| Standard not met | Reason | Action being taken by the Pharmacy | By when | Notification By Pharmacy Improvements Made |
|---|---|---|---|---|
| 1.1 | The pharmacy does not have clear procedures to support its prescribing service or online supplies. And it does not carry out any audit of these services. So it cannot demonstrate that risks associated with these services are being identified or managed. |
We are in the process of creating a SOP for our prescribing service (face to face and online service). Annual audit to be designed to show if all prescribing is in line with the prescribing SOP. This will also help identify risks with prescribing and the risks involved with online selling of P’s and POM’s. Red flag symptom cards to be created to help prescribing decisions to identify any red flags associated with certain conditions and this will be checked across for each patient. Matters outside of the action plan are being dealt with by the conditions imposed |
18/03/2020 | 16/03/2020 |
| 1.2 | The pharmacy does not carry out a full assessment of the risks associated with the medicines it offers on its website. And it cannot show that prescribing is in line with good practice or UK national guidance. |
We are changing our website and algorithm to include a risk assessment for medicines prescribed. Risk assessment will be conducted on the prescribing service including both the face to face and online service. In the interim period ALL prescribing activities will be suspended. A clinical audit will be conducted on an annual basis to check clinical appropriateness of prescribed medication for each therapeutic area e.g if prescribing inhalers then asthma audit against formulary to ensure this is in line with local guidance and to see if prescribing decisions are based on UK national guidance, for example; NICE, CKS, and BNF. Other therapeutic areas we will conduct audits on include URTI, LRTI, UTI, Minor skin conditions, minor eye and ENT infections, GI system. Matters outside of the action plan are being dealt with by the conditions imposed |
18/03/2020 | 16/03/2020 |
| 1.6 | The pharmacy does not keep clear records showing why requests for medicines are approved or refused. So it cannot demonstrate how these judgements are made. |
We are designing a refusal and an approval log. We are working out a way of incorporating this into the website so it is visible when searching a person’s account. The reason for refusal and approval will need to be clear to show how these decisions were made. Matters outside of the action plan are being dealt with by the conditions imposed |
18/03/2020 | 16/03/2020 |
| 1.8 | The pharmacy does not have adequate safeguards in place to prevent vulnerable people from obtaining medicines that could cause them harm. |
Prescribing SOP to incorporate policy to refer if overuse/misuse of medications identified via online or face to face, using order history and thorough identification checks. Matters outside of the action plan are being dealt with by the conditions imposed |
18/03/2020 | 16/03/2020 |
| 2.2 | The pharmacist prescriber cannot provide evidence to show he has the knowledge and experience he needs to safely prescribe all of the medicines that are available on the pharmacy’s website or to effectively administer aesthetic treatments. |
All prescribing activities will be suspended until all training is up to date to show competence and knowledge. The following activities will help to demonstrate competence and knowledge for prescribing: Matters outside of the action plan are being dealt with by the conditions imposed |
18/03/2020 | 16/03/2020 |
| 2.6 | The pharmacy website offers medicines that are liable to abuse. And their high profit margins mean there is a financial incentive to supply that could compromise professional judgement. |
We are completely removing medicines that are liable to abuse from the website. All P medications and POMs will be removed from the website until the whole website is fully revamped and risk assessed. Matters outside of the action plan are being dealt with by the conditions imposed |
18/03/2020 | 16/03/2020 |
| 3.1 | The pharmacy’s website allows prescription only medicines to be selected for purchase before starting a consultation with a prescriber. |
The whole order system of online prescribing will be changed on the website so that the patient cannot select the product required before a consultation has taken place. Once a patient has answered questions regarding their specific problems and the prescriber feels that a prescription is appropriate for this patient, only then a medication will be prescribed which will be a joint decision between patient and prescriber but the final decision will be with the prescriber. POMs will not be available for the patient to select before a full consultation has taken place. Matters outside of the action plan are being dealt with by the conditions imposed |
18/03/2020 | 16/03/2020 |
| 4.2 | The pharmacy does not have adequate controls in place to make sure the medicines it supplies will be used safely. It does carry out robust identity checks to make sure people who order medicines from its website are who they say they are. It does not get enough information to make sure people only receive medicines that are appropriate for them. And it does not have a clear policy about supplying medicines to people who make repeated requests. The prescribing service does not share information about the medicines it supplies with the person’s GP. |
We are incorporating into our website a photograph identification policy. This would require customers to upload a picture of their driving license/passport to verify their identity. This will help prevent multiple accounts and misuse or repeat orders. Consent will be asked from each patient to allow us to share information with GP or give them option to self-refer to GP. Matters outside of the action plan are being dealt with by the conditions imposed |
18/03/2020 | 16/03/2020 |
Pharmacy inspections
Inspection reports and learning from inspections