Distance Selling Pharmacy

Question 1

Principle 3: Premises

Answer 1

From which pharmacy services are provided and any other premises:
- Must meet standards for registered pharmacies
- Must be fit for purpose to reflect the scale of the work done

Question 2

Website layout

Answer 2

• Professional design and layout
• Must be secure and follow laws on data protection
• All info must be clear, accurate and updated regularly, and not misleading in any way

Question 3

Legitimacy of internet pharmacy displayed on website

Answer 3

• Make sure that any business that is either hosted on your website, or reached by an external link, is legitimate.
• Assure prescribers, whether medical or non-medical, follow the relevant remote consultation, assessment and prescribing guidance

Question 4

Consultation before purchasing med online

Answer 4

Make sure person cannot choose a POM and its quantity before there has been an appropriate consultation with a prescriber

Question 5

Website must clearly display:

Answer 5

1. GPhC pharmacy registration number
2. Name of the owner of the registered pharmacy
3. Name and address of the registered pharmacy that supplies the medicines
4. Name of the superintendent pharmacist (where applicable)
5. Details of the registered pharmacy where medicines are prepared (if diff to supplied)
6. Info about how to check the registration status of the pharmacy and the superintendent pharmacist (if there is one)
7. Email address + phone number of the pharmacy
8. Details of how to give feedback and raise concerns

Question 6

If the person is prescribed medicines following an online consultation, your website should also prominently display:

Answer 6

• Name of the prescriber
• Prescribers registration number and country
• Whether the prescriber is: doctor or a independent prescriber
• Address of the prescribing service
• Info about how to check the registration status of the prescriber

Question 7

Website logo compulsory

Answer 7

• Be registered with the MHRA
• Compulsory ‘Distance Selling Logo’ on every page of their website offering medicines for sale
• Logo will take them through to a list of approved UK-registered online retail sellers on the MHRA website

Question 8

GPhC Pharmacy logo (voluntary)

Answer 8

• You can have the GPhC internet logo only once you have applied for, and been given, the MHRA Distance Selling Logo

Question 9

Principles 4: Managing medicines safely

Answer 9

• Think about which medicines are safe for supplying at a distance
• Carry out an appropriate identity check
• Ensure advice is available for all medicines
• Assess suitability and provide counselling
• Awareness of abuse potential
• Signpost where relevant

Question 10

Some categories of medicines are not suitable to be supplied online

Answer 10

• Abx take into account AMR guidelines
• Medicines liable to abuse, overuse or misuse (e.g opiates, sedatives, laxatives)
• Medicines that require ongoing monitoring or management (e.g lithium, warfarin, medicines for diabetes, epilepsy..)
• Non-surgical cosmetic medicinal products (e.g Botox, Dysport)

Question 11

Safeguards to put in place if medicines not suitable for online provision are to be supplied online

Answer 11

• Assured prescriber has robust processes to check the identity of the person
• The person has been asked for the contact details of their regular prescriber, such as their GP, and for consent to contact them about the Rx
• Assured prescriber will share all relevant information about the Rx with other HCPs involved in the care of the person
• Assure prescriber has made a clear record setting out their justification for prescribing, when there is no regular prescriber

Question 12

Delivering medicines safely

Answer 12

• Ensure meds delivered safely to the correct person when they need them
• Delivery method safeguards confidential information, and delivery achieved promptly, safely and in an appropriate condition)
• Need to assess suitability of packing
• Obtain consent to provide the delivery service
• Check laws covering export or import of medicines if the intended recipient is outside of the UK

Question 13

Information for pharmacy users

Answer 13

• Call to to counsel, no f2f
• Make sure generic healthcare advice is accurate, up-to-date and of a high professional standard
• Includes all relevant details of contraindications and side-effects

Question 14

Principle 5: Specialist equipment and facilities

Answer 14

• of high specification, accuracy and security
• calibrated, maintained and serviced regularly
• latest security specifications

Question 15

MHRA enforcement team for regulation of internet pharmacy

Answer 15

• Monitor internet sites
• Focus on advertising and supply of POMs in UK
• Can remove site and prosecute those responsible
• Work with police, ISP’s, DoH and GPhC

Question 16

Software and operating system

Answer 16

• Robust enough to handle volume of work
• Control systems to manage risks
  - Easily accessible
  - You understand your software and operating systems
• Keep maintenance log
  - How to manage risk of equipment failure, and how to make pt. and public aware of any resulting delays to supply of meds.