Interim guidance for pharmacist supervision and private consultation areas
The Royal Pharmaceutical Society has received a number of queries asking
whether dispensed prescriptions can be supplied and pharmacy medicines
sold while the pharmacist is undertaking a private consultation with
a patient on the pharmacy premises (for example, when a pharmacist is
conducting a medicine use review in a private consultation area).
The Medicines Act 1968 requires that pharmacy and prescription only medicines
be sold or supplied by a pharmacist or by someone acting under the supervision
of a pharmacist. Supervision is not defined in the Act, but is currently
interpreted to mean that the pharmacist must be aware of the transaction
and in a position to intervene. Since the introduction of the sale of
medicines protocols, in the mid-1990s, a pharmacist has not needed to
be personally involved in every pharmacy medicine sale, provided sales
are carried out by suitably trained and competent members of staff acting
in accordance with agreed protocols.
Pharmacists who are involved in a consultation with a patient in a private
area or room in the registered pharmacy premises are unlikely to be aware
of the content of the medicine sales taking place or know which dispensed
prescriptions are being supplied. However, in taking into consideration
current legal and professional requirements for the sale and supply of
pharmacy and prescription only medicines and being mindful of the potential
changes to the existing supervision requirements of the Medicines Act,
the Society has issued the following interim guidance.
Interim guidance If a pharmacist is involved in a consultation with
a patient in a private area or room of a registered pharmacy premises,
pharmacy medicines may be sold and dispensed prescriptions that have
been checked for clinical appropriateness and accuracy may be supplied,
provided that robust standard operating procedures (SOPs) are in place.
The pharmacist will still have professional responsibility for any sales
or supplies of medicines that take place while they are involved in the
consultation and it is essential that the SOPs clearly identify when
a pharmacist’s intervention in such medicine sales or supplies
is required and that systems provide for this intervention. All members
of staff need to be aware of the circumstances where pharmacy medicine
sales or dispensed medicine supplies cannot proceed without further intervention
from the pharmacist, and patients should be advised accordingly. Pharmacy
staff who are given delegated authority to sell pharmacy medicines and
supply dispensed prescriptions must have undertaken an accredited training
course relevant to their duties and the pharmacist must be satisfied
that the staff are competent to perform the tasks delegated to them.
Clinical governance arrangements must ensure appropriate audit and risk
assessments are conducted and that adherence to SOPs is regularly monitored
and reviewed.
Pharmacists are required to make a professional assessment of every prescription
to determine its suitability for the patient. If this assessment has
not been performed, prescribed medicines cannot be supplied. Pharmacists
must also ensure that patients receive sufficient information and advice
(from either a pharmacist or an appropriately trained member of staff)
to enable the safe and effective use of the medicines that are sold or
supplied.
Pharmacy owners and superintendent pharmacists will wish to reassure
themselves that the pharmacist in personal control of the pharmacy only
allows delegation of tasks when it is safe to do so. This may be covered
in company procedures. However, a pharmacist in personal control should
decide whether he or she is personally satisfied that the systems in
place, and the level of trained pharmacy staff present on any particular
day, are sufficient to ensure that patient safety will not be compromised.
If the pharmacist cannot be satisfied that appropriate systems are in
place, sales of pharmacy medicines and supplies of dispensed prescriptions
should not proceed when the pharmacist is involved in a private consultation
with a patient. It should also be noted that if a pharmacist has to leave
the registered pharmacy premises to conduct a patient consultation (or
for any other reason) the current personal control requirements of the
Medicines Act will not be met and no sale or supply of medicines, including
general sale list medicines, should take place.
Next steps This interim guidance will be reviewed in light of any changes
to the current requirements of Medicines Act legislation.
Back to Top
|
Guidance on reporting sexual activity in children under 13 years
The Society is aware that some area child protection committees in
England are beginning to develop, or already have in place, local protocols
for managing sexual abuse and sexual activity in children and young
people. A number of these protocols require that all cases where a
child under 13 years is believed to be, or to have been, engaging in
sexual activity should be reported to social services and the police.
These protocols have implications for all sexual health services, including
the supply of emergency hormonal contraception and contraceptives,
and the provision of sexual health advice by pharmacists and their
staff.
Where there is evidence or reason to believe that a child may be being
abused, it is essential that prompt action is taken and that concerns
are discussed with the appropriate agencies or individuals. However,
the Society is concerned that protocols automatically requiring health
professionals to share information about sexual activity in children,
without allowing the professional to assess the facts of each case, will
not take account of a child’s right to confidential advice and
may deter children from seeking support and advice about sexual health
matters.
The Department for Education and Skills is currently considering national
guidance on the sharing of information about underage sexual activity
in England. In the interim, the Society advises that pharmacists need
to be vigilant to signs of sexual abuse, especially in younger children,
and that prompt action must be taken if there is evidence or reason to
believe that a child may be being sexually abused. However, although
pharmacists should be aware of and give consideration to local protocols
for managing sexual abuse and sexual activity in children and young people,
the Society advises that pharmacists should use their professional discretion
to determine, on a case-by-case basis, whether to disclose information
about a sexually active child to social services and/or the police. If
it is decided that referral may be warranted, the child’s consent
should be sought to disclose confidential information whenever possible.
However, a breach of confidentiality could be justified where there is
an overriding need to safeguard the child’s welfare. Appropriate
records should be kept of any action taken, including a decision not
to refer.
Further guidance on what pharmacists should do if abuse is suspected,
and on confidentiality and information-sharing, can be found in the Society’s
guidance
on child protection.
The Society will issue more detailed guidance on managing sexual abuse
and sexual activity
in children and young people once national government guidelines are
published. |
The
Pharmaceutical Journal