There are some exceptions to this rule, such as in the case of telemedicine, where a healthcare provider may prescribe controlled substances via a video call if certain conditions are met. However, the use of psychedelics for medical purposes is still highly regulated and not widely accepted.

One recent example of poor online prescribing practice is a story of a patient who was prescribed 75 doses of Ketamine in 5 minutes online which was then delivered to his house for under $300. Whilst providing access to low-cost medicine for patients is an ethical virtue of practice one should keep in mind that there is an online prescribing best practice which should be followed. This includes online prescribing risk analysis and subsequent mitigation which should be performed after each medicine is added to an online prescribing formulary.

However, if proper safeguards are in place there are a wide range of opportunities in the medical space, including:

• Psilocybin availability in the UK

If you would like more information concerning these opportunities you can contact one of our expert consultants here.

Consumer-facing Prescription Safety Measures

Patients should always be aware of the safety precautions necessary when dealing with chronic prescriptions. There are a variety of potential dangers that can occur such as drug interactions, accidental ingestion, and overdosing.

Above is a list of civil damages claimed by people who use the free NHS in the UK.

• Doctors registered with the GMC
• Dentists registered with the GDC
• Nurses registered with the NMC
• Midwives registered with the NMC
• Pharmacists registered with the GPhC
• Physiotherapists registered with the HCPC
• Podiatrist registered with the HCPC
• Paramedic registered with the HCPC
• Optometrists registered with the HCPC
• Therapeutic radiographers registered with the HCPC

The above registered healthcare professional must be recognised by their regulator as an independent prescriber then they can work within a registered online clinic. This can either be a GPhC or CQC regulated clinic as below.

Online prescribing is the process in which a prescribing healthcare professional uses a digital mechanism to enable them to prescribe to a patient online. There are various mechanisms by which this can occur, these include:

• Algorithmic prescribing – this is when a patient answers a series of online yes/no questions, these are then submitted to the online prescriber for review. If the questions meet the prescriber’s requirements, a prescription is electronically created and submitted to a pharmacy for dispensing.
• Video prescribing – this is when a consult is performed using a video consult system. As consultations are typically confidential in nature, often a bespoke, in-house video consult system is used. The prescriber, in this case, tends not to charge for the creation of a prescription but for the use of their time, these rates vary considerably and are similar if not more than average locum rates.
• Algorithmic prescribing plus video consult – this entails a combination of both of the techniques listed above. By using an algorithm which pre-screens patients and then feeds this data to a clinician, the time-saving benefits of algorithmic and the accuracy of video can be harnessed.
• Over-the-phone prescribing – this is an older form of telemedicine which utilises a standard phone line to offer direct communication with the patient. This method is often seen as outdated as there is no data input from the user; it is difficult to record medical histories accurately.

Before you consider setting up an online prescribing service, there are a few attributes you will need to consider:

Who will you be prescribing for? 

Before starting any new service, to avoid medico-legal issues and to meet regulatory requirements it is first best to perform a new service risk assessment. Whatever risks are foreseen, it is always a good idea to initially restrict prescribing to the UK as sending medicines abroad can have issues; this can be done by IP restriction. Once the service is more established, you will find there are other countries which are friendly to telemedicine, including France, Germany and Ireland. However, accessing these requires tweaking algorithmic questionnaires and amending protocols to fit the relevant jurisdictions.

What will you be prescribing?

Will you have an open formulary or will you restrict what you prescribe? Since, November 2019, due to the Deborah Michelle Headspeath case, which resulted in numerous online pharmacies being shut down the GPhC, CQC and MHRA (the regulators) put out joint guidance addressing unrestricted sales of certain medicines. The guidance recommended that certain medicines should not be repeated online and that  Z drugs, sedatives or opiates should not be sold. From our experience, when starting an online prescribing service it is best to restrict prescribing to a limited number of medicines via algorithmic prescribing mechanisms and then potentially upscale later on to an open formulary via a video teleconsult mechanism. We have created our own online prescribing formulary to mitigate client risks.

When will you be prescribing?

Unlike bricks-and-mortar pharmacies, online pharmacies are open 24/7. What will happen if a consult is performed on your website at 3 am in the morning? Do you have a prescriber on call to determine whether a prescription should be authorised? This could be restricted through automatic gatekeeping; however, from a commercial sense, this may result in lower patient satisfaction.

How are you checking a patient’s identity?

The GPhC and CQC expect all online pharmacies to have systems in place to carry out appropriate identity checks. 

How are you making sure it is safe?

The regulators expect that your online prescribing system is safe and fit for its purpose. To this end, the GPhC not only expect a new set of Standard Operating Procedures for how you manage the operation but systems in place which can monitor patient satisfaction, allow them to complain and contact you where necessary. 

How does the flow of prescribing work?

The regulators refer to Best Practice published by the MHRA (MHRA’s Blue Guide) and expect pharmacy owners to make sure that their websites of companies they work with are arranged so that a person cannot choose a POM and its quantity before there has been appropriate consultation with a prescriber.

How can we help?

OnlinePrescribing.com contains a fully integrated online prescribing software (including an online independent prescribing course) which you can use with our prescriber or use your own. Whether you are a prescribing nurse, pharmacist or doctor, we can give you the tools to aid you to practice online. We have two off-the-shelf portals and a further custom option.

1. Embeddable online prescribing – this is our website-specific prescribing module which can be embedded into your own website, for example, have a look at some of our partners:
   • Highgate Pharmacy
   • MeikleJohn Pharmacy
   • My Care Chemist
2. Custom online prescribing modules – we offer a wide range of solutions for healthcare practitioners wanting to practice telemedicine using a variety of ways to communicate with patients.

~ The National Health Service (Pharmaceutical and Local Pharmaceutical Services) Regulations

Regulation 25 (2)(a), which can be found in the National Health Service Regulations is often quoted by the NHS inspectorate during a refused application for a distance-selling pharmacy. The reason this regulation was initially included by the NHS was to ensure that there are no conflicts of interest in a primary care provider such as a GP surgery opening up a distance-selling pharmacy within its location. The conflict that might arise is that the GP or whoever is writing the prescription will direct the patient to the pharmacy within the building for dispensing. i.e. if the GP has a share in both businesses they will be both the gold mine and the jeweller!

The best way to avoid conflicts of interest like this is to not do it! Or if there is no other option to create a clinical governance framework which would train all prescription writers not to direct prescriptions to the pharmacy within the same building. This is very nuanced, however, has been done in multiple previous locations including Douglas Pharmacy, in Angel Islington. If you would like further advice from the pharmacist that set this up please use this link.