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Pharmacy inspections

Inspection reports and learning from inspections

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Simply Meds Online (9010764) - Improvement action plan

Standard not met Reason Action being taken by the Pharmacy By when Notification By Pharmacy Improvements Made
1.1

The pharmacy cannot show that it identifies and appropriately manages all the risks linked to the supply of medicines online.

The Pharmacy will re-evaluate the risks involved in the supply of the medicines online. It will look at short comings of the current risk assessment and identify more stringent methods in order to assure that any risks are minimised and where possible mitigated. Some of the changes include an update to the quotas.

A separate prescribing risk assessment will be conducted and implemented in order to ensure safe supply of medicines online. This will ensure that it acknowledges and combines the points from the Pharmacy risk Assessment to try and cover all possible associated risks.

By implementing the actions listed below for the other action points this will also help to minimise risks further.

24/12/2020 12/01/2021
1.2

The pharmacy does not routinely assess the safety and quality of the services it provides. With the exception of an annual review of the questions asked in the consultation, there are no clinical audits of the prescribing service provided to people. So, the pharmacy cannot assure people that all its services are safe.

In order to ensure that the Pharmacy routinely assess the safety and quality of the services provided audits will be carried out. These Audits will allow the pharmacy to identify any strengths and weaknesses so that they can be either built upon or improved. An initial list outlining the proposed audits are as follows.

To be carried out quarterly followed by a meeting to discuss outcomes with SI and PIP.

• No of Prescriptions to each gender
• No of Prescriptions based on age group
• No of Prescriptions based on medicine
• No of Prescriptions per area
• No of repeat prescription orders in last 3 months
• How many patients ordered larger quantity versions of their order

Any trends can then be investigated on a granular level later.
By conducting these audits it will allow the pharmacy to routinely self-inspect the safety and quality of the services provided. It will highlight points which may need further work or detail in order to ensure the safety of the service provided.

12/01/2021 12/01/2021
1.6

The pharmacy does not make adequate records about its prescribing decisions. So, important information which may impact the care a patient receives in future is not always available. And it makes it harder for the pharmacy to monitor and review the quality of its prescribing service.

The customer profile page of each account will be changed so that all notes and previous orders are shown on the same screen. This will enable staff to have access to all relevant information for that patient in one area.

The second step to increasing the quality of the prescribing service is by making effective notes in the customer profile. This will include details as following:
- Any contradicting medication
- Allergies
- Medical conditions which may impact treatments
- GP details
- Any recorded review dates
- All previous contact with patient via e-mail/ telephone
- Details of any refusals
- Details of Signposting
- Side effects experienced

Also built in is a ‘flagging’ system which allows the user to identify and flag accounts which are deemed to be ordering medicine not fit for purpose/ outside of the prescribing guidelines. In addition to this any treatment failures will be highlighted, predominately this would be noted in cases where patients order alternative treatments for the same condition in a short space of time. Or in the case of a patient contacting the pharmacy about a case of treatment failure. Likewise any unwanted side-effects experienced or concerns will be addressed and noted on the patients notes. Patients will either be given advice on how to manage the side-effects or signposted to another healthcare professional if need be. This would be dealt with by the Pharmacist on duty with the PIP available if needed.

An SOP will be created which will clearly outline the process by which notes are to be recorded so that all staff have the necessary information to record key parameters.

Having the information available in an easy to see and comprehensive format will allow for more efficient prescribing and concomitant monitoring.

12/01/2021 12/01/2021
3.1

People can choose prescription-only medicines on the pharmacy’s website before having a consultation with a prescriber. This increases the risks of supplying medicines to people which are not suitable.

Complete change of the current consultation process.

Before a customer is shown a POM in a category, they will be presented with a pre-consultation.

Pre-consultation details
• There will be a set of 5 or 6 condition specific questions.
• No separation message for questions that are answered “incorrectly”. I.e. all answers considered and accepted therefore no way to cheat the system.
• Each question is a “trigger question” and what is shown to the patient is based on what answer they have given. An example of this is if the patient answers that this is the 1st time they are using the service they will only be shown the smallest quantities following the consultation. (Note: this is not where they complete the actual medicine based consultation, also this is just one example there will be many conditions placed for each and every condition).
• The answers will determine what the patient is presented with on the screen. They will not be able to deviate from these options or “override” the system in any way as it loads a cookie onto their pc preventing this.

12/01/2021 12/01/2021
4.2

The pharmacy cannot show that its prescribing service always protects people's health and wellbeing. It doesn't routinely share information about its prescribed treatments with other healthcare professionals involved in a person's care, even where consent has been given to do so. People can change answers to the questions on the consultation questionnaire and these changes are not visible to the prescriber. So, people may be able to obtain medication which is not appropriate for their condition. And the prescriber does not make suitable records about their prescribing decisions.

Medicines Consultation Changes
The current consultation method will be revised.
• All questions answered will be accepted and no prompt shown on screen of an unacceptable answer.
• Customers will not be tempted to change their answers just to proceed through the consultation.
• Prompt at the end to tell the customer that they may be contacted before supply or that supply will be held until they have been contacted.

Contacting Patient GP for high-risk treatments
• Patient asked for consent to contact GP during sign up stage. They are actively told that should they receive supply that their GP will be contacted.
• We have purchased a database of GP surgery details in the UK, patients can select their GP with ease during this phase.
• New notes section on order and customer (now linked) where we can note if we choose to supply if the patient cannot supply GP details (e.g. no regular surgery or private only) or if we refuse supply.
• We already stick to strict quotas.

12/01/2021 12/01/2021