| 1.1 |
The pharmacy does not identify and manage all of the risks involved with its services. It has not fully considered and addressed the risks of prescribing medicines largely by relying solely on an online questionnaire without getting further information from people. And its prescribers do not follow some of the safeguards it has to reduce the risks of supplying medicines to people which may not be clinically appropriate. |
-We have implemented mandatory photos into our consultation system and now weight loss medications can only be prescribed if photos are sent in. Prescribing Pharmacists have now been doing this strictly
-The Clinical lead has helped us create and review prescribing guidelines, Risk Assessments and SOP for Saxenda and off-label use of Ozempic and Rybelsus for weight loss. He is also holding weekly meetings with the pharmacists to ensure safeguards are being met. This ensures safeguards are in place and being followed.
-He is also going through SOPs and Risk assessments of other medications to update the reviews with his signature.
-Clear instructions on how to take a medication have always been present on the prescriptions and are visible to the patient once prescribed on the dispensing labels.
-In the consultation process we also collect GP details (mandatory) in order to proceed and this ensures the prescribers can validate information with the GP if needed. We triage patients appropriately. For example, in our guidelines we know patients above 30 or (27.5 if from a non white ethnic group) are eligible for Ozempic off label if they send in photo evidence and have no contraindications. However we have identified that patients between the BMI of 27-30 who belong to a ‘white’ ethnic group need to have a comorbidity which we need to verify. So in this case we need our prescribing pharmacists to contact the GP to validate the comorbidity or for the patients to send a screenshot of the NHS app to verify the comorbidity diagnosis. Prescribing pharmacists can place prescriptions on hold (whilst verifying details) whilst they wait for the confirmation from the practice. Can also email the GP and we require documentation once information received from the prescribing pharmacists
-Prescribing Pharmacists can also have phone consults with the patients to verify details if necessary
-We have identified risks at a business level and on a medication by medication level |
11/07/2023 |
11/09/2023 |
| 1.2 |
The pharmacy does not check that its services are being provided safely. For example, the pharmacy does not review how medicines are prescribed. Or that system-led checks or refusal mechanisms are working in practice. |
-Signatures of the prescribing pharmacists have been added to every script
-We have also limited the supply of ordering medications as well as frequency with the system flagging if multiple orders are made in a set time period
- We are also carrying out a clinical audit led by our clinical lead currently on ‘if prescribing practices are being met’ and aim to produce an action plan based on our findings
- Our weekly and monthly MDT meetings where minutes are taken are helping us continually improve and identify any issues that arise
-Having a clinical lead oversee prescribing has helped us have additional safeguards when unsure about prescriptions or a need to discuss a patient side effect |
11/07/2023 |
11/09/2023 |
| 1.5 |
The pharmacy is not able to demonstrate that it has adequate indemnity insurance to protect people using its services. |
Director looking into getting the insurance coverage needed for the services provided. Currently waiting for a quote from a broker. |
11/07/2023 |
11/09/2023 |
| 2.3 |
The pharmacy does not have adequate professional oversight to make sure medicines are only supplied to people when safe and clinically appropriate. |
-The RP pharmacist is always in charge of overseeing the final accuracy checks on all OTC, P lines or prescribed medications before dispensing and packaging of signed off treatments.
-Accuracy Clinical checks by RP is made by checking the patient’s submitted online consultations, patients order history (regarding supply limits) and any contraindications of treatments.
-The Pharmacists are being overseen by a Medical doctor who is Board Certified in lifestyle medicine with whom they discuss any patient cases when clinical issues arise.
-We have also implemented weekly recorded MDT meetings with the pharmacists where they can raise issues and discuss patient cases with the Clinical Lead as well as monthly meetings with the whole team.
-We are then having improvement plans after every MDT so we can learn and continually improve the service and offer a better experience for patients.
-We now have clear prescribing guidelines in place for the medications including Ozempic, Rybelsus and Saxenda.
-The clinical lead is also overseeing how many medications are being dispensed on a monthly basis. Reviewing the near miss logs with the superintendent. |
11/07/2023 |
11/09/2023 |
| 2.2 |
Pharmacy staff are not always suitably trained or doing the right accredited training for the activities they undertake. |
-Dispensary will be always operated and managed by fully trained dispensers under the supervision of a qualified pharmacist. We are currently hiring a dispenser with full butter cup training qualification to assist the RP in the dispensary.
-prescribing pharmacists have agreed to book onto The National Medical Weight loss Programme accredited course for prescribing Ozempic and Saxenda
-Currently pharmacy also recruiting for dispensers who are qualified
-PIPs have also talked to the Clinical Lead who is Board Certified in Lifestyle Medicine about weight loss treatments and how best to use them.
-Our Clinical Lead ensures he stays up to date and recently attended a webinar on GLP-1s and lifestyle medicine which discussed GLP-1s in detail and best practice when using them |
11/07/2023 |
11/09/2023 |
| 3.1 |
The pharmacy's website allows people to start a consultation from the page of an individual prescription-only medicine. This does not meet GPhC requirements. |
-The website has been designed to be condition focused and not medication focused. For example users see ‘weight loss’ as an objective and then can start a consultation and only then if eligible are presented with medications.
-We are designing through partnerships a more holistic service for weight loss which helps patients adopt to a healthier lifestyle.
- We have ensured we take a condition focused approach as we intend on offering more holistic services in the future |
11/07/2023 |
11/09/2023 |
| 4.2 |
The pharmacy cannot demonstrate that it gets enough reliable information about people to make sure the medicines it supplies, including for weight loss, are clinically appropriate for them. And it cannot show that it has appropriate monitoring in place when supplying prescription medicines such as weight-loss treatments. |
-We are now implementing checks with our patients on their journey with a 1 month check in to report side effects and mood (as we recognise the importance of monitoring a range of aspects). We also offer a full panel of blood tests in the process. Followed by a 2 month check in and then at 4 months to check if 4% percent weight is lost of Saxenda and at 6 months to see if 5% of weight is lost on Ozempic. If these are not met then the medications will be stopped. Then every 2 months after that leading up to the 1 year review. This ensures patient monitoring and safe practice.
-We are also launching monthly webinars by our clinical lead where patients can be educated on the treatment and also ask clinical questions they may have. This will ensure they have access to our clinicians.
-Our mandatory photos, ID verification and GP details ensure only appropriate patients are supplied with medications. In addition patients can send in screenshots of their NHS app (summary care record) for us to further verify or in cases where we must verify a comorbidity
-Our prescribing pharmacists have also been instructed to always add a reason when accepting or rejecting medications |
11/07/2023 |
11/09/2023 |
