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Remote pharmaceutical services

4 October 2014

The Medicines Act was passed at a time when the technology we use had not been dreamt of. The Act contemplated that medicines would only be supplied to someone in a pharmacy.

Home deliveries were not common in 1968, and the legal basis for home deliveries remains unclear.

The GPhC is now consulting on guidance for pharmacies that provide internet and other remote services.

In 2005, the Department of Health assumed home deliveries were lawful and allowed distance selling contracts to be granted if there are procedures to secure the safe and effective provision of essential services without face to face contact between any person receiving the services and staff at the pharmacy.

However, there has been no guidance from the regulator.

The GPhC recognises that the use of technology opens the door not just to internet services, but also to the collection of medicines from machines, click & collect, dispensing from a different location to the one from which a supply is made, and remote supervision.

It is likely that when new guidance comes into force, pharmacies who supply to remote patients will have to:

  • Carry out and document regular audits, looking at:
    • staff training 
    • communication methods with patients
    • records of decisions to make or refuse a sale, and
    • systems for secure delivery to patients
  • Carry out and document a risk assessment
  • Make sure there are clear lines of accountability for any carrier when no pharmacist is present
  • Make sure an identifiable pharmacist is accountable for each part of the service
  • Consider record keeping, which may cover:
    • information and advice provided on safe use of medicines
    • consent to a mode of delivery and date of dispatch, and
    • complaints or concerns from patients or their carers.

The GPhC suggests that pharmacists should check the identity of anyone requesting medication online, though this may not be practicable.

Pharmacies providing online services may have to display prominently:

  • the name of the owner, superintendent, and the address of the pharmacy
  • details of the pharmacy responsible for dispensing if this is done under hub and spoke arrangements
  • information about how to check the registration status of the pharmacy and the superintendent pharmacist, and 
  • details of how patients can provide feedback and raise concerns.

The GPhC is getting to grips with the impact of modern technology on pharmacy practice. The rebalancing committee that is looking at medicines law should make recommendations enabling the law to catch up.

This article was written by David Reissner.

For more information please contact David on +44 (0)20 7203 5065 or david.reissner@crsblaw.com