New ways of delivering health care, using advances in technology, have the potential to improve accessibility and convenience for patients. But they can also carry particular risks which need to be successfully managed.
We are seeing a growing number of providers offering online primary care services, including online pharmacy services, using a range of different online technologies and offering a range of different services.
We have always said that we encourage responsible innovation that may benefit patients, but are also clear about our responsibility to protect people who want to use pharmacy services. This means understanding potential risks and taking action to help make sure these risks are mitigated as far as possible.
Why are more safeguards needed?
Regulating healthcare services on the internet is complex, with different organisations and agencies responsible for different parts of the service. We have been working closely with other regulators in Great Britain involved in regulating online prescribing services to help make sure patients receive safe and effective care at each stage, from when they first visit an online primary care service to when they receive their medicines from a pharmacy.
But we are aware of situations where patients have been put at risk because of the inappropriate prescribing, sale and supply of medicines on the internet. This includes through concerns raised with us and through our work with other regulators.
As an example, the CQC’s recent report, The state of care in independent online primary care services, sets out their findings from their first full programme of inspections of primary health care provided online. This highlights significant concerns around patient safety, including around safeguarding and inappropriate prescribing.
We have become increasingly concerned about the way some primary care services appear to undermine the important safeguards that are in place to protect patients from accessing medicines that are not clinically appropriate for them. It sometimes appears to be too easy for people to obtain prescription-only medicines; someone can obtain a prescription-only medicine with just a few clicks on the screen, answering a short online questionnaire and submitting some credit card details. But medicines are not ordinary items of commerce and must not be treated as such.
We therefore want to play our part in strengthening the safeguards in place for patients and the public trying to obtain medicines online through the guidance we set for pharmacy owners and through our inspections of online pharmacy services.
In 2015, we published guidance which sets out what is expected of pharmacy owners who provide pharmacy services at a distance, including on the internet. We think that the time is right to update this and are proposing to strengthen the guidance.
We want to hear people’s views on these proposals, to make sure we have addressed all the key issues in this rapidly changing area. I’ve set out the key points below, and how you can help shape the final guidance.
What are we proposing?
We plan to include the following points in our updated guidance:
- Transparency and patient choice
We are proposing to set out what information the pharmacy should give people about the online primary care services being offered, and who is providing them, so people can make an informed decision about where to obtain medicines and other services.
- Making sure medicines are clinically appropriate for patients
We are seeking views about whether it is appropriate for pharmacy websites to allow patients to choose a prescription-only medicine, and its quantity, before having a consultation with a prescriber. We want to know the potential benefits and risks of patients being able to do this.
- Further safeguards for certain categories of prescription only medicines
We are proposing that certain categories of medicines, including antimicrobials (antibiotics) and opiates/ sedatives, may not be suitable to be prescribed and supplied online unless further action is taken to make sure that they are clinically appropriate for the patient, such as contacting the patient’s GP. We would make clear that it is not appropriate for pharmacy owners to work with prescribing services unless they are assured that the safeguards we’ve identified are in place.
- Regulatory oversight
It is not appropriate for pharmacy owners to work with online prescribing providers who may try to deliberately bypass the regulatory oversight which aims to ensure patient safety throughout the healthcare system. We raise concerns in the paper about potential additional risks to patients if pharmacy owners decide to work with prescribers or prescribing services operating outside the UK. We plan to make it clear that if a pharmacy owner decides to work with prescribers or prescribing services operating lawfully outside the UK, we expect the pharmacy owner to manage the additional risks this creates.
You can find the full details of our proposals in our discussion paper. Please read it and then let us know your views by responding to our survey.