Archived: Anytime Medical Limited

Letter from the Chief Inspector of General Practice

We carried out an announced comprehensive inspection at Anytime Medical Limited on 25 April 2017.

Anytime Medical Limited operates under the trading name of Anytime Doctor which provides on-line medical services from one website: www.anytimedoctor.co.uk. The website offers prescribing services for several treatment areas and testing kits for sexually transmitted diseases.

The inspection was carried out through discussion with the provider only as no staff were employed by the company at that time. The sole clinical member of staff employed had decided to stop working for the service the day prior to our inspection. This meant the provider was not actively operating on the day of our inspection.

We found this service was providing caring and responsive services in accordance with the relevant regulations. However, improvements were required in relation to providing safe, effective and well led care and treatment.

Our key findings across all the areas we inspected were:

• There was a system in place to check the patient’s identity but this did not include photographic identity checks.
• There were systems in place to mitigate safety risks arising from incidents and complaints, including analysis and learning.
• A safeguarding policy was available but there was no appropriately trained safeguarding lead identified.
• The recruitment procedure included appropriate recruitment checks for clinical staff employed by the service. However, from the records we viewed of previously contracted staff we saw insufficient evidence that checks had been undertaken to ensure they had adequate training and qualifications to carry out their role or that that they had received appropriate appraisal for their on-line prescribing activities.
• There was insufficient monitoring of prescribing to prevent patients accessing inappropriate or unsafe treatment or to ensure clinicians were prescribing appropriately.
• There were some systems to ensure staff had the information they needed to deliver safe care and treatment to patients. However, these systems did not ensure actions were identified, implemented and recorded following best practice updates such as those provided by the National Institute for Health and Care Excellence (NICE) and safety alerts such as those provided by the Medicines and Healthcare Products Regulatory Agency (MHRA).
• The service learned and made improvements when things went wrong. The provider was aware of and complied with the requirements of the Duty of Candour.
• Patients were not always prescribed treatment in line with best practice guidance. We saw evidence of prescribing for asthma which was not in line with current guidelines.
• Medical records we reviewed were maintained to an appropriate standard.
• The service did not have a programme of ongoing quality improvement activity embedded in their clinical governance system.
• The provider had an induction procedure in place to be carried out prior to the doctor treating patients.
• The provider informed us that staff had access to all policies.
• The service offered the option of sharing information about their treatment with the patient’s own GP but the provider had not made this a mandatory requirement even when treating long-term conditions which required monitoring. However, the provider took appropriate action to address this following the inspection.
• Survey information we reviewed showed that patients were satisfied with the service they received.
• Information about how to complain was available and improvements were made to the service as a result of complaints.
• There was a clear business strategy and plans in place.
• There were insufficient 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.
• Systems were in place to protect personal information about patients. The company was registered with the Information Commissioner’s Office.

We identified regulations that were not being met and the provider must make appropriate improvements:

Care and treatment was not being provided in a safe way for service users.

• The provider did not have an effective procedure to ensure safety alerts, such as those provided by the Medicines and Healthcare Products Regulatory Agency (MHRA), were reviewed by a clinician; acted on if necessary and records kept of actions taken.

• The provider did not have a safeguarding lead in place with appropriate training.

Systems and processes were not established and operated effectively to ensure compliance.

• The provider did not have an effective clinical quality improvement programme in place which included clinical audit and monitoring of prescribing against current prescribing guidance and evidence based practice.
• The provider had not ensured that staff management procedures included confirmation that clinical staff had adequate training and qualifications to carry out their role and that appropriate appraisal of their on-line prescribing activities had been undertaken.

The areas where the provider should make improvements are:

• The provider should ensure there are arrangements in place to retain and access medical records for the required period of time following the cessation of trading.
• The provider should consider implementing contingency plans to cover the absence of the Registered Manager or prescribing doctor.
• The provider should consider implementing a follow-up procedure when informing patients of positive results following Sexually Transmitted Disease testing to ensure results are accessed by patients.

You can see full details of the regulations not being met at the end of this report.

Summary of any enforcement action already taken

Following our inspection on 25 April 2017. We identified significant risks related to a breach of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 12 (1) Safe care and treatment. We therefore took urgent enforcement action to impose conditions under s31 of Health and Social Care Act. The urgent condition was to ensure that any service user seeking medical attention from Anytime Medical for long term conditions such as asthma, diabetes or hypertension must do so with the express permission to divulge this information to the service users’ GP. Where providers are not meeting required standards, we have a range of enforcement powers we can use to protect the health, safety and welfare of people who use services. When we took this action, our decision was subject to an appeal by the provider.

Anytime Medical confirmed they had implemented the condition to make the service safe. The CQC will follow this up with another inspection to ensure we are satisfied that the provider has taken the necessary action to mitigate CQC’s concerns.

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice