MedExpress (9012633) - Improvement action plan

The prescribing service the pharmacy works with has implemented some improvements since the last inspection such as use of technology to verify the authenticity of images provided by people accessing weight management treatments. And it has now has access to summary care records (SCRs) to verify some people's medical history. But the pharmacy cannot show that the prescribing service it works with independently verifies people's height, weight and/or BMI when issuing prescriptions for weight management medicines. And a proportion of the people it provides weight management treatments do not have SCR's so medical histories cannot be checked in the same way for these people. 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.

1. Enhanced photo upload requirements: a. Improved recency requirement, reducing from 12 months down to 2 months to enable a more reliable BMI assessment. b. Addition of new video consultation (AV) pathway 2. Utilise the existing SCR scraping tool to extract height, weight, and BMI where available. Data to be used as: a. Primary verification where current and reliable b. Secondary corroboration where partially available 3. An AI-based enhancement will analyse uploaded patient photographs to generate an estimated BMI. The system will indicate whether the estimated BMI falls within an acceptable tolerance range of the declared BMI, providing an independent verification check to support prescriber clinical decision-making. 4. AI image generation / tampering detection which allows us to automatically reject patients that upload AI generated images for their BMI verification photo. This can assess if BMI photos have been generated using all popular AI/LLM image generation techniques. 5. Automated identity verification is planned for implementation, whereby uploaded photographic identification will be validated by a third-party provider with a high level of accuracy to confirm authenticity and usability. This is to mitigate the risk of identity fraud, including the use of altered, fabricated, or third-party identification. 6. For the approximate 10% of patients that do not have a summary care record, these will follow a different prescribing pathway focusing on: a. Enhanced Consultation and Prescriber Discretion i. Strengthen consultation language to clearly emphasise: 1. The importance of full and accurate medical history disclosure 2. The clinical and safety implications of incomplete or inaccurate information ii. Enable prescribers to utilise AV consultations where additional clinical assurance is required - to allow the prescriber to interrogate the information supplied and satisfy themselves that their prescribing decision is appropriate. 7. An additional formal, pharmacy-led audit mechanism will operate on a weekly basis to provide assurance that the pharmacy entity is satisfied with the BMI evidence supporting supply decisions. Audit outcomes will be reviewed through established governance arrangements, with appropriate escalation and structured feedback to Product and Medical functions to drive continuous improvement in prescribing guidance, system controls, and service design. 1 4. This has been superseded by Live photo Capture upon registration 5. Completed 6.a.i. Complete 6.a.ii. Complete 7. Complete See associated documents for all (AV) pathway 2. Utilise the existing SCR scraping tool to extract height, weight, and BMI where available. Data to be used as: a. Primary verification where current and reliable b. Secondary corroboration where partially available 3. An AI-based enhancement will analyse uploaded patient photographs to generate an estimated BMI. The system will indicate whether the estimated BMI falls within an acceptable tolerance range of the declared BMI, providing an independent verification check to support prescriber clinical decision-making. 4. AI image generation / tampering detection which allows us to automatically reject patients that upload AI generated images for their BMI verification photo. This can assess if BMI photos have been generated using all popular AI/LLM image generation techniques. 5. Automated identity verification is planned for implementation, whereby uploaded photographic identification will be validated by a third-party provider with a high level of accuracy to confirm authenticity and usability. This is to mitigate the risk of identity fraud, including the use of altered, fabricated, or third-party identification. 6. For the approximate 10% of patients that do not have a summary care record, these will follow a different prescribing pathway focusing on: a. Enhanced Consultation and Prescriber Discretion i. Strengthen consultation language to clearly emphasise: 1. The importance of full and accurate medical history disclosure 2. The clinical and safety implications of incomplete or inaccurate information ii. Enable prescribers to utilise AV consultations where additional clinical assurance is required - to allow the prescriber to interrogate the information supplied and satisfy themselves that their prescribing decision is appropriate. 7. An additional formal, pharmacy-led audit mechanism will operate on a weekly basis to provide assurance that the pharmacy entity is satisfied with the BMI evidence supporting supply decisions. Audit outcomes will be reviewed through established governance arrangements, with appropriate escalation and structured feedback to Product and Medical functions to drive continuous improvement in prescribing guidance, system controls, and service design.