PHARMACY REGULATIONS & THE GPhC
Gary Wilson from MedivaPharma explains why a pharmacy must acquire direct patient consent as part of the prescribing process
Patient consent is a necessity in prescription practices but this seems to be missing in standard pharmacy practices within the Aesthetics industry. A prescription is the property of the patient, and the patient must consent to the professing and dispensing of their prescription.
Practices & Principles
MedivaPharma is an established medical aesthetics pharmacy operating in the UK for over three years. The pharmacy prides itself on supporting only licensed and registered healthcare professionals in aesthetics and rejecting any proposal for categorising trained healthcare professionals alongside beauticians and other non-healthcare practitioners. The pharmacy continues to work towards ethical and responsible pharmacy practices that protect healthcare professionals and patients. Our principles have shaped our position within the aesthetics industry and our customer know what we stand for.
MedivaPharma intends to maintain its pharmacy principles and call for more industry regulation – one of the pharmacy’s consistent stances is to acknowledge that only licensed, registered and regulated healthcare professionals can order medical aesthetic products. We work within GPhC regulations, as part of our pharmacy practices, protect the integrity of genuine prescribers, promote patient safety, and ethically responsible pharmacy practices.
The General Pharmaceutical Council (GPhC) published guidance for registered pharmacies providing pharmacy services at a distance, including on the internet, in 2015. Since the release of this guidance MedivaPharma has had many discussions with the GPhC in order to deliver a pharmacy service complaint with the rules and what this means for the practitioner and the patient.
The guidance reflects on the changes in pharmacy services, from a traditional (community) pharmacy service that includes the sale and supply of medicines on pharmacy premises, to the latest innovative changes in pharmacy that offer internet and distance based services. It includes how pharmacies show they achieve the same outcomes for patients, and people who use the pharmacy services, in providing safe treatment, care and services,. The scope of this guidance covers non-traditional pharmacy services, including:
- A pharmacy service where the prescriptions are not handed in by patients but collected by pharmacy staff, or received by post, or electronically, such as an electronic prescription service.
- An internet pharmacy service, including ones linked to an online prescribing service.
Section 4.1 (Transparency and Patient Choice) of the GPhC’s Guidance for registered pharmacies providing pharmacy services at a distance, including on the internet outlines the pharmacy’s need to receive patient consent to any and all pharmacy services provided using the prescribing process.
According to the guidelines, a pharmacy must receive some form of patient consent regarding their prescription.
‘In all cases, you and your pharmacy staff must make sure patient consent to any pharmacy service you provide using these prescribing services.’
The guidance elaborates further on the transparency between prescribers, pharmacy and patient. As a pharmacy, we must show that arrangements with medical or non-medical (independent) prescribers are transparent, do not cause conflict of interest, restrict patients choice or unduly influence patents deliberately or by mistake.
How the prescription process works
In a traditional community pharmacy, the prescriber writes a prescription for he patient which then goes to the pharmacy, either directly with the patient or sent via a nomination. I f a patient wants the prescription to go directly to a dispensing pharmacy of their choice, they would have to nominate the pharmacy via a nomination form,or through the NHS spine. Distance selling/internet pharmacies also require the same nomination process and this is currently normal practice in both local and distance selling pharmacies dispensing NHS prescriptions.
The patient would then either collect the prescription medication or nominate a representative who would pick up the prescription, such as a relative or carer, or the prescription would be delivered (by the pharmacy) with the consent as per GDPR.
The patient signs the prescription, pays for it or marks an exemption and receives the medication. the pharmacist may intervene with any medical or medication queries and is able to council the patient on their medication. The pharmacy cannot provide the medication directly to the practitioner without direct consent from the patient.
In most cases in the aesthetic business, the prescription items get delivered to the practitioner and prepared for patient treatment. Just as a community pharmacy, distance selling pharmacies need consent to deliver medication to the chosen delivery address.
In a community pharmacy, the patient would normally live in the local vicinity and the prescriber would be known by the pharmacy. The pharmacist would have face-to-face contact with the patient and would be able to confirm the patients identity, to discuss any medication queries to enable them to check the supply is safe and appropriate and the patient would pay the pharmacy directly where applicable. In most circumstances, the pharmacist would see the patient at least once a month. This face-to-face interaction does not happen in distance selling pharmacies so a measure needs to be undertaken to allow the pharmacist to ensure safe supply of medication and payment is take n appropriately.
MedivaPharma pharmacy aims to offer transparency and choice, like a community pharmacy; it aims to seek patient consent on all patient prescription sent to the pharmacy, a process that will better support genuine healthcare professionals acting in the best interests of the patient. The pharmacy regularly checks the status of licensed healthcare professionals to control the supply of aesthetics product to licensed and regulated healthcare professionals. All prescription medicines that are dispensed from our pharmacy are intended for the use of the named patient only. Appointed prescribers show patient consent for the pharmacy where they are sending h prescription to be dispensed, who is paying for the prescription and delivery address of the patients prescription medication. After all the prescription is the the property of the patient so they should be fully involved in this decision!
Impacts on the Industry
The requirements for patient consent should allow pharmacies to better support genuine licensed healthcare professionals and to ensure medications and prescriptions are provided ethically and responsibly for appropriate patient use.
A pharmacy is responsible for ensuring genuine prescriptions are processed in the best interest of the patient and the prescriber. If a pharmacy is not in the position to validate the authenticity of the patients requirements or whether that patient is in fact aware of the prescription, then this has negative impact on the genuine healthcare professionals who offer fully compliant consultations with patient safety at the heart of their clinical practice.
If a pharmacy is in a position to validate the authenticity of a patient then it will become less likely for a medical prescriber to prescribe irresponsibly for non-healthcare professionals, including beauticians.
The patient should be aware of the value of a pharmacy in the treatment process. If prescribers are more transparent about their use of a regulated pharmacy, and the prescription process to patients, then this should condition the mindset of patients to understand the seriousness and importance of using licensed healthcare professional for their cosmetic treatments. Pharmacies, both traditional and distance selling/internet based, must also be responsible to the patient.
MedivaPharma is making a required step towards structuring its prescription process that accounts for patient consent in line with the GPhC and GDPR regulations and welcomes other reliable and ethically responsible pharmacies to do the same.
Gaining patient consent is the first step in working towards an industry that puts patient safety first, and supports registered and genuine healthcare professionals in the aesthetics industry.
- As featured in the Consulting Room Magazine, Volume 1: Issue 3 | July – September 2018. https://www.consultingroom.com/subscribe/
- GPhC, 2015; ‘Transparency and patient choice’- Guidance for registered pharmacies providing pharmacy services at a distance including on the internet, Section 4.1 pp.15. View Guidelines