How do your staff check the id and capacity of the patient ordering medicines on your website?
This is the first question the GPhC ask in their GPhC voluntary logo application form. It is of primary importance to them as one of the greatest risks associated with dispensing medicines online is ensuring the Prescription Only Medicine that is dispatched to the patient is received by the patient that needs it.
There have been a few documents considered Best Practices in the UK on this subject, most notably:
- UK Government Good Practice Guide (GPG) 45 – details the different confidence levels (listed below).
- The Royal College of General Practitioners – mainly talks about ID verification online for GP services.
- Patient Online Services in Primary Care – by NHS England details out what is considered Good Practice Guidance on Identity Verification in primary care.
In summary, there are 4 different levels of confidence:
- low confidence
- medium confidence
- high confidence
- very high confidence
If you are a healthcare provider you should be looking to get as close to high confidence as possible, however, this is often weighed against the practicality of the validation process which can take up a lot of the patient’s time and can be frustrating.
Low confidence in someone’s identity
Compared to not doing any identity checks, having low confidence in someone’s identity will lower the risk of you accepting either:
- synthetic identities
- impostors who do not have a relationship with the claimed identity
Medium confidence in someone’s identity
Having medium confidence in someone’s identity will protect you against the same things as low confidence. It will also lower the risk of you accepting impostors who have information about the claimed identity that’s not in the public domain.
For example, it would protect you against someone who works for the claimed identity’s employer’s HR department from using any information they have to impersonate the claimed identity.
High confidence in someone’s identity
Having high confidence in someone’s identity will protect you against the same things as medium confidence. It will also lower the risk of you accepting impostors who:
- know the claimed identity (this includes their close friends or family)
- do not match the claimed identity’s photo or biometric information
- Very high confidence in someone’s identity
- Having very high confidence in someone’s identity will protect you against the same things as high confidence. It will also lower the risk of you accepting impostors who are trying to look like the claimed identity, for example by wearing a mask or make-up.
How to check a patient’s capacity online.
The ethical concept of respecting autonomy and giving informed consent to medical treatment both depend on one’s ability to make their own decisions. Therefore, assessing a person’s capacity to make decisions is a fundamental component of all interactions between a prescriber, dispenser and patient. In the UK, as many interactions online are the first instance that the patient has come across that particular access point to the healthcare system, the only way is to ask the patient directly whether they have capacity. This may be in the form of a statement, such as:
Greetings! Your online consultation is built around the answers to this questionnaire. Please be truthful, and if you have any questions about any of your responses, check with your doctor before utilising the service:
- I am 18 years old or above. ✔️
- I am using this service on my own behalf and of my own free will. Any treatment or advice is for my sole use only. ✔️
After this initial statement which excludes age capacity and free will a more precise statement should read as follows:
I confirm the above statements are true
We try our best to help our patients, but sometimes our online service is not able to meet all of your needs. If you need help filling out forms, reading, writing or understanding complicated information, or your acne is severely affecting your mood and self-confidence, then please see your GP.
As part of our service, we will need at least two photos which clearly show the acne, so we can give you advice. We may suggest treatments that you can choose to purchase online, or we may refer you back to your GP if we feel treatment online is not the best option for you.
Conclusion
Patient identification mistakes can affect patient care and safety, reimbursement, data sharing, and interoperability, among other things. Worldwide, a variety of patient identification methods, including hybrid models, algorithms, and unique patient identities, have been put into use. However, no patient identification method currently in use has achieved a 100% match rate.
The best way to meet the requirements set out by the different regulators is to use a third party service provider known as a Know your patient (KYP) service provider. This will ensure you meet one of these confidence levels but work towards improving to a higher level. There are a wide range of service providers here is a short list we have found:
