Capsule Pharmacy (9011378) - Improvement action plan

The pharmacy does not have appropriate risk assessments to identify and manage the specific risks for the online prescribing services it provides.

We have used various credible sources eg pharmacyregulation.org to look for information / guidelines to assist us in creating policies to ensure we follow good clinical governance for all of our online pharmacy offering. We have come up with the following:

We are setting up an advisory board which will meet six monthly. We have in addition to the Superintendent Pharmacist a Doctor, a Pharmacist Independent Prescriber and multiple Pharmacists that will form the board. We will now have minutes taken and they will be reviewed by the CEO. During these meetings there will be things such as clinical recommendations, evidence-based medicine discussions and reviews on any service we offer e.g. online doctor, P med sales, their questionnaires, any updated guidelines, safety concerns of medicines, any national warnings or alerts discussed etc.

We will have governance meetings. These will be monthly and will include the SI Pharmacist, Medical Director, Pharmacist Independent Prescribers and Pharmacists to review any patient complaints, patient experiences, discuss any prescribing errors, review any audits undertaken, rejected or refused supply of medicine and their reasoning, notice and discuss any trends (increased supply) that need addressed etc. We will take minutes and circulate to the team. Actions and outcomes will be reviewed.

We already have daily team meetings. These will however be used to feedback anything from the wider team to take to the governance meetings. It will also allow management to take any actions or plans decided by the advisory board or clinical governance meetings to the team. We discuss workflows, SOPS, service delivery and staff rotas etc at these meetings. We also pass on important information such as MHRA alerts etc …

We will take any patient feedback to all meetings described above.

Need to update / create a risk register where we note any risks that are being discussed.

We will update our prescribing policy to allow for the following:
- Guidance for prescribing for all conditions
- There will be reference to clinical guidelines for all medicines being prescribed
- Will monitor and review the policy annually
- We will update the policy to include our current communication pathway for prescribers or pharmacists to communicate with patients on medicines misuse and any other information we feel the patient requires. We will also update the website to signpost patients to the NHS substance misuse guidance e.g. https://www.nhs.uk/live-well/addiction-support/drug-addiction-getting-help/.
Specific Risk Assessments for each medicine we provide in our Online Doctor Service
- We will update our assessments to include safeguards.
- Regarding medical history of a patient, we ask patients currently to provide this however we will update the policy to additionally allow the prescriber to request proof if required. The prescriber will have access to the patients phone number and email address to do so. This will also be recorded by the prescriber on the patient notes.
- Regarding the max qty supplies of each medicine, we will update our RA’s to include max qty’s for prescribing, any purchase limits at any one time and any purchase limits within a specific time frame.
- Follow-ups. We will update the RA Policy to ensure the patient is contacted after an online doctor supply to ensure they are satisfied, to allow for any feedback on the service and medication, and to ensure the safety of the patient.
- RA Policy will be updated to reflect local or national guidance on prescribing for the individual condition / medication prescribed.
- The RA Policy will be updated to ensure we regularly monitor any unusual repeat orders, orders for high quantities of medication and keep a record of rejected / refused supplies.
- The RA Policy will be updated to reflect regular and proactive review and audit of identifying patients that have created duplicate accounts, different accounts under the same address etc. This is essentially to remove the risk of patients getting access to more medication than allowed and reduce the risk of abuse for example. This will be completed monthly.
Technical difficulties:
- On the private prescription generated by the prescriber, the directions were missing when received by the pharmacy dispensary. This has been reported to our development team and will be remedied.

Our RA Policy will be updated to state that all staff members should read and sign all SOPs.