supply provisions do not extend to controlled drugs at the request of a prescriber where the prescriber is located in another EEA Member State.
See further information on Emergency Supply.
Ethical dilemmas occur every day in practice. The ability to make sound ethical decisions is a fundamental responsibility of pharmacists as healthcare professionals. The Ethical Decision Making Tool is designed to support pharmacists as a guide in decision making when they are presented with an ethical dilemma or issue.
*The EEA is an area of free trade and free movement of peoples comprising the member states of the European Union, in addition to Norway, Iceland and Liechtenstein.
