The General Pharmaceutical Council (GPhC) has just launched a consultation requesting views on changes to their 2015 guidance for pharmacy services, specially for those services provided on the internet or at a distance.
The consultation process will run for 8 weeks, until 21 August 2018, and we strongly urge all providers within this specific sector to contribute.
This is all the more important because of the tone of the consultation itself; coming from a place of concern rather than merely collaboration. In the introduction to the consultation, the GPhC state that they “are increasingly concerned about the way some services appear to undermine the important safeguards that are in place to protect patients from accessing medicines that are not clinically appropriate for them”.
Once the consultation has concluded, the GPhC will consider the responses and formulate new, strengthened guidance for those who provide pharmacy services on the internet or at a distance.
There is much of note within the consultation document and providers must consider the detail to appreciate the potential consequences.
For example, within the first proposal, ‘Transparency and patient choice’, the GPhC state that “a good pharmacy service will verify the patient’s identity so that the medicines are right for the patient”. Within itself, wholly unarguable, but to what extent will the identity need to be identified?
We have recently seen instances of providers being criticised for not contacting or consulting with a service user’s NHS GP, even in circumstances where the service user has explicitly stated that they do not consent to this contact. It is therefore up to providers to respond with explanations of their policies; to supply details of what they consider to be the minimum and/ or maximum steps a provider should be expected to take.
A further highly significant statement is that “We believe that there are certain categories of medicines that may not be suitable to be prescribed and supplied online unless further action is taken to make sure that they are clinically appropriate for the patient”. The list which follows includes:
- opiates and sedatives
- medicines for chronic conditions (such as asthma and diabetes)
- medicines for mental health conditions
- non-surgical cosmetic products (such as Botox)
This therefore has the potential to have a huge (and potentially hugely financially damaging) impact on the sector, if providers are not prepared for it and if they do not understand what steps their regulator wishes them to take to be able to prescribe these wide-ranging medications.
The timing of the consultation, and the emphasis for greater scrutiny of the online and at-a-distance pharmacy providers is not particularly surprising, given the current environment.
A cursory Google search will bring up at least a dozen cases reported by the media, in which service users died or were seriously injured after taking medication which was inappropriately prescribed. Many of these tragic stories involve individuals who, for whatever reason, did not divulge their full medical history to an online prescriber. This is of course a risk inherent with prescribing in any environment, but regulators (including the GPhC and the CQC) have argued that there are greater inherent safeguards in the traditional face-to-face interaction with your NHS GP.
Providers will be quick to highlight that safeguards can and indeed have already been built in to their online service provision and that the current criticism of the move to online is more a reflection of a fear of ‘the new’ (and the financial impact this could have on ‘the traditional’) than any concern of real risk of harm to service users.
CQC however are also yet to be swayed to the provider position. In March 2018, they published the results of the last 12 months of inspections of all 55 online primary care services. Their summary was that, whilst improvements had been made, further action had to be taken.
Whilst noting the potential for online providers to improve access and convenience to patients, CQC warned against the inconsistencies within the services inspected. The statistic most often cited within the media was that 43% of the providers inspected were found not to be providing ‘safe’ care. The examples CQC gave for their concerns (inappropriate prescribing of antibiotics, prescribing high volumes of opioid-based medicines without talking to the patient’s registered GP, inappropriate prescribing of medicines for long-term conditions) are, unsurprisingly, the very same issues being explored in GPhC’s consultation.
It will always and understandably be the case that new ways of doing things will encounter suspicion and scrutiny; this is to be expected. This is not the time for the online and at-a-distance provider sector to stick their fingers in their ears and merely hope that the regulators will learn to trust them in the not too distant future.
Providers should instead treat this consultation as an opportunity; to demonstrate their willingness to engage with their regulators, to explain the safeguards they have in place and why, to demonstrate the safety of their procedures and the depth of their thinking. It is the absence of understanding which is more likely to engender fear and retaliation. We therefore urge providers, take this opportunity to allow the GPhC to understand you.