We carried out an announced comprehensive inspection of PrivateDoc Limited on 10 May 2017 and found that the provider was not providing safe, effective and well led care in accordance with the requirements of the Health and Social Care Act 2008. We issued Requirement Notices and a Warning Notice to the provider to drive improvement. The full comprehensive report on the 10 May 2017 inspection can be found by selecting the ‘all reports’ link for PrivateDoc Limited on our website at www.cqc.org.uk.

The areas where the provider had to make improvements following the 10 May 2017 inspection were:

• Ensure that effective age verification processes are in place.
• Ensure that care and treatment is delivered in line with evidence based guidelines. For example, ensure that dosage instructions for patients are clearly highlighted on prescriptions and that health questionnaires follow national guidance.
• Consent was electronically recorded and required to access further services from PrivateDoc. However there were no risk assessments in place on declining treatment if the patient didn’t consent to informing their GP.
• Ensure effective safeguarding processes are in place, including appropriate training for lead individuals.
• Ensure there is an effective programme in place for monitoring and supporting quality improvement.

We undertook a desk based review on 3 August 2017 to check that the provider had followed their action plan and to confirm that the requirements of the Health and Social Care Act 2008 had been met following our Warning Notice. Following the review on 3 August 2017 we found that the provider had responded appropriately to our findings and had met the requirements set out in our enforcement action.

We carried out an announced comprehensive inspection on 25 January 2018 to check the improvements were embedded and to ask the provider the following key questions: are services safe, effective, caring, responsive and well-led?

This report covers our findings in relation to those requirements and also additional improvements made since our last inspection.

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

Are services safe?

We found that this service was providing safe care in accordance with the relevant regulations. For example:

• Staff employed at the provider had received training in safeguarding and whistleblowing and knew the signs of abuse and to whom to report them.
• Systems were in place to ensure that all patient information was stored and kept confidential.
• The providerhad a system in place to assure themselves of the quality of the dispensing process. There were systems in place to ensure that the correct person received the correct medicine.

Are services effective?

We found that this service was providing effective care in accordance with the relevant regulations. For example:

• The service collected and monitored information on people’s care and treatment outcomes.
• The service monitored consultations, and carried out prescribing audits and reviews of patient records to improve patient outcomes.

Are services caring?

We found that this service was providing caring services in accordance with the relevant regulations. For example,

• Patient information guides about how to use the service and technical issues were available. There was a dedicated team to respond to any enquiries.
• The provider offered consultations to anyone who requested and paid the appropriate fee, and did not discriminate against any client group.

Are services responsive?

We found that this service was providing responsive care in accordance with the relevant regulations. For example:

• The provider identified patients who may be in need of extra support and had a range of information available on the website.
• The provider was able to demonstrate that the complaints we reviewed were handled correctly and patients received a satisfactory response.
• Staff understood and sought patients’ consent to care and treatment in line with legislation and taking into account guidance. The process for seeking consent was monitored through audits of patient records.

Are services well-led?

We found that this service was providing well-led care in accordance with the relevant regulations. For example:

• There was a clear organisational structure and staff were aware of their own roles and responsibilities. There was a range of service specific policies which were available to all staff. These were reviewed annually and updated when necessary.
• Patients had the opportunity to rate the service on an online system called “Trustpilot” which was an open system provided by a third party supplier. At the end of every consultation, patients were sent an email asking for their feedback. We noted that the service provided feedback on online forum comments.

The areas where the provider should make improvements are:

• Review consultation processes for genital herpes prescribing, including the consideration to request details of a sexual health check from new patients.
• Review the safeguarding policy to include considerations around the safeguarding of children.
• Review processes to inform patients of requirements for informing their NHS GP.

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 of PrivateDoc Limited on 10 May 2017 and found that the service was not providing safe, effective and well led care in accordance with the requirements of the Health and Social Care Act 2008. We issued Requirement Notices and a Warning Notice to the provider to drive improvement and we will be monitoring the improvements the service makes to meet the enforcement taken. The full comprehensive report on the 10 May 2017 inspection can be found by selecting the ‘all reports’ link for PrivateDoc Limited on our website at www.cqc.org.uk.On 10 May 2017 we identified regulations that were not being met. The areas where the provider had to make improvements were:

• Ensure that effective age verification processes are in place.
• Ensure that care and treatment is delivered in line with evidence based guidelines. For example, ensure that dosage instructions for patients are clearly highlighted on prescriptions and that health questionnaires follow national guidance.
• Consent was electronically recorded and required to access further services from PrivateDoc. However there were no risk assessments in place on declining treatment if the patient didn’t consent to informing their GP.
• Ensure effective safeguarding processes are in place, including appropriate training for lead individuals.
• Ensure there is an effective programme in place for monitoring and supporting quality improvement.

