Blank Prescription Form Security in Dental Practices: A CQC Compliance Guide
Blank prescription forms may look like ordinary stationery, but they represent a significant security and patient-safety risk. In the wrong hands, a blank prescription form can be altered or used fraudulently to obtain controlled drugs, high-value medicines or medicines that could cause serious harm.
Dental practices that hold FP10D, FP10PCD or other prescription forms should therefore have clear systems covering their ordering, receipt, storage, use, monitoring and destruction.
The Care Quality Commission considers prescription security when assessing whether a dental practice is safe and well governed. Poor controls could indicate that a practice is not meeting the requirements of Regulation 12, safe care and treatment, or Regulation 17, good governance.
This guide explains what dental practices should do to secure blank prescription forms, maintain an effective audit trail and prepare suitable evidence for a CQC inspection.
Why is blank prescription form security important?
A blank prescription form should be treated as controlled stationery.
Although it does not contain medication or patient details, it has financial value and can potentially be used to obtain medicines fraudulently. The NHS Counter Fraud Authority describes prescription forms as assets that can act like blank cheques when they fall into the wrong hands.
The risks include:
blank forms being stolen from an unlocked cupboard or drawer
forms being removed by an unauthorised member of staff
prescription pads being left unattended in a surgery
forms being left inside an unlocked printer tray
practice stamps being stored with blank forms
missing forms going unnoticed because serial numbers have not been recorded
obsolete or spoiled forms being placed in ordinary waste
blank forms being pre-signed
prescription pads being lost during domiciliary visits
forms remaining accessible to a former employee or locum
fraudulent prescriptions being produced using stolen forms
The consequences can extend beyond financial fraud. A fraudulent prescription could allow someone to obtain medicines without a clinical assessment, creating a direct risk of overdose, misuse, dependency or other harm.
What does CQC expect from dental practices?
CQC Dental Mythbuster 36 explains that inspectors consider the use and disposal of prescriptions when reviewing whether a dental practice is safe.
CQC expects practices to have effective systems that prevent theft and misuse. This includes:
secure storage of blank forms
a policy defining responsibilities
local procedures for missing, lost or stolen forms
controls over who can access prescription forms
records of prescription form movements
recording relevant serial numbers
regular stock checks
appropriate arrangements for domiciliary visits
staff who understand what to do if forms cannot be accounted for
Inspectors are unlikely to be satisfied by a policy that staff do not follow. The practice should be able to demonstrate that its controls work in day-to-day operations.
This means having completed logs, documented stock checks, staff training records and evidence that discrepancies have been investigated.
Create a prescription form security policy
Your practice should have a written policy or standard operating procedure covering the complete life cycle of prescription forms.
The policy should explain:
Who is authorised to order forms.
Who is permitted to accept deliveries.
How deliveries are checked.
Where forms are stored.
Who can access the secure storage area.
How forms are issued to individual prescribers.
How serial numbers are recorded.
How frequently stock is reconciled.
What happens to returned, obsolete or spoiled forms.
What staff must do when forms are missing, lost or stolen.
How forms are managed during domiciliary visits.
How the practice manages access for locums and temporary staff.
How incidents are investigated, reported and reviewed.
The policy should reflect the actual arrangements in your dental practice. Copying a generic policy without adapting it to your premises, staffing structure and prescribing activity may leave important risks uncontrolled.
Nominate a suitably senior person to oversee the process. In many dental practices, this may be the practice manager, registered manager, principal dentist or medicines lead.
Ordering and receiving prescription forms
Dental practices in England normally order NHS prescription forms through Primary Care Support England. PCSE states that dental practices can order NHS prescriptions and other secure stationery through its online supplies service.
Access to ordering functions should be restricted to authorised staff. Where practicable, the person ordering forms should not also be solely responsible for receiving and checking them. Separating these duties can help detect errors or inappropriate activity.
When a delivery arrives, the receiving member of staff should check it promptly against the order.
The record should include:
date and time received
order or delivery reference
type of prescription form
number of forms or pads received
first and last serial numbers
name or initials of the person accepting delivery
name or initials of the person checking it
storage location
details of any discrepancy
The NHS Counter Fraud Authority’s August 2025 guidance states that organisations should maintain clear and unambiguous records of prescription stationery received and distributed.
If the number of forms or serial-number range does not match the delivery information, the discrepancy should be investigated immediately. Staff should not simply assume that the remainder will arrive separately.
How should blank prescription forms be stored?
Blank prescription forms should be secured as soon as practicable after delivery.
The NHS Counter Fraud Authority recommends storing forms in a locked cabinet within a lockable room or area. Access should be limited to authorised staff.
