Letter from Chief Inspector of General Practice

We previously inspected Index Medical Limited on 4 May 2017. The full comprehensive report on the May 2017 inspection can be found by selecting the ‘all services’ link for location name on our website at www.cqc.org.uk.

At the May 2017 inspection we found the service was not meeting some areas of the regulations in that it was not providing Safe and Well-led services. However, we found it was providing Caring, Effective and Responsive services in accordance with the relevant regulations.

Following the May 2017 inspection, we issued Requirement Notices to the provider when the report of the inspection was published on 10 July 2017.

We carried out an announced focused inspection at Index Medical Limited on 14 December 2017. This inspection covered the Safe and Well Led key questions to confirm the provider had carried out their plan to meet legal requirements in relation to the breaches of regulations identified in our May 2017 inspection. This report covers our review of the Requirement Notices and findings in relation to those requirements.

Index Medical Limited provides an online primary care consultation service and medicines ordering service. Patients register for the service on the provider’s website. We inspected both online services known as Dr Fox online doctor and pharmacy (www.doctorfox.co.uk); and Fast Doctor on line prescriptions (www.fastdr.com). We did not inspect the provider’s affiliated pharmacy which is based in Scotland.

Our findings in relation to the key questions were as follows:

Are services safe? – we found the service was providing a safe service in accordance with the relevant regulations; and found the issues in the Requirement Notices had been addressed. Specifically:

• Arrangements were in place to safeguard people, including arrangements to check patient identity.
• Prescribing was in line with national guidance, including taking account of medicines safety alerts; and people were told about the risks associated with any medicines used outside of their licence.
• Suitable staff were employed and appropriately recruited.

Are services well-led? - we found the service was providing a well-led service in accordance with the relevant regulations; and found the issues in the Requirement Notices had been addressed. Specifically:

• The service had appropriate insurances in place.
• Staff records were complete and up to date including records of Disclosure and Barring Service (DBS) checks and confidentiality agreements.
• Clinical input, to ensure consultation templates were up to date, was provided by GPs who were registered with the General Medical Council (GMC).

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice

Letter from the Chief Inspector of General Practice

We carried out an announced comprehensive inspection at Index Medical Limited on 4 May 2017.

Index Medical Limited provides an online primary care consultation service and medicines ordering service. Patients register for the service on the provider’s website.

We found this service did not provide safe and well led services but did offer effective, caring and responsive services in accordance with the relevant regulations.

Our key findings were:

• There were clinical governance systems and processes in place to ensure the quality of service provision, however these did not always operate effectively. For example, we found adequate insurance policies were not in place, for example, employer liability insurance, public liability insurance. The provider was also unable to provide confirmation and evidence of  adequate medical indemnity insurance for two of the GPs .Post inspection we received evidence that these had been put into place.
• There was not a comprehensive system in place to check patient’s identity.
• Patients could access the service by phone or e-mail from 9am to 5pm, Monday to Saturday. The provider’s website was available 24 hours a day.
• Systems were in place to protect personal information about patients. Both the company and individual GPs were registered with the Information Commissioner’s Office.
• The service gave patients the option to share information with their GP but we found evidence of prescribing that was not consistent with evidence based guidance, for example NICE ( National Institute for Clinical Excellence) relating to asthma reliever inhalers . Prescribing was monitored to prevent any misuse of the service by patients and to ensure GPs were prescribing appropriately.
• There were systems in place to mitigate safety risks including analysing and learning from significant events and safeguarding.
• The provider was aware of and complied with the requirements of the Duty of Candour.
• There were appropriate recruitment checks in place for all staff.
• An induction programme was in place for all staff. However the provider was not able to evidence that this had taken place for all members of staff.
• Patients were treated in line with best practice guidance and appropriate medical records were maintained.
• Information about services and how to complain was available. Improvements were made to the quality of care as a result of complaints.
• Survey information we reviewed showed that over 99% of patients were happy with the service they had received.
• There was a clear business strategy and plans in place.
• Staff we spoke with were aware of the organisational ethos and philosophy and told us they felt well supported and that they could raise any concerns.
• The service encouraged and acted on feedback from both patients and staff.

We identified regulations that were not being met and the provider must:

• Ensure care and treatment are provided in a safe way for service users.
• Ensure they operate effective systems and processes to assess and monitor the service.

The areas where the provider should make improvements are:

• Ensure systems and processes are reviewed for patients to acknowledge and consent to being prescribed medicines for unlicensed use.
• Ensure systems and processes are reviewed with regards to record keeping of inductions undertaken by new staff.
• Introduce a process to review patients who may have been prescribed medicines which were the subject of medicine alerts.

You can see full details of the regulations not being met at the end of this report.

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice

Index Medical Limited run an online internet prescription service. We used the views of people who had used the service from the providers own survey information. The provider used an independent firm to seek the views of the people who had used the service. There was a high degree of satisfaction from people about the service and the way it had been provided.

The processes that were followed for consultation and treatment were clearly explained to people as was the cost. People were made aware of any risks and side effects that could occur from treatments.

There was a system in place to monitor the service provided. This included contact with people who had used the service to ask them for feedback.

There was an accessible complaints procedure on the provider’s website. Complaints were taken seriously and were addressed promptly.

Index Medical is an online internet prescription service and therefore we obtained the views of patients from survey information. The information had been provided directly to the provider.

Patients stated in their survey responses that they had been satisfied with the service and how it had been carried out. Patients confirmed that the process for consultation and treatment was explained clearly to them including the overall cost. Patients also confirmed they were told about any risks that might arise from using the service.

We found that patients’ needs were met by suitably qualified staff who provided them with an effective service.

There were suitable quality checking systems in place to monitor the overall effectiveness and safety of the service that patients were receiving.