Archived: e-med Private Medical Services Ltd

Updated 26 November 2019

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 and prescriptions for Low Dose Naltrexone (LDN) medicine.

At the time of our inspection the service only offered the prescribing of Low Dose Naltrexone (LDN) to patients. (LDN, is an opiate antagonist. This is sometimes prescribed for patients with long-term conditions such as multiple sclerosis. It has been described as helping to improve some symptoms for these patients). They provided regular treatment to 116 patients members and all staff carried out all consultations by telephone or e-mail.

The service is open between 9am and 5pm on weekdays and available to UK and European residents for phone or e mail consultations. 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 given a refund. For each consultation the patient completes a free-text questionnaire for the symptoms or condition they believe they have, and the prescription is issued or declined by the doctor as appropriate.

The IT system in place enables doctors to request further information from patients via email, or telephone. 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, patients are requested to indicate a pharmacy of their choice for their LDN prescription to be sent to. Patients were also able to request a paper prescription to be posted to them to be dispensed at a pharmacy of their choice. However, as LDN is an off-label medicine (a medicine licensed for a different indication to that for which it is prescribed in this case), it is not readily stocked by all pharmacies and therefore the service recommended patients use an affiliated pharmacy which is also recommended by the LDN Trust.

The provider employed a registered manager and one female doctor on the GMC register to work remotely in undertaking patient consultations based on the information submitted by patients through website questionnaires. 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). An IT consultant was employed on an ad-hoc basis as required.

How we inspected this service

Before the inspection we gathered and reviewed information from the provider. During this inspection we spoke to the members of the management and clinical team. To get to the heart of patients’ experiences of care and treatment, we 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. 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 and as part our programme to rate independent digital services.

Updated 26 November 2019

Letter from the Chief Inspector of General Practice

At our previous inspection on 5, 6 March 2018, we found, in addition to providing a service for patients through the provider website, www.e-med.co.uk; the provider was also providing consultations, private healthcare referrals and prescriptions for five external companies; ‘Health Express Healthcare’; ‘Menscare UK Ltd’; ‘Pharmacy Direct GB’; ‘Healthwise’; and ‘Uk-med’. On 8 March 2018 the provider was issued an urgent Notice of Decision under Section 31 of the Health and Social Care Act 2008, to impose conditions on their registration as a service provider as we found the provider was not providing a safe, effective, caring, responsive and well led service for patients.

We imposed the following urgent conditions on the registration of e-med Private Medical Services Ltd:

• The registered provider must not provide online doctor consultations or prescribe any medicine or medicinal product that contains a medicine, for service users for any companies or websites other than www.e-med.co.uk.
• The registered provider must not prescribe to any service user any medicine, or medicinal product that contains a medicine, other than Naltrexone.

We carried out an announced comprehensive inspection at e-med Private Medical Services Ltd on 1 November 2018 to follow up on breaches of regulations. Where we found the provider was following the urgent conditions. We found the provider was providing a safe, effective, caring, responsive and well-led service in accordance with the relevant regulations.

We carried out an announced comprehensive inspection at e-med Private Medical Services Ltd as part of our programme to rate independent digital services on the 23 September 2019.

At the time of our inspection the service only offered the prescribing of Low Dose Naltrexone (LDN) to patients. (LDN, which is used as a regulator of the immune system, providing relief to patients with autoimmune diseases, and central nervous system disorders). The service provided regular treatment to approximately 116 patients.

This report outlines our findings in relation to the service with the above two urgent conditions imposed:

The overall rating for the service is Requires Improvement

The key questions are rated as:

Are services safe? – Requires improvement

Are services effective? – Requires improvement

Are services caring? – Good

Are services responsive? – Good

Are services well-led? – Requires improvement

At this inspection we found:

• The service did not always provide patients with information that was appropriate for their condition or easily understood when they prescribed medicines.
• The staff had not completed training to ensure they were competent for their role. The service did not have a failsafe system in place regarding the co-ordination with the patient’s GP.
• The provider did not ensure patient and public had up to date information to help them make an informed decision about their care.
• The provider did not have systems in place to ensure the policies and procedures were updated in response to changes. The providers website did not accurately reflect the services provided.
• Suitable numbers of staff were employed and appropriately recruited.
• Quality improvement activity, including clinical audit, took place.

The areas where the provider must make improvements as they are in breach of regulations are:

• Establish effective systems and processes to ensure good governance in accordance with the fundamental standards of care.

(Please see the specific details on action required at the end of this report).

Dr Rosie Benneyworth BM BS BMedSci MRCGP

Chief Inspector of Primary Medical Services and Integrated Care