One feature of the ongoing pandemic is that patients have much reduced access to face-to-face consultations with healthcare professionals.
This, combined with patients already making increased use of online providers in recent years, has led to a huge increase in medications being prescribed remotely by those qualified to do so (principally doctors, although other independent prescribers such as suitably qualified pharmacists can also prescribe remotely).
Doctors and other healthcare professionals will clearly wish to ensure they are prescribing in a manner that is safe, in the best interests of patients, and also in line with guidelines issued by their regulatory bodies.
The General Medical Council (“GMC”) has recently published updated guidance to assist doctors in this area and a copy of that can be found here (the “Guidance”).
The updated Guidance takes effect from Monday 5 April 2021 and sets out how a doctor can, in practical terms, maintain compliance with the relevant principles of Good Medical Practice.
A more general aim of the Guidance is explained by the GMC’s Medical Director and Director of Education and Standards Professor Colin Melville:
"Our updated guidance supports doctors who are navigating what for many has become a new reality of remote medicine, helping them to maintain good patient care in these incredibly challenging circumstances. It’s vital that the principles of good practice apply, whether a consultation is face to face or remote"
The last sentence is a key one so far as the Guidance is concerned – namely, the Guidance applies to all prescribing, whether face to face or remote, and the standards that apply for prescribing in a face-to-face consultation remain exactly the same when remote prescribing. As the Guidance itself states:
“This guidance applies equally to all prescribing, in whatever setting your interaction with a patient takes place, including remote consultations. If you can’t meet the standards, it may be appropriate to offer an alternative mode for the consultation to ensure safe care that meets our standards”
In terms of its contents, the Guidance is comprehensive and covers such issues as:
- Keeping up to date and prescribing safely
- Deciding if it is safe to prescribe
- Assessing the mode of consultation, does it meet the patient’s needs?
- Obtaining information from patients, sharing that information and matters of consent
- Controlled drugs and other medicines where additional safeguards are needed
- Raising concerns and reporting adverse drug reactions, medical device incidents and other patient safety matters
- Reviewing medicines and repeat prescribing.
The Guidance also includes helpful and extensive links to other sources of relevant information such as NICE guidelines, GPhC guidance and MHRA guidance. As such, the Guidance will be of interest to any healthcare professional who may prescribe medicines, even if they are not regulated by the GMC.
Readers will have noted the Guidance is ‘updated’ and most will doubtless already be familiar with the previous guidance on this topic, issued by the GMC in 2013. The new Guidance contains substantial updates and expands from 12 pages to 17 in length. The changes of greatest note are:
- new advice for doctors to stop prescribing controlled drugs without access to patient records, except in emergencies
- stronger advice on information sharing, making it clear that if a patient refuses consent to share information with other health professionals it may be unsafe to prescribe.
- alignment with the GMC’s updated ‘Decision making and consent’ guidance, highlighting the importance of good two-way dialogue between patients and doctors in all settings
- updated advice on treating patients based overseas, to clarify that doctors may need to register in the country where they are based, where the patient is based, and where prescribed medicines are to be dispensed.
In addition, the 2013 guidance had a specific section devoted to “remote prescribing via telephone, video-link, or online” whereas the new Guidance integrates any comments on remote prescribing matters into the body of the relevant section. This mirrors how remote prescribing itself is now more integrated into current medical practice and also re-enforces the message that remote prescribing is not to be viewed as some distinct subset of prescribing generally.
Doctors would be well advised to familiarise themselves with the new Guidance before it takes effect in April. Whilst the Guidance is just that (i.e. a set of guidelines, not rigid tramlines), if any issues with prescribing arise, actions will inevitably be judged (in a fitness to practise context at least) by reference to the standards set out within the Guidance.
Please don't hesitate to contact me or another member of our Professional Discipline Team should you need assistance in relation to any GMC or fitness to practise matter.
