There can be significant benefits for patients using online services to get medicines and treatment but there are also risks that need to be managed to protect patient safety.
We have published a guide with other UK health organisations to help people keep safe if they decide to use online services.
Our advice is to:
- Check if the online pharmacy and the healthcare professionals working there are registered with UK regulators (for example GPhC for Great Britain or PSNI for Northern Ireland). You can check if a pharmacy is registered with us.
- Check how the service works (for example charges, whether you can get a face-to-face appointment)
- Answer questions about your health honestly – it’s important to give honest and accurate information for your own safety.
Medicines are not ordinary items of commerce: for a member of the public to be able to obtain a Prescription Only Medicine (POM) online, they would need to have an appropriate consultation with a prescriber who will decide, based on the information they provide, about whether it is appropriate to issue a prescription.
Sometimes consultations may take the form of online questionnaires, online chats, or they may involve video consultations, or conversations over the telephone. It is essential that the mode of consultation is appropriate to meet the needs of the patient, and it provides the means to ensure that the prescriber has enough information to make an appropriate prescribing decision.
We would expect a prescriber to be able to demonstrate that they have all the information they need to prescribe any given treatments safely. This could be (but is not limited to) carrying out ongoing monitoring of the patient, ensuring weight and height information given to them is accurate and verified, talking to the patient, not relying solely on an online questionnaire and liaising with other healthcare professionals involved in their care. If the prescriber does decide that it is appropriate to issue a prescription, a POM can then be supplied from a registered pharmacy against that prescription.
We regulate pharmacists, pharmacy technicians and pharmacies in Great Britain, including those online pharmacies registered in Great Britain. It’s our role to make sure people receive safe and effective pharmacy care and have trust in pharmacy.
Registered pharmacies providing online prescribing (and supply) services need to meet our standards for registered pharmacies and the relevant supporting guidance, such as the Guidance for registered pharmacies providing pharmacy services at a distance, including on the internet. They need to identify and manage the risks associated with the services they are providing.
Our guidance states pharmacy owners should make sure their pharmacy staff do the following:
- Check that the patient is who they claim to be, by carrying out an identity check appropriate for the medicine being supplied
- Get all the information they need from the patient so they can check that the supply is safe for them, and other details such as their age, gender and other medicines being taken
- Assess if the person receiving pharmacy services has capacity to make decisions about their medicines.
- Identifying requests for medicines that are inappropriate (e.g., identifying multiple orders to the same address, multiple accounts or same payment details used across different orders
- Proactively share all relevant information about the prescription with other health professionals involved in the care of the person (for example their GP)
- Ensure there is appropriate monitoring or management of patients receiving ongoing treatment
- Ensure the patient has enough information to use and dispose of these medicines safely
- Gather evidence about the risks for each individual service, medicine and medical device that they provide before they start providing the service
We set standards for registered pharmacies in Great Britain; and by inspecting pharmacies we assess if they are meeting these standards.
There are two potential outcomes a pharmacy can receive from an inspection: standards met or standards not all met. All of the standards will need to be met for a pharmacy to receive a ‘standards met’ outcome. The vast majority of pharmacies (circa 85% typically) do meet all the standards when inspected.
A pharmacy not meeting all of the standards will usually have to complete an improvement action plan as our first response to failures to meet our standards for registered pharmacies. Improvement action plans are published alongside the report on our inspections website.
Our overall approach is to support and encourage pharmacy owners to meet the standards for registered pharmacies. We try to use the right regulatory intervention required to achieve the desired result. We have a number of different enforcement options available to us to secure compliance with our standards. These range from improvement action plans to statutory enforcement powers including improvement notices and conditions on registered pharmacy premises.
We use our statutory enforcement powers in situations when a pharmacy owner does not complete an improvement action plan and carry out the necessary changes to make sure our standards are met, or in situations when there is a serious risk to patient safety.
These are the considerations we take into account to secure compliance from a point of not reaching standards, to meeting standards:
- Pharmacies not meeting standards may have to complete and implement an improvement action plan (see above)
- Where this isn’t done to our satisfaction, or there is a serious risk to patient safety, we can impose conditions on their registration, for example- a legal prohibition on a pharmacy working with any prescribing service, not supplying certain medicines such as controlled drugs, or not allowing any private supplies outside the NHS system.
- Or if more appropriate we can issue an improvement notice giving a specific timescale and detailing the improvements that need to be made. If this is not complied with, the next stage is very serious and requires a referral to our Fitness to Practise Committee to consider whether the pharmacy owner should be disqualified.
- Ultimately, we can take steps to disqualify the pharmacy owner or business from owning a pharmacy.
- We choose the most appropriate enforcement option available in individual cases. This may involve using one or more of the options set out above. Our enforcement options can be used at any stage and are not sequential. In some cases, we may decide to use a combination of enforcement options.
Where concerns are raised about a practitioner’s fitness to practise, we will manage these concerns in the usual way, judging the alleged misconduct against our threshold criteria. Where there is a risk of harm to the public or it is in the public interest, we may use our powers to seek an interim order.