Archived: e-med Private Medical Services

Updated 2 June 2017

E-Med Private Medical Services Ltd was established in March 2000 and registered with the Care Quality Commission in October 2012. E-Med operates an online clinic for patients via a website ( www.e-med.co.uk ), providing consultations, private healthcare referrals and prescriptions. The service, for consultations, is open between 9am and 5pm on weekdays and available to UK and European residents. E-Med has approximately 1800 members and provides 50-60 consultations on average per week. This is not an emergency service.

Patients are required to join E-Med as a member to access the service and there is an annual membership fee of £20. For each consultation there is a charge of £15 which includes issuing the prescription and if patients are not satisfied with the service they are refunded the consultation.  For each consultation the patient completes a free-text questionnaire for the symptoms or condition they believe they have and the prescription or private healthcare referral is issued or declined by the doctor as appropriate. The doctor requests further information from the patient via email, telephone or Skype where necessary. If the doctor decides not to prescribe a requested medicine, the patient is sent an email stating the order will not be fulfilled and a refund is processed. Once approved by the doctor, the patient can take their prescription to a pharmacy of their choice with the exception of low dose naltrexone  (a medicine generally used to treat the symptoms of multiple sclerosis) which are dispensed, packed and posted by a pharmacy located in Glasgow; and delivered by a third party courier service.

The provider employs two doctors on the GMC GP register to work remotely in undertaking patient consultations based on the information submitted by patients through the website questionnaires. The provider also employs an IT consultant on an ad-hoc basis as required. A registered manager is 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).

How we carried out this inspection

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.

We conducted our inspection on 31 January 2017 and visited the location of the service. We met with the Director and the Service Manager, who is also the Registered Manager and a registered nurse, and spoke with the principal doctor via telephone. We reviewed provider documentation including policies, staff personnel files and patient records.

Our inspection team was led by a CQC Lead Inspector. The team included two GP specialist advisers, a second CQC inspector, and a member of the CQC medicines team.

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?

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

Updated 2 June 2017

Letter from the Chief Inspector of General Practice

We carried out an announced comprehensive inspection at E-Med Private Medical Services Ltd on 31 January 2017.  E-Med Private Medical Services Ltd was established in March 2000 and registered with the Care Quality Commission in October 2012. E-Med operates an online clinic for patients via a website ( www.e-med.co.uk ), providing consultations, private healthcare referrals and prescriptions.

We found this service was not proving safe, effective and well led services in accordance with the relevant regulations but was providing a caring and responsive service.

Our key findings were:  

• There was a system in place for recording, reporting and learning from significant events.
• There were systems in place to protect patient information and ensure records were stored securely however, not all patient information gathered as part of patient consultations had been stored with or attached to, the patient record. The service was registered with the Information Commissioner’s Office.
• The provider could not evidence all staff had received safeguarding training appropriate for their role.
•   The service managed patients’ applications for medicines in a  timely way.
• T he provider was aware of and complied with the requirements of the Duty of Candour and encouraged a culture of openness and honesty.
• Staff did not have a comprehensive understanding of how to seek patients’ consent to care and treatment in line with legislation and guidance.       
• Knowledge of and reference to national clinical guidelines were inconsistent.
• There was no evidence that audit was driving improvement in patient outcomes.
• The provider offered nurse consultations to anyone accessing the website, free of charge. 
• We did not speak to patients directly as part of the inspection but online patient feedback available showed that patients were positive about the service.
• The service offered flexible telephone or video appointments between 9am and 5pm weekdays to meet the needs of their patients.
• There was no clear clinical leadership in place. The practice did not hold clinical meetings to discuss clinical issues and ensure clinicians were kept up to date.      

The areas where the provider must make improvements are:

• Take action to ensure off-label medicines (medicines being prescribed for unlicensed indications) are not prescribed without assessing the legal implications and risk in doing so including adverse reactions, product quality and the ‘Patient Information Leaflet’ associated with this medicine.
• Take action to ensure off-label medicines are not prescribed without gaining informed consent from the patient.
• Take action to ensure medicines are not prescribed without ascertaining if the patient is pregnant; breast feeding or planning to start a family.
• Ensure adequate patient identification checks are carried out to ensure individual identity but also to reduce the risk of under 18s accessing the service.
• Develop an effective system to keep staff up to date with national guidance such as safety alerts and National Institute for Health and Care Excellence (NICE) guidance. 
• Ensure there is a  programme for quality improvement such as clinical audit to monitor and improve the service provided to patients. 
• Ensure there is a full record of the consultation on the patient record and confidentiality of patient information is maintained by employees working remotely.  
• Ensure there is a process in place to manage any emerging medical issues during a consultation

The areas where the provider should make improvements are:

• Formalise staff meetings to ensure all staff are updated with service developments regularly.        
• The provider should take due account of national  guidance such as NICE & GMC guidelines and ensure  clinicians  deliver care and treatment in accordance with them.    

Summary of any enforcement action

The provider has been issued a Notice of Proposal to impose conditions on their registration in relation to Regulation 17, Good Governance.