Further advice to independent prescribers involved in private online pharmacy services

Further to our last message about the enhanced areas of risk when pharmacists prescribe this alert is directed at independent pharmacist prescribers who provide prescribing services for online pharmacies.

Wed 20th November 2019 The PDA

See our recent article here

The GPhC has produced useful information about this area of practice (click here) and we are aware that targeted inspections of online pharmacies are underway with enforcement action being taken against those businesses which do not meet the standards. In the online pharmacy scenario, the practice is manifestly much more risk-laden for the pharmacist because of the extraordinarily high risks of patient harm due to the lack of proximity situation and also because of the business models that are sometimes operated.

Consequently, the regulators are taking extraordinary measures by way of a proactive additional inspection regime even though nothing wrong may even have yet occurred. During this process, the clinical competence of pharmacists associated with those pharmacies is also placed under scrutiny using specialist expertise within the GPhC.  A number of prescribing pharmacists are now on their way to Fitness to Practise hearings as a result of these inspections.

Online pharmacies also use medical prescribers to provide similar services to support their business model and following referrals of those practitioners to the General Medical Council, several have now been suspended from practice. The GPhC will hold pharmacist prescribers to the same standard of clinical competence and patient care as that of doctors if their practice is investigated; so that pharmacists can assess their own levels of competence to provide such services and identify the risk management steps necessary to protect their registration, the PDA urges its members to read the following Fitness to Practice cases we have identified:

https://www.mpts-uk.org/-/media/mpts-rod-files/dr-edward-pooley-18-july-2019.pdf

https://www.mpts-uk.org/-/media/mpts-rod-files/dr-dharson-dharmasena-18-july-2019.pdf

These two fitness to practice cases demonstrate the level of scrutiny that independent prescribers may face on how they clinically assess patients as being suitable for being prescribed high risk medicines and that simple tick box self-assessment protocols are not in themselves sufficient to demonstrate appropriate clinical input. A review of these cases followed by a reflective CPD exercise can help pharmacists demonstrate a positive attitude towards their own professional development and most importantly help ensure patients continue to receive the high standards of care that pharmacists are well placed to provide.

Furthermore, use of the Boundaries of my Competency to Practice Statement (BCPS) is both a useful mechanism to help a pharmacist reflect upon their competence prior to taking on any such responsibilities as well as a useful exercise in terms of providing a defence platform in the event of an investigation or proactive inspection or other form of scrutiny. Participation in a documented BCPS process should help to make it much more apparent to the pharmacist ahead of starting an online pharmacy role, if they are getting involved in something for which the risks may be too high, and the responsibilities may be too onerous.

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