| Standard not met | Reason | Action being taken by the Pharmacy | By when | Notification By Pharmacy Improvements Made |
|---|---|---|---|---|
| 4.2 | The pharmacy does not always make sure that it independently verifies people’s information submitted in their online questionnaires. It has a well-documented process for assessing people’s information but does not fully demonstrate that it consistently independently verifies patients’ weight, height and/or BMI before medicines are prescribed. It relies significantly on information and images submitted by people. This means the pharmacy cannot provide sufficient assurance that its safeguards are robust enough to confirm patients are clinically suitable for treatment. |
1. GP Connect implementation with Maywoods support, to independently verify height, weight, BMI, medical history and medication against the patient's live GP record at the point of prescribing, which provides access to medical records and stronger continuity of care. (Phase 1: ODS code and DSPT readiness commenced September 2026; go-live dependent on NHS England approval). 2. Tiered verification escalation applied to every enrolment: technology checks (Persona ID, metadata and plausibility checks cross-referenced to ID), escalating to an audio clarification call and then a live video consultation wherever doubt remains about weight, height, BMI or image authenticity. 3. BMI re-verification at refill- periodic re-verification every 6 months; Ensuring hard-stop measures preventing prescribing where BMI is below the safe protocol threshold as per prescribing entities protocol, or any safeguarding concern is raised. 4. Continued improvement of automated AI image-manipulation screening (TruthScan, embedded in the clinical dashboard) of every BMI verification photograph, with flagged cases held and information from metadata to be shared with prescribers to support prescribing decisions which they don’t currently see. 5. AI BMI estimation tool added to the product roadmap to independently estimate BMI from verification photographs against a declared-BMI tolerance range. Product design/procurement started within 20 working days. 6. Docman integration - We will ensure that we continue to request GP details as a pre-requisite of using our service, and will electronically instantaneously submit patient information that has been provided to us as well as treatment outcomes to GP’s in order to support with our independent verification of height, weight and BMI. 7. Apple has now announced a new technology improvement known as ‘Apple Reference Image’ which creates a digital fingerprint within the image. This will provide proof the photo that is submitted is real, which we will be able to incorporate into our current verification workflows alongside truthscan to support in independently verifying photos and thus height, weight and BMI for clinicians. (within 6 months). |
09/10/2026 | |
| 4.2 | Pharmacists complete an electronic clinical check of prescriptions before dispensing, but do not routinely use prescribing, clinical and verification information to make a suitable clinical assessment. So, there is a risk the pharmacist misses interventions to protect patients’ health and ensure supplies are appropriate. |
1. Clinical dashboard enhancement: a prescribing-journey summary panel displayed at the verification screen (clinician review date, ID verification status, previous vs current dose, allergies, titration history and alert flags for cases needing attention, e.g. low BMI, missed titration step, reported side effects) so the pharmacist has prescribing, clinical and verification information within the clinical check workflow and this will be flagged (in red) making it really clear for the pharmacist if issues are present and thus giving them the ability to make interventions. 2. Clinical check SOP updated to define the minimum information reviewed at each check based on the changes above; training delivered to all pharmacists with acknowledgement records. 3. We will continue to make improvements within the prescribing system which reduces and completely restricts the ability of prescribing clinicians to make errors which would traditionally be checked by the pharmacist clinically checking, such as quantity, dose and prescribing to individuals where certain parameters make them completely outside of protocol - e.g. age. This doesn’t negate the need for the clinical check, but supports the clinical checking pharmacist decision making process. |
09/10/2026 | |
| 1.2 | The pharmacy does not adequately demonstrate that it learns from and acts effectively on all issues identified through its governance and audit processes. The pharmacy completes a small number of marketing compliance reviews and identifies some concerns relating to promotional activity, including references to prescription-only medicines, promotional claims, pricing promotions and the presentation of risk information. But the pharmacy’s website and social media advertising does not always follow guidance issued by the Medicines and Healthcare products Regulatory Agency and Advertising Standards Authority. This means the pharmacy cannot fully demonstrate that learning from marketing compliance reviews is embedded effectively across the service. |
1. Pre-publication audits in force: This will come in the form of attending marketing team meetings to audit marketing conception conversations to ensure alignment with MHRA Blue guide and ASA/CAP guidance. 2. Complete a full compliance audit of the pharmacy's website, social media and affiliate advertising against MHRA Blue Guide and ASA/CAP guidance in order to remove/amend references to prescription-only medicines and unclear promotional claims or pricing promotions. 3. Deliver training to the marketing team around ‘What Good Looks Like’, with acknowledgement records retained. 4. Monthly marketing compliance reviews with findings logged, actioned and tracked to closure through the Governance structures, and learning formally cascaded to the marketing and affiliate teams. Superintendent/Deputy Superintendent Pharmacist to attend the fortnightly advertising concept-creation meetings and hold a monthly compliance review with the Head of Performance and Creative Lead. |
09/10/2026 | 21/10/2026 |
Pharmacy inspections
Inspection reports and learning from inspections