Archived: FMC Marketing Limited - Grand Union Studios

Updated 20 July 2017

FMC Marketing Ltd was established in 2003 to provide an online clinic, consultation, treatment and prescribing service for a limited number of medical conditions to patients from England, Italy, France and Germany. The number of conditions treated had recently been reduced to three; weight loss, hair loss and erectile dysfunction.

FMC Marketing Ltd consists of five members of staff which includes the registered manager, commercial/patient services manager, technical services manager, patient services lead and a doctor. The doctor was not a GP but was registered with the General Medical Council (GMC) and contracted via an external provider to undertake remote patient consultations by reviewing patient requests and completed medical questionnaires when patients apply for medicines on-line.

The service’s call centre is open between 9.30am and 5.30pm on a Monday to Thursday and from 9am to 5pm on a Friday. However, patients are able to submit a request for treatment 24 hours a day, seven days a week on the providers website. Requests for treatment received up to 3pm on a weekday were generally dealt with within a three hour timescale. Other requests were dealt with the following working day.

This is not an emergency service. Subscribers to the service pay for their medicines when their on-line application has been assessed and approved. Once approved by the prescriber, prescriptions are issued to one of the two pharmacies used by the provider who are contracted to dispense, pack and post (via registered mail) the prescribed course of treatment.

FMC Marketing Ltd is operated via three separate websites (www.firstmed.co.uk, www.prima-med.com and wwww.myonlinedoctor.co.uk.

FMC Marketing Ltd registered with the CQC at their current location in July 2016. 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.

We carried out an announced inspection of this location on 19 April 2017. We visited FMC Marketing Limited’s operating site in Ladbroke Grove, London and spoke to their doctor and managers. We looked at the records, policies and other documentation the provider maintained in relation to the provision of services. We also spoke to pharmacists employed by the two pharmacies used by the provider to fill and deliver the prescriptions issued.

To get to the heart of people’s experiences of care, we always ask the following five questions of every service and provider:

• Is it safe?
• Is it effective?
• Is it caring?
• Is it responsive to people’s needs?
• Is it well-led?

Our inspection team was led by a CQC Lead Inspector. The team also included two GP specialist advisers, a second CQC inspector and a pharmacist specialist.

We inspected this service as part of our comprehensive inspection programme. We carried out a comprehensive inspection of this service under Section 60 of the Health and Social Care Act 2008 as part of our regulatory functions. The inspection was planned to check whether the provider is meeting the legal requirements and regulations associated with the Health and Social Care Act 2008, to look at the overall quality of the service.

Updated 20 July 2017

Letter from the Chief Inspector of General Practice

We carried out an announced comprehensive inspection at FMC Marketing Ltd on 19 April 2017.

FMC Marketing Ltd provides an online clinic, consultation, treatment and prescribing service for a limited number of medical conditions to patients from England, Italy, France and Germany.

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

Our key findings were:

• The service had systems to keep service users safeguarded from abuse.
• Appropriate systems were in place to record and learn from significant and clinical events.
• There were some systems in place to protect patients personal information and the provider was registered with the Information Commissioners Office.
• The service encouraged and acted on feedback from patients.
• The service managed patients’ applications for medicines in a timely way.
• Information about services and how to complain was available on the providers websites.
• The provider was aware of the requirements of the duty of candour.

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

• Add the name, GMC number and brief description of their doctor to their websites to enable potential patients to make an informed choice.
• Ensure medical questionnaires are updated to capture all potentially relevant information and reflect current best practice guidance.
• Ensure there is a formal process or policy in place governing the identification or classification of risk when assessing medical questionnaires.
• Introduce a programme of clinical audit and quality improvement activity.
• Ensure doctors employed by the service are appropriately appraised for their work with FMC Marketing Ltd.
• Ensure that there is an effective process in place for identifying and verifying patient identification.
• Ensure that doctors employed by the service have the skills, training, experience and medical indemnity required to enable them to carry out the role of online doctor.
• Continue with the introduction of a process to review and monitor prescribing and consultations.
• Ensure there is more clinical involvement and oversight in the day to day operation and running of the service.

The areas where the provider should make improvements are:

• Update the medical emergency protocol to ensure a patients location as well as home address are known prior to consultation.
• Record a patients own GP details before consultation and treatment is approved.
• Take steps to ensure patient confidentiality is comprehensively protected when patient data is being accessed by the doctor and in the event that the company should cease trading.

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