POM-A lets a podiatrist administer ten named prescription-only medicines, mostly local anaesthetics. POM-S lets them sell or supply eleven, mostly antibiotics and topical treatments. They are separate annotations with separate training, and holding one does not give you the other.
Finding the actual lists is unreasonably hard. The HCPC confirms the annotations exist and points readers to the MHRA. The Royal College of Podiatry's guidance sits behind member login. The lists are published on gov.uk, in a document about several professions at once, which is why almost nobody in the podiatry-facing web has reproduced them.
So here they are, with the conditions attached.
What is an annotation?
An annotation is an entry against your name on the HCPC register recording an additional entitlement beyond your core registration. For podiatrists there are two relevant to medicines, plus independent and supplementary prescribing at a higher level.
A confusing wrinkle worth naming: gov.uk still uses the older language of a certificate of competence in places, while the HCPC talks about annotations. They are describing the same entitlement. If you have a certificate and no annotation, the annotation is the thing that counts, because that is what appears on the public register.
What can you administer under POM-A?
POM-A covers administration only, and the list is dominated by local anaesthetics:
- Bupivacaine hydrochloride
- Bupivacaine hydrochloride with adrenaline
- Lignocaine hydrochloride
- Lignocaine hydrochloride with adrenaline
- Mepivacaine hydrochloride
- Prilocaine hydrochloride
- Adrenaline (epinephrine) Injection BP
- Methylprednisolone
- Levobupivacaine hydrochloride
- Ropivacaine hydrochloride
The condition that catches people: podiatrists may use readily mixed combinations only, and may not mix the medicines themselves.
That is why the list names bupivacaine and bupivacaine with adrenaline as separate entries. Drawing up bupivacaine and adding adrenaline yourself is outside the entitlement even though the combined product is on the list. If you want the combination, it has to come premixed.
What can you sell or supply under POM-S?
POM-S covers sale and supply, which is a different activity from administering, and the list looks different in character:
- Amoxicillin
- Amorolfine hydrochloride cream, maximum strength 0.25% w/w
- Amorolfine hydrochloride lacquer, maximum strength 5% w/v
- Co-codamol
- Co-dydramol 10/500
- Codeine phosphate
- Erythromycin
- Flucloxacillin
- Silver sulfadiazine
- Tioconazole 28%
- Topical hydrocortisone, maximum strength 1% w/w
Note the strength caps. Amorolfine, tioconazole and hydrocortisone are all specified at maximum strengths, and supplying above them is outside the entitlement.
POM-S also carries a general permission covering all P (pharmacy) and GSL (general sales list) medicines, which is broader than most podiatrists realise and covers a good deal of routine practice.
| POM-A | POM-S | |
|---|---|---|
| Activity | Administration | Sale and supply |
| Character of list | Local anaesthetics, adrenaline, methylprednisolone | Antibiotics, antifungals, analgesics, topicals |
| Key restriction | Readily mixed combinations only, no self-mixing | Named maximum strengths |
| Also covers | Nothing further | All P and GSL medicines |
Do I already have these?
Depends when you qualified, and this is the practical fork.
Training in both is now an integral part of pre-registration education on approved programmes. So podiatrists graduating from an approved UK programme receive the annotations as part of qualifying, without doing anything extra.
Practitioners who qualified before that became standard need a standalone top-up programme to obtain them. That is a discrete course rather than something that accrues through experience, and it is the reason two podiatrists of similar seniority can have different entitlements.
If you are unsure, check the public HCPC register entry for your own name. The annotations appear there, and that is the authoritative answer rather than what you remember from your course.
What does this not cover?
Three limits worth stating plainly.
It is not prescribing. POM-A and POM-S are entitlements to administer and to sell or supply specified medicines. Independent and supplementary prescribing are separate, higher-level annotations with their own training routes and much broader scope.
The lists are exhaustive. These are not examples. A medicine not named is not covered, whatever its clinical similarity to one that is.
Entitlement is not the same as competence. Holding an annotation means you may do the thing. Whether you should, in a given case, remains a clinical judgement, and your indemnity provider will expect you to have exercised it.
What should you have in place?
Five things, if you administer or supply under either annotation.
- Confirm your annotation on the register, and know which of the two you hold
- Keep your medicines list current against the published lists, because they are amended
- Record administration in the clinical notes with the medicine, strength, dose, site, batch and expiry, and the time
- Have a written procedure covering storage, stock rotation, and what happens to expired stock
- Check your indemnity actually covers the activities you carry out under the annotation
The record-keeping point is the one that comes back to bite. An administration recorded as "LA given" is not a record that will help you if a patient reacts badly and you are asked, three years later, what you gave and how much. Contemporaneous notes, attributable to you, amendable only in a way that leaves the original visible, are what defends the decision. Systems like Atlacare lock a note on sign off and keep a versioned audit trail, which is the standard the rest of your record-keeping should meet anyway.
The short version
Two annotations, two lists, two different activities. POM-A for administering, and remember you cannot mix. POM-S for selling and supplying, and watch the strength caps.
If you qualified recently you probably hold both. If you qualified some time ago you may hold neither, and the route to them is a specific course rather than time served. Check the register rather than assuming, because it is the register that decides.
This is general information about the scope of HCPC annotations, not clinical or legal advice. The medicines lists are amended from time to time. Confirm the current lists on gov.uk and your own annotation status on the HCPC register before relying on either, and take advice from the Royal College of Podiatry where the position is unclear.
Sources: Rules for the sale, supply and administration of medicines for specific healthcare professionals, GOV.UK · HCPC, sale, supply and administration of medicines · HCPC, prescription only medicines standards
Related: Controlled drug storage in a private clinic · Is my practice VAT exempt? · UK GDPR for practitioners