Good storage controls include:
using a robust locked cupboard or cabinet
restricting access to named members of staff
controlling access to keys or electronic entry codes
keeping the storage area away from public access
avoiding open shelving and unlocked desk drawers
returning unused forms to secure storage at the end of a session
not leaving forms unattended in surgeries, reception areas or staff rooms
checking whether forms have been left in printer trays
periodically reviewing who still requires access
The storage arrangements should be proportionate to the number and type of forms held, the practice layout and the level of public access.
A locked drawer inside an unlocked room that can be entered by patients, visitors or contractors may not provide sufficient protection.
Store practice stamps separately
Practice and dentist stamps should be stored securely and separately from prescription forms.
A stolen blank form becomes harder to identify as suspicious if it has also been stamped with genuine practice details. Keeping the stamp and forms together therefore increases the potential impact of a theft.
Practices should avoid stamping multiple blank forms in advance. A form should only be stamped when it is required as part of the authorised prescribing process.
Blank prescription forms must never be pre-signed.
Maintain a prescription monitoring log
A prescription monitoring log creates an audit trail showing what happened to each pad or range of forms.
The log may be maintained electronically or on paper. An electronic system can make reconciliation and audit easier, provided access is appropriately controlled and records cannot be changed without accountability.
At a minimum, consider recording:
date and time of the transaction
type of movement, such as received, issued, returned or destroyed
type of prescription form
order or transaction reference
number of forms involved
first serial number
last serial number
original storage location
person, prescriber or location receiving the forms
name or initials of the person completing the transaction
name or initials of the person checking or authorising it
outcome or explanatory notes
whether any follow-up is required
A separate stock-check record can document the physical count, expected stock, first remaining serial number in an active pad and any difference found.
Do not enter patient names, NHS numbers, clinical information or medication details in a blank-form stock-control log. The purpose of this log is to monitor controlled stationery, not duplicate clinical records.
Download the free dental prescription monitoring log
To make this process easier, download the free Dental Prescription Form Monitoring Log.
The workbook includes:
a prescription form stock register
a periodic stock-check sheet
an incident log
drop-down movement and incident categories
fields for first and last serial numbers
colour-coded discrepancy and investigation flags
guidance notes for staff
links to the relevant official guidance
The template should be adapted to your practice policy, prescribing arrangements, local commissioner requirements and records-retention schedule.
How often should prescription forms be checked?
CQC refers to regular stock checks but does not prescribe one universal frequency for every dental practice.
The frequency should be determined by a documented risk assessment. Factors to consider include:
the number of forms held
how frequently prescriptions are issued
the number of authorised prescribers
whether pads are shared
whether locums use the forms
whether the practice provides domiciliary care
the security of the premises
previous discrepancies or incidents
the number of staff with access
whether prescription forms are loaded into printers
A practice that rarely issues prescriptions may still need routine checks. Infrequent use can increase the risk that a missing form remains unnoticed for a long period.
The NHS Counter Fraud Authority describes recording the first remaining form in an in-use pad at the end of the working day as good practice. This makes it easier to identify forms that disappear overnight.
Your policy might include a combination of end-of-session controls, periodic formal reconciliation and additional checks following staffing changes or incidents.
Issuing forms to dentists and locums
When a prescription pad or group of forms is issued to a dentist, the practice should record:
the date and time
name of the prescriber
form type
first and last serial numbers
number of forms issued
person issuing the forms
expected return arrangements
actual forms returned
any spoiled, used or unaccounted-for forms
Locum and temporary dentists should be included in the same control process. They should receive information about the practice’s prescription security procedure before they are given access.
The practice should not assume that an experienced locum already knows the local arrangements. Storage locations, reporting contacts and recording systems differ between providers.
When a dentist leaves the practice, changes location or no longer has prescribing responsibilities, unused personalised forms should be recovered and securely destroyed where appropriate. Access permissions, keys and relevant system access should also be reviewed.
Domiciliary dental visits
Taking prescription forms away from the registered location creates additional security risks.
Only the minimum number of forms required should be taken. Their serial numbers should be recorded before the dentist leaves the practice.
Forms should be carried in a lockable case and kept out of sight until required. They should not be left visible in a vehicle and should never remain in a vehicle overnight.
After the visit, unused forms should be returned to secure storage and the movement recorded.
If a form is issued, spoiled or cannot be accounted for, the log should be updated immediately.
Spoiled, duplicate and obsolete prescription forms
Spoiled, duplicate and obsolete forms must not be thrown into ordinary waste.
