| 1.6 |
The pharmacy's private prescribing service consultation records are incomplete. So, this makes it more difficult to understand the reason for the prescription and the clinical evidence available to the prescriber at the time. |
To develop a Standardised Consultation assessment form:
This form will include mandatory fields such as:
• Patient details
• Reason for prescription / clinical indication
• Relevant clinical history and evidence reviewed
• Assessment findings
• Decisions made during consultation
• Any advice, referral or follow-up arranged
• Safetnetting Advice
• Patient Consent
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08/09/2025 |
31/12/2025 |
| 1.1 |
The pharmacy does not always appropriately manage the risks associated with its prescribing service. And there is evidence that it has not put in place the mitigations identified in its own risk assessment. For example, the risk mitigation for overprescribing was to have a standardised assessment protocol. But there is no evidence that this has been implemented. And it cannot show how it is mitigating the risks. Some risk assessments do not have implementation or review dates, so they may be less likely to reflect current best practice. |
Immediate Review and Update of Risk Assessments:
The pharmacy will undertake a full review of all risk assessments related to my prescribing service by 22nd of August 2025. All risk assessments will be updated to include clear implementation and review dates.
Going forward, risk assessments will be reviewed at least every six months.
Development and Implementation of a Standardised Assessment Protocol:
By 22nd of August 2025, the pharmacy will implement a standardised assessment protocol to mitigate the risk of overprescribing. This will include, a separate assessment form to be filled by the patient before the consultation and another form for me (prescriber) to filled for prescribing. Patient’s form can be sent to them via email or via message as a link. Also update my current SOP to reflect this.
Establish Clear Mitigation Measures and Monitoring.
Starting from 13/08/2025, the pharmacy will conduct a three monthly audit of my prescribing activity to ensure my adherence to the standardised assessment protocol. This is to make sure both patient and prescriber’s form are filled and present for audit.
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08/09/2025 |
31/12/2025 |
| 4.2 |
The pharmacy does not have sufficient systems in place to ensure that its private prescribing service is safe and effective. It prescribes antibiotics at a distance. But it doesn't independently verify information provided during telephone consultations before prescribing antibiotics. And it doesn't always refer people to other healthcare providers when the exclusion criteria in its own prescribing formulary are met. Additionally, the pharmacy cannot demonstrate that it obtains consent for and routinely shares information about medicines it has prescribed with people’s regular prescriber. |
Verification of Patient Information During Remote Consultations:
A strict verification process will be put in place to confirm patient information before prescribing antibiotics remotely. This can be done by :
• Request Photo ID
• Before sharing any information or proceeding with prescriptions, get verbal or written consent, which should be recorded.
• Also if any concern or doubt a video call will be arrange to allow me to see the patient, which adds an extra layer of identity confirmation. This will be done with the patient's consent and help me to verify age, general appearance, and engagement etc.
Strict Adherence to Exclusion Criteria and Referral Procedures.
• Review the current prescribing formulary to make sure there is clear exclusion criteria.
• Develop a referral log system to track all patients who are referred elsewhere, including reasons and follow-up actions.
For Distant and Remote Prescribing:
Effective immediately, a live video consultation will be mandatory requirement for any remote prescribing activity. This will only be done after having a clear consent for video consultation and to share details with GP.
Furthermore, with the patient's consent, the pharmacy will proactively check the Summary Care Record (SCR) prior to the consultation where clinically necessary. This is to independently verify past medical history, current medications, and confirmed allergies, ensuring my clinical decision is based on accurate data and protect any overprescribing.
The video consultation will be used to conduct a structured clinical observation, which is critical for making a diagnosis. The specific observations the pharmacy will make include, but are not limited to:
• General Appearance: Assessing for signs of systemic illness, such as lethargy, flushing, or apparent distress.
• Visual Inspection of Infection Sites: For instance, examining the tonsillitis; inspecting skin for erythema, swelling, cellulitis, or the presence of an abscess; assessing eyes for discharge or conjunctival injection.
• Requesting Patient-Led Measurements: Where clinically necessary, the pharmacy will ask the patient to provide objective data such as body temperature (using a thermometer) or heart rate, Blood pressure reading (if they have availability) to help me in diagnosis.
This new practice will make my prescribing practice safe, appropriate and based on clinical evidence rather than subjective reporting alone by patient.
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08/09/2025 |
31/12/2025 |
