Radiotherapy Prescribing Framework for those not on the Specialist Register for Clinical Oncology

In the UK, the prescription of radiotherapy for therapeutic purposes is governed by IR(ME)R legislation. For full governance process this legislation requires local protocols to be in place. These protocols define who can prescribe radiotherapy completely independently as a “practitioner” as well as those who can prescribe under a local competency framework as an “operator”.

The vast majority of those who prescribe radiotherapy in the UK work as practitioners and hold substantive consultant clinical oncology appointments in the NHS and are on the GMC specialist register for clinical oncology. They have all completed specialist training in a clinical oncology numbered training post (NTN) or been formally recognised as deemed to be equivalent to a doctor who has completed this training.

The next largest group prescribing radiotherapy comprises those holding a NTN in clinical oncology. They usually prescribe as a practitioner, but dependent on departmental protocols may be classified as operators. The curriculum does not describe at which point independent prescribing is allowed to those still in training.

Anecdotal information suggests most departments have used success in the FRCR examination as a basis for determining radiotherapy prescribing competency. Increasingly, an additional locally developed competency package is used to complement this. Often completion of First FRCR and local competency assessments are used to allow independent prescribing of palliative treatments and Final FRCR for radical therapies. However, the actual framework is determined and governed by local IR(ME)R policies, not national guidance.

The remaining groups who prescribe radiotherapy without the FRCR comprise those doctors employed as specialty doctors or associate specialists (SASG) and advanced practitioner radiographers. Each of these groups will comprise a mixture of those acting as operators or practitioners depending on local IR(ME)R protocols. This is the most heterogeneous group in terms of experience and formal training, including qualifications. Whilst there is no essential requirement for those prescribing radiotherapy to have an FRCR or indeed a primary medical degree it is essential to ensure a consistent overall approach to the competencies required within a radiotherapy service.

In terms of support for those prescribing radiotherapy who are not on the GMC specialist register as clinical oncologists, we would recommend:

1. A defined locally recognised competency framework for all aspects of the relevant site specific patient pathway including:
   1. Interpretation of diagnostic imaging
   2. Understanding of radiotherapy indications
   3. Obtaining informed consent for treatment, including assessment of capacity
   4. Knowledge of local radiotherapy treatment protocols
   5. Understanding of the likely side effects of radiotherapy, and their management
   6. Understanding of the principles of training and the assessment of competency
2. Clear local IR(ME)R policies which allow prescription of radiotherapy by those without FRCR and / or a medical degree within the practitioner’s defined range of competence
3. An identified clinical oncology consultant to provide mentoring, appropriate peer review and advice
4. Inclusion in department wide radiotherapy quality assurance and peer review activities, such as radiotherapy planning meetings, non-conformance / incident review meetings and tumour site specific meetings e.g. MDT
5. Access to defined study leave (including the associated budget) to maintain appropriate CPD in relevant tumour site(s)