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Inspection carried out on 10 October 2017

During an inspection to make sure that the improvements required had been made

Letter from the Chief Inspector of General Practice

We undertook an announced comprehensive inspection of MSF Medical Services on 8 May 2017 under Section 60 of the Health and Social Care Act 2008 as part of our regulatory functions. Breaches of Regulation 12 (Safe care and treatment) of the Health & Social Care Act 2008 were found. The full comprehensive report following the inspection on 8 May 2017 can be found by selecting the ‘all reports’ link for MSF Medical Services on our website at www.cqc.org.uk.

This inspection was a follow up desk based focused inspection of MSF Medical Services carried out on 10 October 2017 to confirm that the service had implemented their plan to meet the legal requirements in relation to the breaches in regulations that we identified in our previous inspection. This report covers our findings in relation to those requirements.

The service is now providing safe, effective and well led care in accordance with the relevant regulations.

Our key findings were:

  • Following the previous inspection, the service had introduced quality assurance processes to ensure that medicines were prescribed in line with national guidance and internal policy.

  • The service had reviewed their system for the storage of patient safety and medicine alerts and made changes to ensure that they maintained a clear audit trail.

  • The service had re-assessed the risks associated with the medicines they had available to prescribe, and had made changes to mitigate the risks identified to ensure that they were prescribing safely.
  • The service had put processes in place to flag when staff training and registrations were due for renewal.
  • The service had introduced a programme of team meetings which were attended by all GPs.
  • The service had revised the contract of employment for all of their GPs to include the requirement that GPs should provide evidence that they have discussed their role in online prescribing with their appraiser as part of their NHS appraisal.
  • The provider had considered the risks associated with patients being able to revise the answers given in the prescribing questionnaire, and as a result they had amended their system to alert GPs where this had happened.

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice

Inspection carried out on 8 May 2017

During a routine inspection

Letter from the Chief Inspector of General Practice

We carried out an announced comprehensive inspection at MSF Medical Services on 8 May 2017.

MSF Medical Services provides prescribing services to two online pharmacies (Assured Pharmacy and Mens Pharmacy). The service is run by a GP (who is the registered manager) who provides the prescribing service along with two additional GPs who are contracted by MSF and work remotely. GPs from MSF have access to the online systems for both the online pharmacies they prescribe from, and can view patient records from previous contact with the service when considering prescription requests.

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

Our key findings were:

  • The service had clear systems to keep people safe and safeguarded from abuse.
  • There was an adequate system in place to check the patient’s identity.
  • There were systems in place to mitigate safety risks, including analysing and learning from significant events and safeguarding.
  • There were appropriate recruitment checks in place for all staff.
  • Prescribing was monitored to prevent any misuse of the service by patients; however, there was no process in place to quality assure GPs’ prescribing decisions.
  • There were systems to ensure staff had the information they needed to deliver safe care and treatment to patients.
  • 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 treated in line with best practice guidance and appropriate medical records were maintained.
  • The service had a programme of ongoing quality improvement activity.
  • An induction programme was in place for all staff, and GPs registered with the service received specific induction training prior to treating patients. Staff, including GPs who worked remotely, also had access to all policies.
  • Details of the patient’s registered GP were not routinely collected when the patient registered with the service, and prescriptions were issued without information being shared. Following the inspection the service had conducted risk assessments for each of the medicines they had available in order to identify those where they considered the risk was such that they could only prescribe safely if the patient’s registered GP was notified; however, this assessment did not go far enough in identify medicines which carried significant risk.
  • Patient feedback we viewed was generally positive about the quality of the service they received, and we saw evidence that any negative feedback received was followed up, and where necessary, used to improve the service.
  • Information about services and how to complain was available. Improvements were made to the quality of care as a result of complaints.
  • There was a clear business strategy and 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.
  • There were 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 service was registered with the Information Commissioner’s Office.

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

  • Introduce quality assurance processes to ensure that medicines are prescribed in line with national guidance and internal policy.
  • Ensure that there is an effective system in place for the management of patient safety and medicine alerts, which includes a clear audit trail.

The areas where the provider should make improvements are:

  • The provider should re-assess the risks associated with the medicines they have available to ensure that they are prescribing these safely.
  • The provider should put processes in place to flag when staff training and registrations were due for renewal.
  • The provider should consider providing opportunities for GPs to meet as a team (either in person or virtually).
  • The provider should review their staffing procedures to formalise the expectation that GPs include their role with the service as part of their NHS appraisal.
  • The provider should consider the risks associated with patients being able to revise the answers given in the prescribing questionnaire.

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

Summary of any enforcement action

We are now taking further action in relation to this provider and will report on this when it is completed.

Professor Steve Field CBE FRCP FFPH FRCGP

Chief Inspector of General Practice