If an error is made, the prescriber may clearly mark the form as spoiled or securely destroy it and start again, depending on the circumstances and local policy.
Forms requiring destruction should be rendered unusable, such as by secure shredding, before being placed into confidential waste. The serial numbers should be recorded.
The updated NHS Counter Fraud Authority guidance states that destruction should be witnessed by another member of staff. Records should identify:
date of destruction
reason for destruction
type and number of forms
serial numbers or serial-number range
person destroying the forms
witness
disposal method
Records should be retained in accordance with the practice’s approved records-retention policy.
What should you do if a prescription form is missing?
A missing form should be treated seriously and investigated without delay.
The immediate steps should include:
Check the physical stock again.
Review the monitoring log and recent transactions.
Confirm whether the form was issued, returned, spoiled or transferred.
Identify the serial number or likely serial-number range.
Notify the practice’s designated responsible person.
Secure the remaining stock.
Record the matter through the practice incident-reporting system.
Follow local reporting arrangements.
Depending on the circumstances, notifications may need to be made to the supplier, police, Controlled Drugs Accountable Officer, Local Counter Fraud Specialist or those responsible for organisational security.
Where fraud is suspected, the incident should be reported to the NHS Counter Fraud Authority. Its current guidance provides an incident-response table showing the contacts that may be appropriate for different situations.
The practice should document who was notified, when the notification was made and any reference number provided.
After the immediate response, carry out a documented review. Identify how the incident happened, whether controls were followed and what needs to change to prevent recurrence.
What evidence might a CQC inspector review?
A CQC inspector may look for evidence that prescription security arrangements are both documented and implemented.
Useful evidence may include:
the prescription security policy or SOP
a prescription form risk assessment
the completed stock register
delivery and order records
serial-number records
periodic stock-check records
records of forms issued to dentists or locums
destruction records
incident reports and investigations
staff training or briefing records
an authorised-access list
evidence of action following previous discrepancies
checks showing that practice stamps are stored separately
evidence that blank forms are not left in printers or unattended areas
Inspectors may also speak to staff. Team members should know where forms are stored, who is authorised to access them and what they must do if a form is missing.
Common prescription security mistakes
Frequent weaknesses include:
relying on a delivery note without maintaining an internal register
recording the number of pads but not their serial numbers
leaving blank forms in printer trays overnight
storing a practice stamp beside the prescription pad
allowing too many staff to access the storage cupboard
failing to remove access when an employee leaves
issuing pads to locums without recording them
carrying an entire pad on a domiciliary visit
failing to document spoiled forms
destroying obsolete forms without recording or witnessing the destruction
having no clear incident-reporting procedure
completing stock checks but failing to investigate differences
A log is only effective if it is kept up to date and reviewed. Reconstructing entries immediately before an inspection is unlikely to provide a reliable audit trail.
Frequently asked questions
Does CQC require a specific prescription log template?
CQC does not prescribe one mandatory template. The practice needs a system that is suitable for its service and provides a clear audit trail.
Must dental practices record prescription serial numbers?
Current CQC and NHS Counter Fraud Authority guidance supports recording serial numbers to control and track prescription form movements. The first and last serial numbers of pads or batches should be recorded.
Can blank prescription forms be kept in a locked surgery?
They should be kept in a locked cabinet within a lockable room or controlled area, with access restricted to authorised staff. The practice should assess whether its arrangements provide effective protection.
Can a dentist pre-sign blank prescriptions?
No. Blank prescription forms should never be pre-signed.
Should prescription forms and practice stamps be stored together?
No. Practice and dentist stamps should be secured separately from blank prescription forms.
How long should prescription monitoring records be kept?
The practice should follow its approved records-retention policy and any applicable local requirements. Specialist Pharmacy Service guidance advises retaining records of serial numbers for blank forms received for at least three years after the form is used. Destruction and incident records should follow the relevant organisational retention schedule.
Final prescription security checklist
Your dental practice should be able to confirm that:
blank prescription forms are treated as controlled stationery
a responsible person oversees the process
ordering and receipt are restricted to authorised staff
deliveries are checked promptly
serial numbers are recorded
forms are stored in locked facilities
practice stamps are stored separately
blank forms are never pre-signed
issue, return, transfer and destruction are documented
regular reconciliation checks take place
domiciliary and locum arrangements are controlled
missing forms are reported and investigated promptly
staff understand the procedure
records can be produced during a CQC inspection
Effective prescription security does not need to be complicated. A clear policy, secure storage, an accurate monitoring log and staff who understand their responsibilities will provide a strong foundation for safe and accountable prescribing.
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