The GPhC has recently initiated a significant rise in enforcement actions against pharmacist prescribers connected to specific categories of online prescription services. We are aware of at least 6 pharmacists who have recently been the subject of Interim Order petitions and have had their registration suspended or severely restricted while a thorough Fitness to Practise hearing examining serious accusations made regarding their prescription practises is taking place. All of the pharmacists concerned are or have previously been associated with online prescribing services that are not subject to regulation by a UK regulator.
Common features that underpin the allegations include:
- Overreliance on a patient questionnaire to inform clinical decision-making.
- No patient/prescriber interaction.
- Prescribing high-risk medicines without adequate safeguards.
- Inadequate systems and processes which lead to inappropriate prescribing.
- Very high volumes of prescriptions authorised in short periods of time.
- Prescribers/patient relationships are established via an unregulated online portal.
In order to decide whether to dispense a drug in a safe and clinically acceptable manner, the pharmacist prescriber is required to have the essential background clinical knowledge (current physical and mental health, current medication prescribed, current secondary care treatment, investigations, and planned follow-up).
Access to patients’ medical records or communication with their GPs is a vital step in the consultation process in order for the prescriber to evidence clinical history and corroborate the self-reported information given in the questionnaire.
Such information can only be gleaned by accessing medical records or discussing with a patient’s GP and without this clinical information, it is unsafe for a clinician to prescribe any medication. If there is not a satisfactory 2-way discussion between Clinician and patient, there is a risk of inappropriate medication being prescribed including duplicate medication, drugs of potential misuse, failure to optimise current medication, giving medication in the wrong formulation, prescribe out with local or national guidelines, or clinically unsuitable drugs.
In order for the prescriber to verify the self-reported information provided in the questionnaire and support the clinical history, access to patients’ medical records or communication with their doctors is a crucial stage in the consultation process.
It is risky for a doctor to prescribe any drug without this clinical knowledge, which can only be obtained by obtaining medical records or speaking with a patient’s GP. Failure to optimise current medication, giving medication in the wrong formulation, prescribing out with local or national guidelines, or prescribing drugs that are not clinically appropriate are all examples of inappropriate medication that may be prescribed if there is not a satisfactory two-way discussion between the clinician and the patient.
