This is a pharmacy which offers its services to people through its website. The pharmacy has a prescribing service provided by doctors based in mainland Europe. The website offers prescription medicines for a range of conditions but mainly supplies medicines for the treatment of pain and sleeping tablets. It is a private pharmacy and does not supply NHS prescriptions. People do not visit the pharmacy in person and medication is sent by post or delivered by a courier.
- 1.1 - The risks associated with providing pharmacy services are identified and managed
- 1.5 - Appropriate indemnity or insurance arrangements are in place for the pharmacy services provided
- 1.8 - Children and vulnerable adults are safeguarded
- 4.2 - Pharmacy services are managed and delivered safely and effectively
Why this is poor practice
The pharmacy has no assurance that the remote prescribing service it uses is safe. It has not checked that the prescribers it works with are competent, can lawfully issue prescriptions to people in the UK and are covered by appropriate indemnity arrangements.
What the shortcomings are
The pharmacy uses prescribers who are not based in the UK, or registered with UK regulators, but it does not know whether the prescribers are following UK guidelines. This means the pharmacy cannot show that the prescribing service is safe.The pharmacy’s business involved the supply of prescription only medicines (POMs) to patients in the UK and some other countries in Europe. The medicines were supplied against private prescriptions issued by two overseas doctors. The prescribing service could only be accessed via the pharmacy website. Most of the medicines prescribed were opioid painkillers (dihydrocodeine and codeine) or sleeping tablets (Z drug sedatives, e.g. Zopiclone). The medication re‐ordering SOP specified that the RP would hold monthly clinical meetings with the prescribers, but this did not happen. The RP had daily contact with both of the online prescribers and they discussed patterns and trends in declined or suspended orders, but the prescribers worked independently and no records of these discussions were kept. The RP had completed a risk assessment for the pharmacy. But this had been completed before the GPhC Guidance for registered pharmacies providing pharmacy services at a distance had been issued and had not been reviewed in light of this guidance. The control measures stated on the risk assessment for using prescribers not trained in the UK and not familiar with UK prescribing, was to ensure they were ‘well trained, and diligence checked’ but there was no evidence of this. The RP had checked the credentials of the two doctors currently used and had copies of their registration certificates and photo ID, but there was no information to confirm that the prescribers were competent in their prescribing, or able to legally prescribe in the UK. It was also not clear if the prescriber’s indemnity arrangements covered online prescribing for patients in the UK .
What improvements are required
The pharmacy should review its complaince with GPhC guidance on providing services at a distance, ensuring all services, including those provided by remote dispensing services are safe, legally compliant and have appropriate indemnity cover.
We have identified the standards most likely and least likely to be met in inspections, and highlighted examples of notable practice for each of these standards; to help everyone learn from others and to support continuous improvement: