Dickson Chemist (1091065) - Improvement action plan

The pharmacy does not have robust procedures to ensure it adequately identifies and manages all the risks associated with the private prescribing services it is associated with. This includes not adequately assessing the risks with prescribing and supplying medicines to people living outside the UK. And not suitably managing the risks associated with the dispensing of prescriptions from third-party clinics.

Review of safeguards and Risk Assessments (RA) are being added formally to these meetings. Risk assessment for remote consultations has been reviewed and is now included in the overall RA and review process. Safeguards are in place to appropriately identify patients and make sure therapy is appropriate, with signed copies of Risk Assessments being reviewed at quarterly meetings going forward.

* RA for all unlicensed medicines have been reviewed and updated, specifically regarding Ozempic off license and the need to record reasons for unmet need and prescribing off license.

* Risk assessments have been completed for dispensing against 3rd party clinics

* 3rd party clinics will now have a formal onboarding process, with formal review period to check clinical status – in addition to current checks completed by the RP at dispensing.

* 3rd party clinic prescribing is currently reviewed but not recorded formally, when a new medicine is prescribed a formal record will be kept of suitability and appropriateness
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The pharmacy does not keep complete prescribing consultation records for prescribers and the responsible pharmacist to access. It does not always keep accurate records of its higher-risk medicines as it must by law, as it does not always make register entries when it makes supplies.

* The majority of records are correctly uploaded, however, there was not a review and check process in place at the time of the inspection to ensure all records are embedded in the one system. Although the data was safely stored, secure and available, it is our process that this should have been happening and the inspection has identified a need to check and review this. This is now part of daily standard practice with all data safely in the one system.

* Although prescribers have completed adequate masterclass or similar training for the field of private prescribing, the notes for each individualised patient don’t make sufficient reference to the data sources for unlicensed prescribing, this has been rectified going forward from April 2023.(As per prescribing policy references)

* Consultation records are now kept on premises for all HBOT.

*Responsible Pharmacist (RP) has reverted to MDS being written out weekly, rather than all at once as deliveries have now reverted to mostly 1 MDS at a time.