Providing medicines online
This policy is for all pharmacists who provide or are considering providing, online supply of medicines.
Policy Context: Medicines are not ordinary items of commerce. These powerful compounds can effectively treat illnesses but can also cause harm. The public need to be assured that the medicines they are given are safe and appropriate to their individual needs.
Online pharmacy services and access to medicines online have brought a new dimension to medicines supply. The changing habits of consumers, the exponential growth in the use of online services in the NHS over the past five years1 2, and the growth in online pharmacy, will have a considerable impact on access to medicines across Great Britain.
There is concern about the increasing number of private services prescribing and supplying medicines, and the governance structures supporting these.
The risk of harm or death associated with online pharmacy services must be minimised.
Patients and the public rightly expect all online pharmacy services to be of the same quality and standard as a ‘bricks and mortar’ pharmacy. All services providing medicines must always focus on patient safety.
This policy aims to ensure the quality and safety of online pharmacy services and consistency with the standards of ‘bricks and mortar’ pharmacies.
A checklist for online pharmacy
Any online pharmacy service should:
- Make it clear who is delivering the service, where they are physically located, and the qualifications of the professionals involved
- Be registered with the General Pharmaceutical Council (GPhC) and their registration number should be available to the public to check that they are a registered pharmacy
- Ensure the identity of the responsible pharmacist is clear and visible, just as in any community pharmacy, by using an online version of the Responsible Pharmacist3 notice
- Be able to verify a person’s identity when supplying prescription only medicines online by adhering to any national guidance provided by national regulators, including those outside of pharmacy such as the Care Quality Commission
- Always provide an opportunity to access advice from a pharmacist when medicines are supplied
- Ensure enough information is provided before any medicines purchase to support an informed decision, particularly where multiple treatments are available
- Have an online consultation process of the same clinical standard as a face-to-face consultation, including checks and risk assessments to ensure that all provided medicines and advice are appropriate for the individual
- Make it clear from the start that supply of the product, whether POM, P or GSL medicine, is dependent on a clinician reviewing suitability for the medicine as part of a consultation
- Ensure that prescription only medicines (POMs) cannot be prescribed without a thorough consultation and support from an appropriate clinician
- Ensure any algorithms used in the clinical decision making process are registered with the Medicines Health and Regulatory Agency (MHRA) and meet the NHS Digital Standard DCB01604. Algorithms should be centred on the medical condition and not the product
- Recognise that some treatments are not suitable for online provision. Risk assessments should assess which medicines, conditions and quantities are appropriate for online supply, taking into account risk of addiction, misuse, etc.
- Have a quality improvement system in place so that concerns, complaints and incidents are appropriately investigated, addressed and the learning implemented
- Ensure effective triage to healthcare professionals and services if the initial service provider cannot assess, diagnose, make a decision or supply the medicine
- Be registered with the MHRA’s register of authorised online sellers of medicines
- Display the Distance Selling Logo on every web page that provides human medicines to the public
- Have a full audit trail for the delivery of medicines which should include a signature on delivery.
Things to think about prior to providing medicines online:
People supplying online medicines must have undertaken a risk assessment to make sure the medicine is safe and appropriate.
The supplying pharmacist is responsible for ensuring the medicine is clinically appropriate for an individual as part of the clinical check. This may require access to the person’s electronic record and / or liaison with the person’s regular GP or multidisciplinary team.
Pharmacists must work only within their individual competency, using the information they have to hand and using their clinical judgement.
- Do you know the person’s age and are there safeguarding issues to consider (see MEP 2019 page 114)?5
- Is the prescription legal and can it be dispensed in the UK? (see MEP 2019 page 48)
- Can you communicate with the person’s regular GP?
- Can you communicate with the person or their carer?
- Do you have all the information you need about current and previously prescribed medicines? Do you have all the information to assess whether it is safe to supply a medicine online? What about medicines provided privately, via homecare or by other pharmacies?
- Do you have access to relevant test results and monitoring?
- How often has the person ordered this medicine from you and is this still clinically appropriate or should they be referred?
- Can you check nothing has changed in the person’s medical history? Can you check for allergies and side effects before supplying the medicine?
- Are you the independent prescribing pharmacist? If so, do you have another pharmacist or accredited checking technician to check the medicine prescribed? (see MEP 2019 page 74)
- Are you able to have mental breaks and safety checks to ensure patient safety?
- Identity Verification and Authentication Standard for Digital Health and Care Services
- GMC guidance on remote consultations
- The responsible pharmacist is the pharmacist who is in charge at that point in time. Their role is protect patient safety.
- NHS Digital Standard DCB0160
- Medicines, Ethics and Practice 2019