After the inspection the service provided us with an action plan to demonstrate how they intended to comply with the requirements of the Health and Social Care Act 2008. We carried out a focused inspection on 3 August 2017. We contacted the service to request that they send us evidence to show they had implemented the changes outlined to us in an action plan following the publication of the report of the comprehensive inspection and the warning notice. We found that the service had responded appropriately to our findings and had met the requirements set out in our enforcement action:

• Identity verification was strengthened with an electoral roll check to ensure that the person was over the age of 18 and their stated home address was correct. The provider had also risk assessed the identity verification processes but further consideration for identity concerns in the context of the service had to be made.
• Once the doctor prescribed a medicine, information was given to patients on the purpose of the medicine and any likely side effects and what they should do if they became unwell.
• The provider had implemented systems to receive and review alerts and updates from the Medicines and Healthcare products Regulatory Agency (MHRA).
• New clinical questionnaires had been developed which followed best practice guidance.

This report only covers our findings in relation to the improvements required following our enforcement action in May 2017. You can read the report from our last comprehensive inspection, by selecting the ‘all reports' link for PrivateDoc Limited on our website at www.cqc.org.uk.

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 PrivateDoc Limited on 10 May 2017. PrivateDoc Limited offers a digital service that allows patients to obtain a prescription and purchase medicines from an affiliated pharmacy which we do not regulate but is registered with the General Pharmaceutical Council.

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

Our key findings were:

• There were systems in place to protect patient information and ensure records were stored securely.
• On registering with the service, patient identity was only verified by credit/debit card checks. Electoral roll identity checks were in the process of being introduced, but were not yet live at the time of our inspection.
• The provider complied with the requirements of the Duty of Candour.
• Safety alerts, for example those from the Medicines and Healthcare products Regulatory Agency (MHRA), were considered but there were no records available to indicate that these had been actioned.
• There were enough doctors to meet the demand of the service and appropriate recruitment checks for all staff were in place.
• We found that assessments of patient needs and care was not consistently being delivered in line with relevant and current evidence based guidance and standards. Clinical questionnaires that patients had to complete required improvement and there were no clear dosage instructions highlighted to patients. The provider told us they amended their questionnaires to reflect NICE guidelines after our inspection.
• The service had arrangements in place to coordinate care and share information appropriately for example, when patients were referred to other services. But information sharing with other services did not take place consistently.
• Medicines prescribed to patients from online forms were monitored by the provider through ad-hoc reviews to ensure prescribing was evidence based, although we noted the process for following up these reviews was not fully embedded. There was a complaints policy which provided staff with information about handling formal and informal complaints from patients.
• The provider told us they had a clear vision to provide an accessible and responsive service.
• Practice policies were in place and available.
• The provider was responsive to our findings and made immediate changes where possible. For example, on the day of the inspection the provider removed asthma treatment from their website and service provision while they reviewed the prescribing protocol.

We identified regulations that were not being met. The areas where the provider must make improvements are:

• Ensure that effective age verification processes are in place.
• Ensure that care and treatment is delivered in line with evidence based guidelines. For example, ensure that dosage instructions for patients are clearly highlighted on prescriptions and that health questionnaires follow national guidance.
• Consent was electronically recorded and required to access further services from PrivateDoc. However there were no risk assessments in place on declining treatment if the patient didn’t consent to informing their GP.
• Ensure effective safeguarding processes are in place, including appropriate training for lead individuals.
• Ensure there is an effective programme in place for monitoring and supporting quality improvement.

The areas where the provider should make improvements are:

• Implement an effective process in place for the recording of safety alerts, for example those from the Medicines and Healthcare products Regulatory Agency (MHRA).
• Improve the recording of incidents and significant events.
• Maintain evidence of training for clinicians.

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice

We found a service that was well led by people who were mindful of people’s privacy and safety. We found safeguards in place to protected people’s private information. That included their medical and financial details. Information supplied was straightforward and clear for people to make an informed decision.

Treatment was based upon a thorough medical assessment. Doctors were paid for their judgement and diagnosis of the person and their conditions. This was not linked to the prescription of any drug or amount of drug, therefore people were assured that the treatment they received was impartial and in their best interests.

People using the site were not incentivised to choose one drug over another as no medication was on special offer or promoted through publicity more than any other. This meant that people were more likely to choose the medication best suited for them.

This report does not contain any feedback from people who use this service. A potential system to be initialled by the provider was discussed at the inspection, but no feedback was received. On balance this has not been followed up as we do not hold any adverse intelligence about this service. Therefore we will seek people’s feedback on the next inspection visit to this service.