- Start:Nov 26, 2019
- End:Feb 18, 2020
- Results planned
for publication:Dec 31, 2020
- Reference number:66
About this call for evidence
We’re asking organisations and individuals with relevant expertise to share their experiences, views, data and insights about remote consultations and prescribing via telephone, video-link or online.
We will use the submissions we receive together with other information we hold, to decide if we need to make any changes to our guidance for UK doctors, Good practice in prescribing and managing medicines and devices (February 2013). If so, this evidence will help us decide if we need to run a public consultation on a revised draft and help us shape the consultation document and methods.
The call for evidence will run from 26 November 2019 until 18 February 2020.
Our role is to protect patients and improve medical education and practice across the UK. We do this by working with doctors, employers, educators and patients to achieve high standards of care. We:
- decide which doctors are qualified to work in the UK
- oversee UK medical education and training
- set the standards doctors need to follow throughout their careers
- where necessary, take action to prevent a doctor from putting patients’ safety, or the public’s confidence in doctors, at risk.
Our professional guidance applies to all doctors registered with us, whatever their grade, specialty or UK location, so it is necessarily high level. It’s important that it represents common ground between the profession, the public and service providers, which is established through an extensive review process that can include public consultation. It must also reflect how individual patients, carers and members of the public experience healthcare - particularly those with unequal access to care or with significant needs, such as patients with impaired capacity.
You can access our guidance and see how it applies in practice on the ethical hub pages of our website.
We expanded our guidance Good practice in prescribing and managing medicines and devices in 2013 to give advice on remote consultations and prescribing. This was in response to changes in the way health services are delivered. Below is a summary of our current guidance on this area of medicine.
Good practice in remote prescribing
Our guidance advises doctors to treat patients remotely only where it is safe to do. If they do not have enough information about the patient’s health to prescribe safely or the medium is inappropriate to meet the patient’s needs, they should explain that they cannot prescribe and offer the patient alternative options.
When making a judgement on whether it is safe to prescribe remotely, doctors should consider the need for a physical examination and access to medical records before proceeding.
Doctors are responsible for the prescriptions they sign, and the mode of consultation should not compromise safe practice. In our guidance we say that doctors must:
- only prescribe drugs when they have adequate knowledge of their patient’s health and are satisfied that the drugs serve their patient’s needs
- satisfy themselves that they can make an adequate assessment, establish a dialogue and obtain the patient’s consent
- check that the care or treatment they give to each patient is compatible with any other treatments the patient is receiving
- take an adequate history, including any previous adverse reactions to medicines, recent use of other medicines, and other medical conditions
- contribute to the safe transfer of patients between healthcare providers and between health and social care providers
- tell the patient’s general practitioner about changes to medicines, intended length of treatment, monitoring requirements and any new allergies or adverse reactions, unless the patient objects or privacy concerns override this duty.
If a patient has not been referred by a GP, the doctor should consider whether the information they have is detailed and reliable enough to allow them to prescribe safely. If before prescribing they need more information, or confirmation of information, they should ask for the patient’s consent to contact their GP. If the patient objects, and the doctor considers that the information is necessary to prescribe safely, the doctor should explain that they cannot prescribe and outline other options for the patient.
What has changed?
We believe that if doctors follow our guidance, patient safety is not compromised by the remote provision of healthcare. But, since we last updated our guidance in 2013, there has been a significant expansion in the provision of remote prescribing in the NHS and independent sector, and we want to make sure our guidance is keeping up with the fast pace of change.
In the last six years, the number of online providers registered in UK has increased from 14 to 46 and doctors are estimated to deliver thousands of remote consultations to patients based in the UK every week. The Royal College of Physicians also recently recommended that doctors should do more video and telephone consultations to manage increased demand for appointments. Innovative new service models have also developed, which aim to improve access to healthcare for patients in some areas of medicine, for example, there is a growing market for online providers of sexual health advice.
This trend looks set to continue as the NHS Long Term Plan is committed to supporting mainstream roll out of digitally-enabled care in England over the next 10 years. Use of technology is also a priority for the Scottish Parliament, as outlined in Scotland's Digital Health & Care Strategy. In Wales, A Healthier Wales - our Plan for Health and Social Care explores investment in digital technology. And, in Northern Ireland, in Health and Wellbeing 2026 - Delivering Together, the Department of Health commits to making better use of technology and data.
Changes to the GP contract made this year also include a commitment to support existing practices deliver digital first primary care. And, the independent Topol Review into preparing the healthcare workforce to deliver the digital future was published in February 2019. Its key recommendations highlighted the importance of a fit-for-purpose ethical governance framework that is trusted by the public, patients and staff.
Working with others
The issues involved in setting standards for and regulating doctors who give health advice through remote consultations are complex. Some UK-registered doctors may work for providers who are based in other countries or work for UK-based providers who deliver care to patients who live overseas. Patients in the UK may also choose to access care remotely from doctors who are based in other countries and may not be on the UK medical register, and who therefore fall outside our regulatory scope.
As the regulatory body for doctors in the UK, our guidance is only effective in encouraging good practice among doctors who are on the UK medical register - it cannot mitigate risks to patient safety posed by other doctors. Nor does our guidance apply to other healthcare professionals with prescribing responsibilities in the UK.
That is why we are working in partnership with key partners to support a cross-regulatory approach. Recently, we published shared high-level principles for all healthcare professionals who undertake remote consultations and prescribe remotely in the UK. These principles were co-authored and endorsed by the UK professional and system regulatory bodies and other key stakeholders, and they align with our existing collective guidance.
We are also working with stakeholders to share intelligence where there are concerns about individual prescribers and providers of remote healthcare services. This helps to support relevant bodies to take action to protect patients worldwide.
You can access the English and Welsh PDF versions of this Call for Evidence by clicking on the button below.
Gallwch droi at y fersiynau PDF Cymraeg a Saesneg o'r Alwad hon am Dystiolaeth trwy glicio ar y botwm isod.
What we need from you
We want to hear from organisations and individuals with knowledge and expertise in this area. Relevant evidence may include your views, experiences, data and insight on the issues outlined in this document and anything else you think could impact on doctors’ responsibilities in remote and online environments.
This will help us understand the different perspectives of those involved in this area of practice, such as professional and system regulators, those who provide online or other remote healthcare services, medical representative bodies, medical royal colleges, research bodies, patient safety organisations and patient and public representative groups.
How do I respond?
Please send us your response to this call for evidence by 18 February 2020.
You can respond by:
If you’d like this call for evidence document in Welsh, easy read, or another format or language, please call us on 0161 923 6602 or email us at firstname.lastname@example.org.
What this call for evidence does not cover
We won’t necessarily be able to act on all the information we receive, but we will listen carefully to what you have to say.
As part of this work, we will not consider concerns or complaints about individual doctors. If you are concerned about a doctor’s remote or online practice, please visit our website at www.gmc-uk.org/concerns or phone our contact centre on 0161 923 6602 to raise this with us.