Archived: e-med Private Medical Services

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.