Advice line dilemma - Internet consulting

A young GP was approached by an online pharmacy asking him to provide a remote consulting and prescribing service to its patients. He was told that many of the patients required treatment for erectile dysfunction and cosmetic imperfections.

The GP phoned the MDU to seek advice about the medico-legal implications of remote consulting and prescribing.

Our advice

In 2013, the GMC published updated guidance on prescribing. The guidance states that "You should prescribe medicines only if you have adequate knowledge of the patient's health and you are satisfied that they serve the patient's needs".

Some medications must not be prescribed remotely without examination. The guidance states that "you must undertake a physical examination of patients before prescribing non-surgical cosmetic medicinal products such as injectable cosmetic medicines and must not therefore prescribe these by telephone, video-link, or online".

For other prescriptions, doctors prescribing remotely must consider:

  1. the limitations of the medium through which you are communicating with the patient
  2. the need for physical examination or other assessments
  3. whether you have access to the patient's medical records.

Communication with patients is key because, in order to comply with GMC guidance, prescribing doctors should have sufficient information about each patient's history including:

  1. any previous adverse reactions to medicines
  2. recent use of other medicines, including non-prescription and herbal medicines, illegal drugs and medicines purchased online
  3. other medical conditions.

Doctors should fully explain to patients the likely benefits and side-effects of the medicines, what to do if things go wrong, and what monitoring or adjustments are likely to be necessary.

Communication with the patient's own GP is also important. If a patient has not been referred by their GP, the doctor should consider whether they have sufficient reliable information to prescribe safely, and should ask for the patient's consent to contact their GP if more information, or confirmation, is needed. If the patient objects, the doctor should explain that the prescription cannot be provided, and explain the options.

Unless the patient objects, the doctor must also keep the GP informed about any new medicines, or changes to existing medications, with information about the proposed duration of treatment, any monitoring requirements, and any new allergies or adverse reactions identified.

Finally, doctors prescribing online should take care to avoid prescribing via websites that breach advertising regulations and should be aware that some of their patients might be making contact from overseas. If so, doctors may need to consider whether there are implications for import/export requirements, whether the doctor needs registration in the country where the medicines are to be dispensed and additional indemnity requirements.

If doctors cannot satisfy these conditions they should not use remote means to prescribe for a patient.

On reflection of the advice given, the doctor felt that it might be difficult to provide a safe remote consulting and prescribing service for these conditions. He was disappointed, but thanked the MDU adviser for the chance to talk through his concerns.

Doctors who wish to prescribe online and/or provide advice over the internet should contact our membership team on 0800 716 376 to keep us up to date. Lines are open 8am to 6pm Monday to Friday, except bank holidays.

Learning points

  • Some conditions are unsuitable for remote consultations because of the inability to conduct a physical examination, to monitor treatment and to provide appropriate aftercare.
  • Doctors have an ethical and legal duty to ensure that personal data and communication systems are secure and protected from unauthorised access.
  • Doctors must ensure that patients understand the limitations of online consultations and give informed consent.
  • Doctors should only prescribe if they have enough information about the patient, and sufficient dialogue with the patient, to do so safely.
  • Doctors should only prescribe remotely if they can fulfil all the requirements of the GMC guidance.
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This page was correct at publication on . Any guidance is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.


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