MedExpress (9012633) - Improvement action plan

The prescribing service the pharmacy works with is relying on an on-line consultation questionnaire and photographic evidence to make prescribing decisions. It does not have processes to independently verify information supplied by people including people's weight, height and medical history. This means the pharmacy cannot be sure that the prescribing service it works with is getting all the information needed to make safe prescribing decisions.

The prescribing service, Central Medical Solutions Ltd (CMS), has committed to improving their processes of Independent Verification by implementing the following process changes and technology improvements:

Independent verification of height and weight:
1. Multiple photographs referenced with official identification (passport/driving licence)
a. We have added clear photo-taking instructions and customer-facing examples of what a high-quality Weight Verification photo should look like.
The above will be delivered by the beginning of July 2025.
2. Real time photoa. We plan on building the functionality for customers to capture their Weight Verification photos live with their device's camera (e.g. phone camera or computer camera). This means the photo is as recent as possible and difficult to fake.

3. Meta data assessed to prevent manipulation
a. Each Weight Verification photo that is uploaded to our platform has its associated photo metadata scanned. We run automated checks on the age of each photo to ensure that any old photos are blocked from being uploaded. There are clear instructions around photo recency within the customer-facing experience.
b. We plan on running automated checks on additional metadata fields to ensure that a photo has been taken by a camera, and has not been through photo editing software. Whilst not a guaranteed way of ensuring a photo has not been edited, it improves our confidence for the 70% of photos where these fields are present.

4. AI screening
a. We are soon to release functionality that runs Weight Verification photos through our private AI model that provides immediate feedback to patients on the quality of the photo. This includes clear feedback on photo: blurriness, contrast, whether the patients' full bodies are in the photo, whether they are the only person in the photo, and filters out explicit nudity. We will soon be adding a prompt to include feedback on loose clothing. This means that the quality of each photo we receive from customers is far higher.

Independent Verification of Medical History:
1. CMS has built the function to flag higher risk patients who change their answers in the consultation to eating disorder, diabetes or BMI input questions. Enabling CMS prescribers to further scrutinise these consultations. These patients will then have their SCR, if available, checked prior to supply or an alternative method of verification will be requested.
a. CMS add a warning flag in the prescriber admin system to any patient who may indicate that they have an eating disorder or is diabetic. CMS also add a warning flag in the prescriber admin to patients who edit their height and weight after initially inputting them. This helps CMS flag patients who may be riskier.

2. Ongoing discussions with NHS England to
a. Access to the ITSM toolset requested with NHS Digital on 13th April, a blocking step that we need to complete to access health care record data.

3. Working on automated/programmatic access to SCR as manual access is not practical at scale.
a. Scoping conversations underway, investigating build or partner options. Build option blocked by waiting for set up from NHS Digital. Buy options with “Patients Know Best” and other providers in progress.

4. Every prescription issued is notified to the patients NHS GP. We have a well-developed communication pathway with our GP colleagues. We can evidence this is effective due to the interventions made. We aim to build on this safety mechanism by hosting further outreach sessions with NHS GPs and developing a dedicated GP hotline/platform to further improve the sharing of information for the benefit of patient care.

The pharmacy has also implemented a more robust clinical check process. Part of this clinical check allows the dispensary pharmacist to review submitted weight verification information to provide a second opinion on the prescribers initial BMI assessment.

As detailed in our dispensary Risk assessment, the dispensary pharmacists also conduct a manual Summary Care Record check, this is used in conjunction with the Statement of Medical Quality supplied by CMS Ltd., each day on a small amount of patients to help build confidence in the quality of the prescribing service.