Recently there has been a dramatic increase in action being taken by the GPhC against pharmacist prescribers associated with certain types of online prescribing services. The PDA is aware of at least 6 pharmacists within the last few weeks who have been subjected to Interim Order applications and either been suspended or had significant restrictions placed upon their registration pending a full Fitness to Practise hearing into serious allegations being made about their prescribing practices.
READ THE PREVIOUS WARNING ON THIS ISSUE HERE
All of the pharmacists concerned are or have previously been associated with online prescribing services that are not subject to regulation by a UK regulator.
Common features that underpin the allegations include:
- Overreliance on a patient questionnaire to inform clinical decision making
- No patient/prescriber interaction
- Prescribing high risk medicines without adequate safeguards
- Inadequate systems and processes leading to inappropriate prescribing
- Very high volumes of prescriptions being authorised in short periods of time
- Prescribers/patient relationship established via an unregulated online portal
To progress the allegations being made, the GPhC has instructed an expert clinical adviser whose views on online prescribing can be summarised as:
- in order for a competent prescriber to exercise their clinical judgment to make a safe and effective prescribing decision, a clinician should consider non-pharmacological treatments first in conjunction with or instead of prescribed medication. This should follow a two-way dialogue with the patient so that the patient can make an informed choice about potential treatment options.
- the pharmacist prescriber is expected to have the necessary background clinical information in order to make a safe and clinically appropriate decision to supply (current physical and mental health, current medication prescribed, current secondary care treatment, investigations and planned follow up).
- access to patients’ medical records or communication with their GPs are a vital step in the consultation process in order for the prescriber to evidence clinical history and corroborate the self-reported information given in the questionnaire
- such information can only be gleaned by accessing medical records or discussing with a patient’s GP and without this clinical information, it is unsafe for a clinician to prescribe any medication. If there is not a satisfactory 2-way discussion between Clinician and patient, there is a risk of inappropriate medication being prescribed including duplicate medication, drugs of potential misuse, failure to optimise current medication, give medication in wrong formulation, prescribe out with local or national guidelines, or clinically unsuitable drugs.
PDA Advice to Members
Members who are issuing private prescriptions via an arrangement with an online service or clinic setting where the patient/prescriber relationship is established or maintained via a website or third-party organisation which is not registered with either the relevant pharmacy regulator (GPhC or PSNI) or the country specific regulators dealing with the providers (Care Quality Commission – CQC in England; Regulation and Quality Improvement Authority – RQIA in Northern Ireland; Care Inspectorate in Scotland, or the Care and Social Services Inspectorate Wales – CSSIW, in Wales) must contact the PDA for further advice on protecting their position.
ALL pharmacist prescribers must be familiar with and follow the latest prescribing guidance issued by GPhC.
LEARN MORE
Further information relevant to managing the risks of prescribing:
- GPhC issues warning about online prescribing practice
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Support for pharmacist independent prescribers seeking to expand their prescribing practice
- GPhC Document: “Providing safe and effective treatment”
- GPhC Guidance for pharmacist prescribers – November 2019 ( republished February 2020)
- GPhC Guidance for registered pharmacies providing pharmacy services at a distance, including on the internet (updated March 2022)
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