All pharmacies in Great Britain are expected to comply with our standards for registered pharmacies which set out the areas that pharmacy owners should consider before setting up a new service.
When setting up a new service which includes the prescribing and/or supply of medicines for weight management the pharmacy owner and the Superintendent Pharmacist (if there is one) need to consider the following:
- Are governance arrangements in place which identify and manage the risks associated with providing a weight management service?
- Do staff have the appropriate skills, qualifications and competence for their role and the tasks they will carry out? For example, is the prescriber practicing within their own scope of practice and competence, which includes having the required training, knowledge, skills and experience to prescribe medicines for weight management? Prescribers should be able to demonstrate ongoing competency of prescribing for weight management and prescribe in line with legislation and national guidance. Pharmacist prescribers should follow our guidance, In practice: guidance for pharmacist prescribers.
- Is there a system in place for keeping and maintaining the necessary records for the safe provision of the service and for managing information in such a way as to protect the privacy, dignity and confidentiality of patients and the public who receive the service?
- Are there incentives or targets that may compromise the health, safety or wellbeing of patients and the public, or the professional judgement of staff?
- Is the environment and condition of the premises safe, clean, properly maintained and suitable for the service provided? Does the premises also protect the privacy, dignity and confidentiality of patients and the public who receive the service?
- Are appropriate indemnity or insurance arrangements in place for the services provided?
Pharmacy organisations that may provide helpful advice on setting up a weight management service include:
We also recommend seeking independent legal and professional indemnity advice before starting to operate these services.
We’ve shared good and poor practice examples in relation to providing weight loss services that we’ve gathered from our inspections. You can find these in our online newsletter, Regulate.
We also recommend reading the detailed guidance from the MHRA on advertising and promoting medicine.
Providing a weight management service at a distance, particularly online, carries different risks to those in face-to-face settings. In addition to the areas mentioned in the sections above, if any part of the weight management service is to be provided online or at a distance, the pharmacy owner and the Superintendent Pharmacist(s) should consider our guidance for registered pharmacies providing pharmacy services at a distance, including on the internet.
Our guidance puts in place extra safeguards to help make sure that people only receive medicines that are clinically appropriate. The safeguards to put in place when supplying medicines for weight management include:
- Making sure the prescriber has robust processes to check the identity of the person to make sure the medicines prescribed go to the right person.
- Making sure the prescriber does not base prescribing decisions on the information provided in a questionnaire alone but instead uses a method of consultation that allows timely two-way communication between the prescriber and the person. This allows both the prescriber and the person to ask questions and get all the information they need for the medicine to be prescribed safely.
- Making sure the prescriber independently verifies the information the person provides including the person’s weight, height and/or body mass index. By ‘independently’ we mean that the prescriber uses a different way to verify the information provided to them by the person. This could be through a video consultation, in-person, from the person’s clinical records or by contacting another healthcare provider such as the person’s GP. If the prescriber is not able to verify the information the person provides or get the information they need, the person should be directed to an appropriate care provider so that they can be appropriately assessed.
- Making sure the prescriber proactively shares all relevant information about the prescription with the person’s regular prescriber after seeking the person’s consent. If the person does not have a regular prescriber, such as a GP, or if there is no consent to share information, the prescriber should then decide whether it is safe to prescribe. The prescriber should make a clear, comprehensive record, at the time they make the decision, setting out their justification for prescribing, or not prescribing. If the decision is made not to prescribe, the person should be directed to an appropriate care provider so that they can be appropriately assessed.
- Making sure prescribers are working within national prescribing guidelines for the UK and following good practice guidance. This would include following national patient safety alerts and the relevant guidance on prescribing
For more information, please see our FAQs for providing services online.
We state in the guidance that by ‘independently’ we mean that the prescriber uses a different way to verify the information provided to them by the person.
The guidance explains that the prescriber could independently verify the person’s weight, height and/or body mass index through a video consultation, in-person, from the person’s clinical records or by contacting another healthcare provider such as the person’s GP.
Verifying information through a phone call would not be appropriate when supplying medication for weight loss.
It would also not be appropriate to solely use a photograph or pre-recorded video supplied by the person to verify their weight, height and/or body mass index. This is because it can be difficult to verify someone’s weight from a photo or pre-recorded video alone. It would be particularly challenging to verify someone’s weight from a photo or video if they had a BMI between 25-30. There is also the potential risk that a photo or pre-recorded video could be digitally edited by the person.
It may in some circumstances be appropriate to use a photo or video recording when the prescriber is providing a subsequent prescription for an ongoing supply, where other means have been used to verify the initial weight before the first supply was made to the person. But there would need to be a mechanism to check how the person’s weight-loss is progressing and monitor and verify it periodically.
Additionally, people with certain co-morbidities may be suitable for weight loss treatments at lower BMIs. These are often long-term conditions and so in line with guidance, we would expect pharmacist prescribers to independently verify the person’s medical history before providing the weight-loss treatment.
If the prescriber is not able to verify the weight, height and/or BMI the person provides, or any other information they need, the person should be directed to an appropriate care provider so that they can be appropriately assessed.
Pharmacies that provide a prescribing service (including those that provide a service online) and are registered with the GPhC are not required to register with other healthcare regulators.
If the weight management service is taking place in a setting that is not registered with or regulated by the GPhC, we recommend the pharmacy owner and the Superintendent Pharmacist, if there is one, to seek guidance from their relevant healthcare regulator as to their registration requirements. For example, the Care Quality Commission, Healthcare Improvement Scotland or Healthcare Improvement Wales on the registration required for that service .
