Thirteen of the UK’s healthcare regulators have today published ethical guidance for healthcare professionals offering remote consultations and remote prescribing.
Termed to be ‘high level principles for good practice in remote consultations and prescribing’ the guidance is aimed at all healthcare professionals who provide care in any form remotely, particularly those that exercise prescribing responsibilities in this way.
A UK-wide cross regulatory forum was established in February 2017 that aims to take a coordinated approach, address regulatory gaps, and help improve the quality and safety of services delivered online. The guidelines published today aim to address just that by focussing and reiterating principles that should already be second nature to healthcare professionals, placing the emphasis on remote care.
There has been a rise in providing consultations and prescriptions over the telephone, through online platforms and even by video-links. These new means of consultation can provide benefits to patients who may be less able to leave the home, consider symptoms not serious enough to attend in person, or want an initial or more immediate response as to whether they should seek face to face care. The use of remote services can also ease pressure on already stretched resources and help individuals access healthcare more readily than they have done previously.
On the other hand, remote practice may also be cause for some concern. There is a clear limit to the nature of what information is available and what a healthcare practitioner can assess during the consultation that takes place electronically. There is also the question of patient safety linked to continuity of care, as many of the remote healthcare providers may not have direct access to a patient’s medical records, nor will they have direct access to a patients GP or regular healthcare providers. It is difficult to see how the records can be amalgamated quickly and securely, especially for patients that may be vulnerable, have ongoing monitoring or continued care.
The introduction of the principles aim to address the concerns had with remote healthcare head on. The principles attempt to highlight current safe practice, and provide safeguards to protect both the healthcare professionals and the patients who use the services.
The GMC’s publication clearly outlines that they expect all UK registered healthcare professionals to follow ten high level key principles when providing remote consultations or prescribing remotely. This includes any remote advice given overseas.
The principles were co-authored and agreed jointly by thirteen bodies across the whole of the UK including the CQC, various Regulatory Bodies, Royal colleges and faculties.
The principles are as follows:
Principle 1: Make patient safety the first priority and raise concerns if the service or system they are working in does not have adequate patient safeguards including appropriate identity and verification checks
Principle 2: Understand how to identify vulnerable patients and take appropriate steps to protect them.
Principle 3: Tell patients their name, role and (if online) professional registration details. Establish a dialogue and make sure the patient understands how the remote consultation is going to work.
Principle 4: Explain that:
They can only prescribe if it is safe to do so.
It’s not safe if they don’t have sufficient information about the patient’s health or if remote care is unsuitable to meet their needs.
It may be unsafe if relevant information is not shared with other healthcare providers involved in their care.
If they can’t prescribe because it’s unsafe they will signpost to other appropriate services.
Principle 5: Obtain informed consent and follow relevant mental capacity law and codes of practice.
Principle 6: Undertake an adequate clinical assessment and access medical records or verify important information by examination or testing where necessary.
Principle 7: Give patients information about all the options available to them, including declining treatment, in a way they can understand.
Principle 8: Make appropriate arrangements for after are and, unless the patient objects, share all relevant information with colleagues and other health and social care providers involved in their care to support ongoing monitoring and treatment.
Principle 9: Keep notes that fully explain and justify the decisions they make.
Principle 10: Stay up to date with relevant training, support and guidance for providing healthcare in a remote context.
Safe remote practice
The principles shouldn’t be entirely new to any practicing healthcare professional. They are underpinned and have been devised from existing guidance that all healthcare professionals should already be aware of, whether practicing remotely or not.
The principles act as a reminder of the care required to be taken and importance of clear communication, when assessing and prescribing medications to patients remotely, particularly where a patients’ previous records cannot be reviewed or, for example, where high risk medicines may be being prescribed. Healthcare professionals must be astute to the limitations of offering remote services and alive the problems this can cause when communicating with the patient.
Those offering remote services (both practitioners and employers) should have robust systems in place to ensure they can verify the identity of patients as far as possible and have the ability to identify any concerning patterns of behaviour. Employers should ensure systems are in place and steps are taken to protect patients when they are accessing remote services. For example, this could include vulnerable patients, those at risk of self-ham, substance or drug use disorders, or children accessing the services intended for adults.
Employers, those responsible for leading teams, and/or individuals offering remote care are expected to understand their role, their duties and ensure safe systems are maintained and effective.
Whilst remote consultations do have their place, they are not always an appropriate alternative to seeing a professional face to face. Practitioners must be aware of their limitations and act accordingly.
Some categories of medicines are not suitable to be prescribed remotely unless certain safeguards are in place. Healthcare professionals should consult their prescribing guidance in relation to categories of medicine they should not supply without assurance that safeguards are in place.
Practitioners offering remote practice should ensure they are correctly registered with all necessary bodies, and have the appropriate indemnity or insurance to cover their practice.
Authored by Holly Paterson, Solicitor