Leyland Late Night Pharmacy (1106584) - Improvement action plan

The pharmacy's prescribing service is not supported by clear policies and procedures. And the pharmacy cannot demonstrate that it identifies or manages the risks associated with it.

Several measures have been taken to address this issue.
The two documents published by the GPhC which were pointed out by the inspector, namely 'Guidance for Registered Pharmacies Providing Pharmacy Services at a distance, including on the internet' (Updated March 2022) and 'In practice: Guidance for Pharmacist Prescribers' (Dated November 2019) have both been read and acknowledged by our independent prescribers. They have both signed a document confirming they have done this and that they shall adhere to the stipulations and/or recommendations stated therein when prescribing. This is being retained on the premises. By adhering to this guidance, this minimises and manages the risk associated with prescribing.

Furthermore, a detailed 13-page Service Specification has been produced, which has been signed by all prescribers confirming they have read, understood and agreed to adhere to the stipulations therein. This further helps limit the risk of any dangers associated with prescribing.

Thirdly, there is a copy of the ‘Formulary of Competence’ for each prescriber retained on the premises. This qualifies the areas within which each prescriber has the competence to prescribe within. It lists the prescribing areas and/or list of drugs for any independent prescriber(s).

Moreover, a copy of the indemnity insurance certificate for each independent prescriber(s) is being retained on the premises.

Fifthly, when a private prescription is written a copy of the notes from the consultation are documented by the prescriber as before, however, a copy of these notes is also retained on the premises. This is in accordance with the advice given by the GPhC inspector.

Also, now as was the case previously, for all private prescriptions that have been written by independent prescribers the patients’ GP surgeries are notified accordingly by the independent prescriber about the consultation in writing. However, we have now introduced a system whereby a note indicating when this was done is being retained on the premises e.g. 'Email sent to Dr Joe Bloggs' Surgery on 1 Jan 2023'.

Seventhly, a copy of every prescription with indelible ink with the actual hand-written signature is being retained on the pharmacy premises. If the patient is prescribed an item remotely and there is no way of physically being able to obtain the prescription before the item is needed, then the Responsible Pharmacist on duty seeks reassurances from the prescriber that it is impracticable to furnish the physical prescription forthwith and reassurances are sought from the prescriber that the physical prescription will be brought into the pharmacy at the earliest possible opportunity.

If the Responsible Pharmacist feels it is not professionally appropriate to dispense the prescription, then they refuse to do so, in exactly the same manner that checks are made for the suitability and veracity of a prescription and/or prescriber by a Responsible Pharmacist when analysing what is purported to be an NHS prescription emailed across from an Out of Hours GP prescriber or a private prescription from a private clinic based in London etc.

Lastly, as per the advice given by the GPhC inspector a document confirming a quarterly 'peer review/discussion' relating to independent prescribing and areas of competence etc. between the independent prescriber and another independent prescriber, signed, dated and kept up-to-date every quarter, will be retained on the premises. A copy of this is not present in the premises at the time of writing (3 Jan 2024) however it shall be within the stipulated 3-month period.

As a result of all of the above, the pharmacy is confident that the pharmacy's prescribing service is supported by clear policies and procedures and this clearly demonstrates that risks associated with it are identified and appropriately managed.

The pharmacy’s prescribing service sometimes issues prescriptions without obtaining enough information to properly assess the patient’s condition. And people using the service do not always get enough advice about what to do if their condition does not improve or gets worse.
The pharmacy dispenses prescriptions against verbal instructions provided by the prescriber, or against scanned copies of the prescriptions. But the pharmacy could not show they always received the actual written copy of the prescription, which is required by law.

As outlined in 1.1 above, a robust procedure is followed in terms of the manner in which the prescribing service is offered in order to minimise and manage any risks.

The prescribers adhere to the guidance issued by the GPhC in the two documents 'Guidance for Registered Pharmacies Providing Pharmacy Services at a distance, including on the internet' (Updated March 2022) and 'In practice: Guidance for Pharmacist Prescribers' (Dated November 2019) and a signed document is retained on the premises confirming this in writing.

Appropriate records are maintained of any prescribing and details are forwarded to the patient’s GP in writing in respect of which the prescribers retain a reference within the pharmacy as well as consultation notes.

The original physical copies of private prescriptions are retained on the premises and filed away in a timely, organised and appropriate manner. The computer system automatically retains a record of all private prescriptions that are dispensed. Private prescriptions are dispensed from the original copy of the physical prescription. However, in the circumstance that the patient is prescribed an item remotely and there is no way of physically being able to obtain the prescription before the item is needed, then the Responsible Pharmacist on duty seeks reassurances from the patient and/or prescriber that it is impracticable to furnish the physical prescription forthwith, reassurances are sought from the prescriber that the physical prescription will be brought into the pharmacy at the earliest possible opportunity and at the very least a copy of the prescription is sent across to the pharmacy via email.

In exactly the same manner that checks are made for the suitability and veracity of a prescription and/or prescriber by a Responsible Pharmacist when analysing an NHS prescription emailed across from an Out of Hours GP prescriber or a private prescription from a private clinic based in London etc, where the Responsible Pharmacist feels it is not professionally appropriate to dispense the prescription written by the independent prescriber then they refuse to do so.