Tackling patient safety concerns when providing pharmacy services online

4 October 2022

With a growing demand for online pharmacy services, models of delivery are developing rapidly - which means pharmacy and other healthcare services are being delivered in new and innovative ways. This can be useful for patients and the public and we support and encourage these changes as long as people using these services receive safe, effective and person-centred care.

Unfortunately, this is not always the case.

We are continuing to identify serious patient safety concerns relating to some online pharmacies and online prescribing services.

  • Around a third of our open fitness to practise cases relate to online pharmacy 
  • Only 71% of online pharmacies that we inspected from 2019-22 met all our standards for registered pharmacies, compared to an overall benchmark of 84%.

Common themes in our open fitness to practise cases

Unacceptable prescribing practices

  • medicines being prescribed to patients based on an online questionnaire alone, with no direct interaction between the prescriber and the patient or their regular prescriber. This is of particular concern where it is part of a high volume, transactional supply of high-risk medicines
  • prescribing of medicines outside the prescriber’s scope of practice
  • transactional approach to prescribing with high volumes of prescriptions being issued by the prescriber in short periods of time
  • inadequate assessment of informed consent from patients 

Inadequate governance structures

  • prescribing of high-risk medications or medications which require monitoring without adequate safeguards in place
  • using overseas prescribers outside of UK regulatory oversight
  • poor risk management
  • poor record keeping 

What action we’re taking

Where there are serious concerns regarding patient safety, we have taken enforcement action to ensure standards are being met and people are not being put at risk.

We continue to prioritise and focus our resources on those models which pose a higher risk to patient safety through our risk-based and intelligence-led inspections. We are also taking a preventative approach by utilising regulatory levers at an earlier stage, for example, at registration of new premises.

In addition, we are leading a cross-regulatory group to help raise public awareness and help educate people on how to access medicines safely online.

Enforcement actions taken against online pharmacies and pharmacists

March 2019 – August 2022 – Enforcement action taken against 55 online pharmacies

March 2022 – August 2022 - Seven interim orders placed on the registration of pharmacists who have worked for or with online prescribing services whether through dangerous prescribing practice, poor governance structures or lack of due diligence when dispensing 

Ongoing – Currently investigating more pharmacists working for online services with further action expected

Ongoing- bringing disqualification precedings against those pharmacy owners which have not made significant improvements or changes to governance structures 

Actions to take if you work for or own an online pharmacy or prescribing service

Pharmacists and pharmacy technicians

You should:

  • make sure you are meeting our standards for pharmacy professionals at all times
  • make sure that the organisation or service that you are working for is appropriately regulated in the UK and/or is meeting the relevant UK regulatory standards for that service, including our standards for registered pharmacies if it is a registered pharmacy 
  • seek assurances that the service is following the relevant parts of our guidance on providing pharmacy services at a distance, including on the internet

Pharmacist independent prescribers

As well as the actions above, you should:

  • make sure you follow our guidance for pharmacist prescribers when prescribing
  • follow the Royal Pharmaceutical Society’s competency framework for all prescribers
  • consider other guidance such as the General Medical Council’s guidance on prescribing

Pharmacy owners and superintendents

You should:

  • make sure you are meeting our standards for registered pharmacies and following our guidance for registered pharmacies providing pharmacy services at a distance, including on the internet at all times
  • make sure that you actively and successfully manage the extra risks which are created if your service lawfully involves working with prescribers or prescribing services that are not regulated by UK regulators
  • not work with online providers who try to circumvent the regulatory oversight put in place within the UK to ensure patient safety
  • make sure that the prescribing models used to prescribe medicines dispensed by your pharmacy, support the prescribers to make prescribing decisions in line with our standards for pharmacy professionals and our guidance for pharmacist prescribers

Prescribers from other professions

We recognise that some online pharmacies employ doctors to prescribe medicines to patients. The General Medical Council (GMC) provides clear guidance on prescribing, which applies to doctors working for these services. The guidance highlights that doctors should only prescribe medicines if they have adequate knowledge of the patient’s health and are satisfied that the medicines serve the patient’s needs. See the ‘find out more’ section for more information.

Find out more

Below is a list of resources to help you make sure you are meeting our regulatory standards and guidance and working in line with good practice.

GPhC information

Information from other regulators