Archived: Escripts Marketing

Updated 8 November 2017

Escripts Marketing provides an internet based healthcare service direct to patients in the form of online health consultations with a medical practitioner; health advice and the issuing of private prescriptions sent direct to a pharmacy for dispensing and supply of medicines. They also provide an internet based travel clinic prescribing service for patients and a professional support service for pharmacists registered with the service. This service provides prescriptions for vaccines and travel related medicines.

Escripts Marketing does not have clinic premises where patients can visit. The healthcare service is provided via the internet only from several websites: www.pharmadoctor.co.uk, www.uniclinix.com and www.etraveltool.com and is administered from office premises located at Grand Union Studios 1.21, 332 Ladbroke Grove, London W10 5AD.

Operational activities were managed and undertaken by the three directors and one additional administration staff member. The provider also employed one prescribing doctor who provided prescriptions for all websites and prescribing, clinical advice and support for the on-line travel service. Eight additional clinical staff were employed for the online ETool travel service including two doctors, one pharmacist and five nurses.

On the day of the inspection the service prescribed medicines for the treatment of impotence, hair loss, weight loss, influenza, smoking cessation, raised cholesterol, travel health vaccinations, travellers' diarrhoea, jetlag, malaria, premature ejaculation, acne and eczema, asthma, diabetes, hay fever, hypertension, period delay, unwanted facial hair and contraception. However, following the inspection we were informed by the provider that medicines would no longer be prescribed for the long-term conditions of hypertension, diabetes and asthma.

All treatments provided via the Pharmadoctor website are for patients over 18 years old only. Prescriptions provided via the travel services websites are for children and adults from the ages of 6 to 74 years.

All prescriptions are sent to a General Pharmaceutical Council registered pharmacy for dispensing and supply of medicines. Travel vaccine and anti-malarial prescriptions are administered from named pharmacies in England registered with the Escripts Marketing ETool travel service.

The customer support service was available 9.30am to 5.30pm Monday to Thursday and 9am to 5pm on Friday. During this time patients could contact the service by telephone, email or the online ‘live chat’ facility.

One of the directors was the Registered Manager for the service. A Registered Manager is a person who is registered with the Care Quality Commission to manage the service. Like registered providers, they are ‘registered persons’. Registered persons have a legal responsibility for meeting the requirements of the Health and Social Care Act 2008 and associated Regulations.

How we inspected this service

We carried out an announced comprehensive inspection of Escripts Marketing on 16 May 2017 at their operating site at Grand Union Studios 1.21, 332 Ladbroke Grove, London W10 5AD. Our inspection team was led by a CQC lead inspector accompanied by a second inspector, two GP Specialist Advisers and a member of the CQC medicines team.

Before visiting, we reviewed a range of information we hold about the service and pre-inspection information provided by Escripts Marketing Limited.

During our visit we:

• Spoke with a range of staff including the company directors, patient services manager and prescribing doctor.
• Reviewed organisational documents, such as policies and procedures and other documentation which the provider held in relation to the provision of services.
• Reviewed staff records.
• Reviewed a sample of patient consultation 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?

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

Why we inspected this service

We carried out this inspection under Section 60 of the Health and Social Care Act 2008 as part of our regulatory functions to check whether the service was meeting the legal requirements and regulations associated with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

Updated 8 November 2017

Letter from the Chief Inspector of General Practice

We carried out an announced comprehensive inspection at Escripts Marketing on 16 May 2017.

Escripts Marketing provides online medical services from several websites:

• www.pharmadoctor.co.uk - provides consultation and prescribing services direct to patients for several treatment areas
• www.uniclinix.com and www.etraveltool.com – provides on-line travel health and vaccination consultation and prescribing services to patients and signposting to pharmacies who are able to administer the vaccines. This service uses the ETool system developed by the provider.

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

Our key findings were:

• Information about services, including a number of FAQs (Frequently Asked Questions) was available on the website but there was no information on the prescribing doctor.
• The provider did not always provide adequate information to patients regarding the medicines they were prescribed.
• The service offered patients the option of sharing information about their treatment with the patient’s own GP; however, there was no encouragement to do so, or risk assessment in place to decide when this should be required.

• 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 actioned appropriately.
• The provider did not have systems in place to ensure clinical staff had access to relevant and current evidence based guidance and standards, such as National Institute for Health and Care Excellence (NICE) best practice guidelines and did not monitor that these guidelines were followed. We saw evidence of prescribing that was not in line with current guidelines.

• The provider did not have adequate staff management procedures in place to ensure the checking and retention of records to confirm that clinical staff had the appropriate recruitment checks, training, qualifications, professional registration, appraisal and indemnity cover to carry out their role.

• Clinical staff did not take part in the induction and annual appraisal programme.
• Staff working remotely, including the prescribing doctor, did not have access to policies and procedures although copies of specific documents would be emailed to staff if requested.
• The service did not have a clinical quality improvement programme in place. There were no clinical governance systems or processes to ensure the quality of clinical service provision.
• The service had systems in place to keep people safeguarded from abuse.
• There was a clear business strategy and business plans in place.
• 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.
• The service encouraged and acted on feedback from both patients and staff.
• There were systems in place to protect personal information about patients. The company was registered with the Information Commissioner’s Office.
• There was a system in place to check the identity of patients. However, there were limited checks in place to ensure patients under the age of 18 were not accessing services covertly.
• There were systems to mitigate safety risks arising from incidents and complaints, including analysis and learning. Improvements were made as a result of complaints.
• The service learned from and made necessary improvements when things went wrong. The provider was aware of and complied with the requirements of the Duty of Candour.

We identified regulations that were not being met:

The provider must ensure care and treatment are provided in a safe way:

• The provider must ensure consultation questionnaires capture the information required to make accurate prescribing decisions prior to prescriptions being issued.
• The provider must ensure information given to patients about the medicines they are prescribed is sufficient.
• The provider must ensure that there is an effective process in place for identifying and verifying patient identification.
• The provider must ensure they have effective systems in place to confirm patient safety alerts, such as those provided by the Medicines and Healthcare Products Regulatory Agency (MHRA), are actioned appropriately.
• The provider must ensure they encourage patients to give their consent to share prescribing information with their registered GP or risk assess the medicines prescribed to decide when this should be required in accordance with General Medical Council guidance.

The provider must ensure effective governance, including assurance and auditing systems and processes:

• The provider must ensure they have effective clinical quality improvement systems and processes established to enable them to assess, monitor and improve the quality and safety of the services provided.
• The provider must ensure that policies and procedures are easily accessible for staff working remotely.
• The provider must ensure they have an effective system in place to ensure treatment is monitored and delivered in line with relevant and current evidence based guidance and standards such as those produced by the National Institute for Health and Care Excellence (NICE) and the General Medical Council (GMC).
• The provider must ensure that staff management procedures include the checking and retention of records to confirm that clinical staff have the appropriate recruitment checks, training, qualifications, professional registration, appraisal and indemnity cover to carry out their role.

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

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice