| 1.1 |
The pharmacy has not implemented its updated risk assessment for its weight loss service. And it has not completed a review of risk assessments for other treatments. The pharmacy team, including prescribers, do not readily have access to the risk assessments and prescribing policies to refer to whilst working. So, the pharmacy does not adequately manage risks with its services to help protect patient’s safety. |
Cloud Pharmacy is committed to implementing the following as stated in the updated weight management service risk assessment:
- Live Images:
- Functionally is being built so that all BMI verification image uploads from patients will be updated to “live images” - where images are captured in real time from the patient’s device camera, without the ability to upload a previously stored image. Preventing the ability to upload old, edited or AI generated photos.
- Live images will be required for all new and existing weight loss patients
- Video consultations:
- For BMI weight verification
- Currently building video consultation functionality into our systems to enable BMI weight verification.
- Patients will be instructed to show their official government ID (passport/drivers license) to confirm it is the right person
- Video BMI verification can be carried out by prescribers to also allow them deliver real-time education, confirm patient comprehension, and answer questions directly.
- Prescribers will also be able to arrange video consultations for any patient they deem necessary to provide a holistic approach to our care.
- Verifying information provided:
- Question will be added to consultation forms for patients to upload their NHS GP records to enable prescribers to verify information given on the consultation form
- Notification of treatment letter sent to patients GP surgery directly upon treatment initiation via direct channel where GPs are asked to respond if they feel that there is a reason that the patient should not be prescribed the treatment, or any other concerns that we should be aware of.
Updated risk assessments for all treatments other than weight loss:
- Cloud Pharmacy will review and update the risk assessments and prescribing policies for all services and medications provided through Cloud Pharmacy based on current evidence, clinical guidelines and best practice.
Access to risk assessments and prescribing policies:
- Risk assessments and prescribing policies will be accessible to all staff within the pharmacy and prescribing team. Access will be via secure platforms such as slack, shared drives, and physical printed copies on site. |
25/11/2025 |
24/12/2025 |
| 1.2 |
The pharmacy’s audit activity does not consider individual prescriber’s practices, including the frequency and volume of their prescribing. And the audits don't cover all areas, such as adherence to frequency and quantity of supplies it makes against its policies. So, the pharmacy doesn't have a robust process to check if all supplies are appropriate for people. |
Cloud Pharmacy’s current regular prescribing audit protocol will be updated to include:
- A review of the frequency and volume of prescribing by individual prescribers.
-We will build a system to allow data to be recorded from a sample of one working day per prescriber to evaluate prescribing frequency and volume.
- The appropriateness of each prescription decision, quality of documentation, and adherence to each prescriber's scope of practice will also be assessed.
- In addition, compliance with Cloud Pharmacy’s policies on the frequency and quantity of supplies issued will be reviewed.
- % of each prescriber’s total prescriptions for the month will be audited.
- Findings will be fed back to prescribers, with measurable improvement actions identified where appropriate. Progress against these actions will be reviewed at subsequent audits to promote accountability and support continuous quality improvement in prescribing practice.
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25/11/2025 |
24/12/2025 |
| 1.6 |
Prescribers do not regularly record consultation notes when prescribing. The notes prescribers make are basic and do not show how the prescriber makes their decision to prescribe or not. And they do not show ongoing monitoring or consideration for any follow-up required. This makes it harder for the pharmacy to demonstrate continuity of care and show the supplies it makes are appropriate. |
Consultation Notes:
- Communicated to prescribers to leave detailed consultation notes for every prescribing decision to provide evidence of their reasoning and detailed plans for monitoring and follow up.
- Training has been provided to prescribers on good practice for clinical note taking.
- New prescribers will have clinical note training as part of their onboarding.
- Clinical notes will be audited as part of the regular prescribing audit.
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25/11/2025 |
24/12/2025 |
| 4.2 |
The prescribers rely on the responses people provide in assessments forms to make their prescribing decisions and they don’t take steps to appropriately independently verify the information people provide. Pharmacy team members, including prescribers, do not make sufficient checks on quantities and frequencies of requests to ensure supplies are appropriate. There are examples of medicines for weight loss being supplied too frequently. So patients may receive medicines which are not appropriate for them. |
Independent verification of height and weight and ID:
- All new patients to Cloud Pharmacy will undergo a video consultation with a prescriber to independently verify reported weight and height. Patients will be asked to ensure they have a set of scales and measuring tape to hand.
- Patients will be required to show official government issued ID (passport, driver license) at this consultation.
- We plan to build the functionality for all new and existing patients will be required to submit live images upon first order and at least every 3 months (every 1 month for higher risk patients i.e. maintenance)
- Automated emails for live full body images will be requested every 3 months or sooner (frequency can be adjusted by the prescriber) to support this.
- As part of the prescribing audit, compliance with the requirement of images every 3 months will be reported on.
- As part of our clinical check process within the pharmacy, our pharmacists will now provide a second check on BMI images to verify the prescribers initial BMI assessment
- This will be assessed as part of the regular pharmacy compliance audit.
Independent verification of medical history:
- The following will be implemented/ has been requested to enable prescribing pharmacists to independently verify medical information provided by patients.
- Request has been sent to National Care Service Records (NCSR) for access to NHS Summary Care Records (SCR).
- National Services Scotland (NSS) Digital & Security department have been contacted regarding the possibility of gaining access to NHS Emergency Care Summary (ECS)
- A section will be added to consultation forms for patients to upload their NHS GP records (NHS App, repeat prescription slips).
- Notification of treatment letter sent to patients GP surgery directly upon treatment initiation via direct channel where GPs are asked to respond if they feel that there is a reason that the patient should not be prescribed the treatment, or any other concerns that we should be aware of.
- Providing GP details mandatory
- Prescribers communicated that if they have any concern about the accuracy or completeness of the information provided, they must contact the patient’s GP directly before making a prescribing decision.
Pharmacy team members and prescriber checks on quantity and frequency of supplies:
- Communicated to prescribers about strengthening checks on the quantity and frequency of supplies in compliance with Cloud Pharmacy’s prescribing policy.
- Plan to build automatic processing into the prescribing system that flags if a patient has ordered more than one weight loss injection.
- Quantity and frequency of supplies will be checked as part of the prescribing audit for individual prescribers.
- Communicated to dispensary pharmacists to ensure quantity and frequency of supplies are included in their clinical check process.
- This will be assessed as part of the regular pharmacy compliance audit.
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25/11/2025 |
24/12/2025 |
