Archived: Frosts Pharmacy Ltd

Updated 6 April 2017

Background

Frosts Pharmacy Ltd is based in Banbury in Oxfordshire. Frosts Pharmacy Ltd set up an online service in October 2012 which includes consultation with a GP. The provider moved the online part of the service to an industrial unit in October 2016. We did not inspect the provider’s affiliated pharmacy. We inspected the online service which is also known as Oxford Online Pharmacy at the following address:

Unit 7, Apollo Office Park, Ironstone lane, Wroxton, Banbury, OX15 6AY.

Frosts Pharmacy Ltd provides an online primary care consultation service and medicines ordering service. Patients register for the service on the provider’s website, select the medicines they require, complete an online consultation form which is reviewed by a GP, and if approved, the affiliated pharmacy (which we do not regulate) sends the medicines to the patient by secure post.

The service employs staff who work on site including a pharmacy manager, pharmacy and dispensing staff and administrative staff. At the time of the inspection, the service had approximately 41,200 patients registered. However, although all those patients registered with the service, not all of them may have been prescribed medicines. The provider estimated that approximately 10,000 of those patients may have not completed their order or had their prescriptions declined.

The service can be accessed through their website, www.oxfordonlinepharmacy.co.uk where patients can place orders for medicines seven days a week. The service is available for patients in the UK and in the EU. Patients can access the service by phone or e-mail from 9am to 5.30pm, Monday to Friday and 9am to 1pm on Saturdays. This is not an emergency service. Subscribers to the service pay for their medicines when making their on-line application. Once approved by the prescriber, medicines are dispensed, packed and posted; they are delivered by a third party courier service.

Frosts Pharmacy Ltd was registered with Care Quality Commission (CQC) on 23 January 2015 and have a registered manager in place. A registered manager is a person who is registered with the CQC to manage the service. Like registered providers, they are ‘registered persons’. Registered persons have legal responsibility for meeting the requirements in the Health and Social Care Act 2008 and associated Regulations about how the service is run. At the time of our inspection, the provider was in the process of updating their registration to reflect their new address.

Our inspection team was led by a CQC Lead Inspector accompanied two CQC Inspectors, a GP Specialist Advisor and a Pharmacist Inspector.

Before visiting, we reviewed a range of information we hold about the service and asked other organisations to share what they knew.

During our visits we:

• Spoke with a range of staff including the Managing Director, the pharmacist manager, a pharmacist, a pharmacist technician, two doctors and non-clinical staff.

• Reviewed organisational documents.

• Reviewed a sample of patient records.

To get to the heart of patients’ experiences of care and treatment, we always ask the following five questions:

• Is it safe?

• Is it effective?

• Is it caring?

• Is it responsive to people’s needs?

• Is it well-led?

We carried out this inspection under Section 60 of the Health and Social Care Act 2008 as part of our regulatory functions. This inspection was planned to check whether the service was meeting the legal requirements and regulations associated with the Health and Social Care Act 2008.

These questions therefore formed the framework for the areas we looked at during the inspection.

Updated 6 April 2017

Letter from the Chief Inspector of General Practice

We carried out an announced comprehensive inspection at Frosts Pharmacy Ltd on 24 January 2017.

Frosts Pharmacy Ltd provides an online primary care consultation service and medicines ordering service. Patients register for the service on the provider’s website

We found this service was not providing safe, effective and well led services in accordance with the relevant regulations. However, we found they were providing caring and responsive services in accordance with the relevant regulations.

Our key findings were:

• Patients could access a brief description of the GP available. At the time of our inspection, patients could only access a female GP for the online consultation. A hospital-based general physician who was not a GP, was contracted by the service but was not prescribing for patients.
• Prescribing was monitored to prevent any misuse of the service by patients and to ensure GPs were prescribing appropriately. However, when prescribing was not appropriate there was no evidence that actions were taken to prevent re-occurrence or that learning was disseminated.
• There were no systems in place to mitigate safety risks including analysing and learning from significant events.
• There were no systems in place to ensure that emergency services could be directed to the patient in the event of a medical emergency during consultation.
• There were not appropriate recruitment checks in place for any staff.
• An induction programme was in place for all staff and clinicians contracted by the service had received specific induction. The GP told us they had access to all policies; however some staff were not sure about whether they could access policies on the provider’s system.
• Staff had not received training in all areas needed such as Mental Capacity Act 2005, health and safety and fire training.
• Patients were not always treated in line with best practice guidance.
• Medical records were maintained; however recording was not always adequate.
• There was a basic system in place for checking patient’s identification; however, these checks did not ensure the provider could confirm who the patient was.
• There were limited clinical governance systems and processes in place to ensure the quality of service provision.
• The service encouraged and acted on feedback from both patients and staff.
• The provider was aware of and complied with the requirements of the Duty of Candour.
• There was a clear business strategy and plans in place.
• Systems were in place to protect personal information about patients. Both the company and the GP were registered with the Information Commissioner’s Office.
• Staff we spoke with were aware of the organisational ethos and philosophy and told us they felt well supported and that they could raise any concerns.
• Information about services and how to complain was available. Improvements were made to the quality of care as a result of complaints. However, learning from those complaints were not always shared with staff.

The areas where the provider must make improvements are:

• Ensure there is a system to record, assess and manage significant events/incidents.
• Ensure prescribing decisions are documented and made appropriately, based on a thorough medical history and made in line with evidence based, risk assessed national guidance and best practice.
• Ensure systems are in place to confirm a patient’s identity and that the systems are consistently applied.
• Ensure systems are in place to manage and treat medical conditions appropriately.
• Ensure systems are in place to assist patients in the event of a medical emergency during consultation.
• Ensure consent to care and treatment is sought in line with legislation and guidance and recorded.
• Ensure all staff receive training relating to the Mental Capacity Act 2005, health and safety and fire training.
• Ensure recruitment checks are appropriately carried out and recorded.
• Ensure systems and processes are in place to ensure the effective governance of the service.

The areas where the provider should make improvements are:

• Ensure there are regular team meetings and clinical meetings and minutes from those meetings are appropriately documented.
• Ensure learning from complaints and feedback are shared with all staff.
• Improve accessibility to the service for patients who may find it difficult to use the telephone and for those where English is not their first language.

We are now taking further action against the provider Frosts Pharmacy Ltd in line with our enforcement policy. Since the inspection, the provider has submitted an action plan in response to the issues found on inspection. We will check the effectiveness of these actions when we re-inspect.

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice