Accountable officer notification - helpful information

Below are some of the points on which the Healthcare Commission’s Controlled Drugs Regulation team has provided advice about Accountable Officer (AO) notifications:

Access to notification web form

For the password to log on to the notification form, please email feedback@healthcarecommission.org.uk, quoting your name, role and organisation, and we will email you the password.
If you are unable to access the web form, please send us an email so that we can investigate.
When you have submitted your completed form, you will receive an email acknowledging receipt. This email includes a reference number and a PDF file with a copy of the information you have submitted. If you do not receive this within 48 hours then please email us at: feedback@healthcarecommission.org.uk.
If you have previously notified us of your AO and now want to update the details, please type your reference number into the form. The reference number is located in the top left hand corner of the PDF file automatically generated when you first notify us of your appointment of an AO. If you have lost the reference number, email us at feedback@healthcarecommission.org.uk and we will email it to you.
If the web form rejects your reference number, this may be due to a simple error. Please check that you have entered CDAO (O being a letter) and not CDA0 (0 being a number).
If you select “Other” for the question “How does this person meet the ‘seniority’ requirements set out in regulation 5? (subsection (1) (a) for independent hospitals, or subsection (5) (a) for NHS organisations)”, then you will encounter a warning message on the next form. The message is just a warning and will not stop you from proceeding and completing the form. You may wish to add a note in the box when the form asks if you wish to provide any more information to explain why you think this person meets the requirement.
If you select “Yes” for the question “Does this person routinely supply, administer or dispose of controlled drugs as part of their duties? (see regulation 5 (1 or 5) (b))”, then you will encounter a warning message on the next form. The message is just a warning and will not stop you from proceeding and completing the form. You may wish to add a note in the box when the form asks if you wish to provide any more information to explain why you think this person meets the requirement.

Suitable person to be accountable officer (AO)

The requirements for a suitable AO are contained within regulation 5 of Controlled Drugs (Supervision of Management and Use) regulations 2006 available on the Internet and also available in print version from The Stationery Office. More detailed guidance can be found in the Safer Management Of Controlled Drugs: (1) Guidance On Strengthened Governance Arrangements, published 1st Jan 2007 from the DH website.

The Controlled Drugs (Supervision of Management and Use) Regulations 2006 (opens new window)

Safer Management Of Controlled Drugs: (1) Guidance On Strengthened Governance Arrangements (opens new window)
The AO does not have to have a clinical background.
Someone who does occasional clinical sessions, which may occasionally involve them supplying or administering controlled drugs, may be appointed as AO provided that they put in place formal, documented arrangements for scrutiny by someone else in case of possible conflict of interest. For example, if someone reported concerns about their own handling/use of CDs. However it would not be appropriate to appoint as AO someone who does occasional clinical sessions such as in the areas of substance misuse or palliative / pain relief, since these are likely to involve CD activity.
If you are having difficulty in finding someone within the organisation who meets the requirements of both seniority and not handling controlled drugs routinely, then please ask us for advice and we will try to help. It is your responsibility to find someone suitable and you may want to consider putting appropriate arrangements in place to avoid 'conflict of interest' by delegating duties to another member of staff.
You are not required to inform us of the job role of the AO, but in many cases this is apparent to us from the notification details anyway. People in a wide variety of job roles have been appointed as AO, including (amongst others): clinical governance director, executive director, director of public health, nursing director, head of medicines management, chief pharmacist, and registered manager. You need to select the most suitable person in your circumstances and not assume that just because another organisation has appointed their nursing director (say) that you should do so too.
Please notify us of any interim or temporary acting appointments to the AO role. If someone is off sick for a short period or away on holiday then you do not need to let us know, but if the AO is on long term sick leave or on a sabbatical please notify us of who is acting in the role.
In certain circumstances two NHS trusts of the same type can share an AO. You need to fill in the form twice, once for each trust, and explain the circumstances in the comments box.
Two independent hospitals may be able to share an AO if both have the same registered manager. You need to fill in the form twice, once for each establishment, and explain the circumstances in the comments box.
On appointment to the role of AO you will no longer be able to remain, or become, a person authorised to witness the destruction of controlled drugs, even if you were previously authorised to do so.

Organisations that need an accountable officer (AO)

If you do not administer or hold controlled drugs; you are still required to register an AO with the Healthcare Commission if you are a Designated Body: i.e. an independent hospital or an NHS organisation (PCT, NHS Trust, Foundation Trust). If your CD handling is minimal, then the responsibilities for the AO should also be proportionately small. You will be expected to link to your Local Intelligence Networks to share information and be aware of any issues in your area.
Establishments registered with the Healthcare Commission under one of more of these service user categories fall under the definition of "independent hospital" for the purposes of the CD regulations, and hence are controlled drugs designated bodies (CDDBs) and need to appoint an AO.

AH - Acute hospitals (with overnight beds)
AH(DS) - Acute hospital (day surgery only)
H(A) - Hospice for adults
H(C) - Hospice for children
MH - Mental health establishments, not including those where people are liable to be detained
MH(D) - Mental health establishments taking people liable to be detained
A clinic or private doctor handling controlled drugs does not need an AO unless they are registered with the Healthcare Commission under one of the six specified service user categories. However they will need to ensure good governance arrangements for controlled drugs, and where appropriate link into Local Intelligence Networks.

Occurance report - controlled drugs concerns

A draft template form is available to download below. this may be adapted for use by accountable officers for quarterly reports of any concerns that their designated body has regarding management and use of controlled drugs (clause 29). The form has been produced by the Healthcare Commission controlled drugs regulation team, and should be further developed within the local intelligence network in the light of experience in use.
To download the report to your computer, click the right mouse button, and select 'Save Target As...'

Occurance report template (doc 89kb) (opens new window)

Scope of accountable officer role

The scope of the accountable officer role is covered in:
Part 2 of the Controlled Drugs (Supervision of Management and Use) Regulations 2006 (opens new window)

Self assessment tool

We have developed a self-assessment tool for primary care trusts to check how they are doing in terms of controlled drugs governance.

More information about the self assessment tool

Healthcare providers