Letter from the Chief Inspector of General Practice

The Independent Pharmacy is an online service providing patients with prescriptions for medicines that they can obtain from the provider’s registered pharmacy (which we do not regulate).

We carried out an announced focussed follow up inspection at The Independent Pharmacy on 10 January 2018. We had previously carried out an announced comprehensive inspection on the 25 April 2017 where we found that the provider did not provide safe, effective and well-led services in accordance with the relevant regulations. We did however find that the provider delivered caring and responsive services in accordance with the relevant regulations. We also carried out an announced focused responsive inspection on the 17 October 2017 in response to concerns we received from another regulatory body. At that time we found the provider was working through a plan in relation to the actions we had told them they needed to take and had made a number of improvements. The full comprehensive report on 25 April 2017 and the focused responsive report on 17 October 2017 inspections can be found by selecting the ‘all reports’ link for The Independent Pharmacy on our website at www.cqc.org.uk.

This Inspection was carried out to follow up on breaches of regulations identified at our previous comprehensive inspection on the 25 April 2017. We inspected the safe, effective and well-led key questions.

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

Safe – we found the service was providing a safe service in accordance with the relevant regulations.

Specifically:

• Suitable numbers of staff were employed, appropriately recruited and had received training appropriate to their role.
• Risks were assessed and action taken to mitigate any risks identified.
• Systems were implemented to ensure learning from safety incidents, including significant incidents and safeguarding, were shared with all staff at monthly meetings.
• We found patients were prescribed a range of medicines. There were systems in place to ensure that excessive amounts of medicines were not supplied and prescriptions were not issued if the service had any concerns for the safety of the patients.

Effective - we found the service was providing an effective service in accordance with the relevant regulations.

Specifically:

• Arrangements for patient consultations were effective and information was now shared with a patient’s own GP in line with GMC guidance.
• Staff had now received the appropriate training to carry out their role.

Well-led - we found the service was providing a well-led service in accordance with the relevant regulations.

Specifically:

• The service had clear leadership and governance structures.
• Policies and procedures had been reviewed and all staff had access to these.
• Systems and processes had been implemented and embedded in the service to ensure patients were kept safe.

The areas where the provider should make improvements are:

• Monitor improvements made to assess their effectiveness and ensure ongoing quality improvement.

We saw one area of notable practice:

• The service provided a testing service for sexually transmitted infections and where patients tested positive, systems were in place to advise patients on the most suitable service available to them to seek further help, such as injectable antibiotics, near their home address. Patients who tested negative but were experiencing symptoms of sexually transmitted infections were referred to their own GP or nearest sexual health clinic.

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice

Letter from the Chief Inspector of General Practice

The Independent Pharmacy is an online service providing patients with prescriptions for medicines that they can obtain from the provider’s registered pharmacy.

We carried out an announced focussed responsive inspection at The Independent Pharmacy on 17 October 2017. This inspection was carried out under Section 60 of the Health and Social Care Act 2008 as part of our regulatory functions and in response to concerns we received about the provider’s prescribing practices from another regulatory body. The inspection was to check whether the service was undertaking safe prescribing and that the governance arrangements ensured systems and processes were operating effectively to ensure patient safety. Therefore, this inspection focused on the safe and well-led key questions.

We had previously carried out an announced comprehensive inspection on the 25 April 2017 where we found that the provider did not provide safe, effective and well-led services in accordance with the relevant regulations. We did however find that the provider delivered caring and responsive services in accordance with the relevant regulations.

At this inspection on the 17 October 2017, we found the provider was working through a plan in relation to the actions we had told them they needed to take and had made a number of improvements. We found that in some areas this service was not providing safe, effective and well-led services in accordance with the relevant regulations. As such our judgement from our previous inspection on the 25 April 2017, that this service was not providing safe, effective and well-led services in accordance with the relevant regulations remains unchanged.

Specifically, we found:

• Patients were prescribed a range of medicines following consultation with a clinician. There were systems in place to ensure that excessive amounts of medicines were not supplied and the provider had improved its system to ensure prescriptions were not issued if the service had any concerns for the safety of the patients.
• Systems to mitigate safety risks including analysing and learning from significant events and safeguarding were being developed.
• The provider was undertaking a risk assessment for the areas of prescribing where they would need to share information about treatment with the patient’s own GP in line with General Medical Council guidance.
• Some medicines used to treat long term conditions, such as for high blood pressure, had been suspended until a safe system was implemented to ensure patients received the appropriate monitoring from their own GP.

The areas where the provider should make improvements are:

• Continue to develop and improve the management of significant events, incidents and alerts to ensure leaning points are identified and cascaded to all staff.
• Continue to risk assess the areas of prescribing to ensure patients’ own GPs are consistently informed of treatment where appropriate.

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 The Independent Pharmacy on 25 April 2017.

The Independent Pharmacy is an online service providing patients with prescriptions for medicines that they can obtain from the provider’s registered pharmacy. The service issues prescriptions for an average of 2200 items per month.

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

Our key findings were:

• Patients could access a brief description of the clinicians available.
• Systems were in place to protect personal information about patients. The company was registered with the Information Commissioner’s Office.
• There was a basic credit card checking system to check the patient’s identification.
• The service did not always share information about treatment with the patient’s own GP in line with General Medical Council guidance.
• We found patients being prescribed a range of medicines. There were systems in place to ensure that excessive amounts of medicines were not supplied and prescriptions were not issued if the service had any concerns for the safety of the patients.
• There were no systems to mitigate safety risks including analysing and learning from significant events and safeguarding.
• Appropriate recruitment checks had not been carried out for all staff.
• An induction programme was in place for all staff, and clinicians registered with the service received specific induction training prior to treating patients. Staff, including clinicians, also had access to all policies.
• 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. However, the complaints policy did not comply with the relevant regulation and there was no evidence that complaints had been monitored over time and learning shared with staff.
• Survey information we reviewed showed that patients were satisfied with the care, treatment and service they 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 they could raise any concerns.
• There were clinical governance systems and processes in place to ensure the quality of service provision.
• The service encouraged and acted on feedback from both patients and staff.

We identified regulations that were not being met (please see the requirement notices at the end of this report). The areas where the provider must make improvements are:

• Ensure care and treatment is provided is a safe way to patients.
• Ensure staff receive training necessary for them to carry out their roles.
• Ensure specified information regarding members of staff are available.

The areas where the provider should make improvements are:

• Ensure their complaints policy is reviewed regularly to ensure it complies with the relevant regulation.
• Ensure safe systems are in place for the diagnosis of sexually transmitted infections.

We found that this practice was not providing care in accordance with the relevant regulations. We have told the provider to take action. (See full details of this action in the requirement notices at the end of this report).

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice