Internet / Distance Selling
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 is not following its own policies and procedures intended to prevent abuse of medication.
What the shortcomings are
Policies and procedures were in place to prevent people from ordering too many medicines, but they were not always followed. There was an opioid policy, which specified the maximum quantities that would be supplied and how frequently repeat supplies could be made. The SOPs stipulated what action should be taken when patients repeatedly reordered medicines. Larger supplies of some pain relief medicines could be ordered at the consultation stage. The opioid policy stated a maximum of 112 tablets of dihydrocodeine per month, but 224 could be selected when ordering. A patient had been supplied with 252 pregabalin without a fully documented justification. This medicine was listed on the opioid policy with a maximum monthly quantity of 28. The opioid policy stated that the pharmacy was particularly careful when supplying patients under the age of 25. But it was not clear what actions the pharmacy took in those circumstances, or whether they would or would not prescribe. When opioids or sleeping tablets were ordered the pharmacy requested a copy of a previous prescription to confirm the patient had been prescribed the medicine before. But this could be a cause for concern because it could indicate that the patient may also be receiving supplies from their GP. The pharmacy did not take any steps to verify this or contact their GP. Patients ordering opioids or sleeping tablets were required to confirm that they were aware the medicine was addictive and declare that they would inform their own doctor and read the patient information leaflet. Records of decisions to refuse were kept and an e‐mail was sent to the patient explaining why the supply could not be made, e.g. medication not appropriate for condition, maximum quantity exceeded within time scale. The RP checked the patient’s medication record (PMR) to see if there had been previous supplies and checked the request was in line with the opioid policy, and that the patient’s name and address provided matched the payment details and identification provided. But the system was not very sophisticated and did not automatically detect potential fraudulent or dishonest activity, or abuse. It relied on the vigilance of the prescriber and the RP to detect this, and this over reliance on one or two individuals increased the risk of inappropriate supplies being made. Patients requesting sleeping tablets and opioids were required to upload personal identification (ID), confirmation of address, and proof of previous GP prescription. But this was not requested if patients ordered any other medicines. There was no way of assessing a patient’s mental capacity, to determine whether a remote consultation was appropriate.
What improvements are required
The pharmacy should ensure that pharmacy practices comply with policies and procedures for preventing abuse and addiction and align with the GPhC's guidance on providing services at a distance.
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: