Dispensing overseas prescriptions
The Royal Pharmaceutical Society’s fitness to practise and legal
affairs directorate has received calls from pharmacists who have been
approached by American or Canadian counterparts to dispense prescriptions
written by doctors registered in the US. Pharmacists are reminded that
such prescriptions are not valid in the UK and any supplies of prescription-only
medicines to patients against prescriptions signed by US registered doctors
would be unlawful.
Even if such prescriptions were to be signed by UK registered doctors,
pharmacists should note that guidance from the General Medical Council
states that doctors must prescribe drugs or treatment (including repeat
prescriptions) only where they have adequate knowledge of a patient’s
health and medical needs. Given this, the prescriber would need to be
consulted to ascertain his or her reasons for prescribing for a patient
abroad. Pharmacists would need to be satisfied of the professional appropriateness
of dispensing such a prescription, if the doctor has not performed a
clinical assessment of the patient or has adequate knowledge of their
medical history.
Should a pharmacist supply against a valid prescription for a patient
abroad, consideration would need to be given to ensuring that the patient
receives his or her medication safely and promptly and is adequately
counselled on its appropriate use.
Service Specification 8 of the Code of Ethics must be complied with whenever
dispensed medicines are not to be handed directly to the patient or the
patient’s representative. Pharmacists are advised to consult the
Medicines and Healthcare products Regulatory Agency in relation to export
requirements, and patients should contact the embassy of the country
into which the medicines are to be sent for any import requirements.
Consideration should also be given to labelling and packaging requirements.
Information may be obtained from carriers experienced in the export of
medicines and from HM Customs and Excise.
Persons lawfully conducting a retail pharmacy business may undertake
wholesaling activity without the need for a wholesale dealer’s
licence, provided that the sale constitutes no more than an inconsiderable
part of the business. Although this has not been subject to judicial
interpretation, it is believed that a pharmacy will fall within this
exemption if its wholesaling activity accounts for no more than 5 per
cent of its total medicines trade.
Assuming that the appropriate enquiries have been made of the MHRA with
respect to wholesale dealer’s licence requirements, pharmacists
can export to hospitals, clinics, other wholesale businesses, doctors
resident abroad (provided that the doctor supplies his patients and does
not order the medicines for his own use) and pharmacies (provided that
the medicines are then supplied to a patient).
The fitness to practise and legal affairs directorate has produced a
fact sheet giving guidance on exporting medicines. “The export
of medicines” (Fact Sheet 4) can be accessed on the Society’s
website (PDF 110K). |
The
Pharmaceutical Journal