High level principles for good practice in remote consultations and prescribing

It sets out the shared high level principles of good practice expected of everyone when consulting and or prescribing remotely from the patient.

The principles are underpinned by existing standards and guidance from professional and system regulators. Healthcare professionals should continue to follow guidance from regulatory bodies and take clinical guidance into account in their decision making.

This information is not clinical guidance or new guidance from regulatory bodies.

These principles have been co-authored and agreed by a range of healthcare regulators and organisations (see Annex A below).

Safeguards for patients accessing healthcare remotely

Remote consultations and prescribing provided online, over video-link or by phone can benefit patients*, save resources and help meet public demand for more convenient access to healthcare.

However, there are potential patient safety risks, particularly where services aren’t linked to a patient’s NHS GP or regular healthcare provider, and where there may be limited access to a patient’s medical records.

Issues include increased attempts to gain access to medicines which can cause serious harm and the need to ensure safe ongoing monitoring of those with long term conditions. Providers of remote services and the healthcare professionals they work with must be aware of these risks and be clear about their responsibilities for protecting patients.

Patients can expect to have effective safeguards in place to protect them when they receive advice and treatment remotely. Safeguards are necessary whether the consultation happens in the context of a continuing treating relationship or is a one-off interaction between a patient and a healthcare professional.

Key principles

We expect UK registered healthcare professionals to follow ten high level key principles when providing remote consultations and prescribing remotely to patients based in the UK or overseas.

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.**
2. Understand how to identify vulnerable patients and take appropriate steps to protect them.
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.
4. Explain that:
   
   a. They can only prescribe if it is safe to do so.
   
   b. 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.
   
   c. It may be unsafe if relevant information is not shared with other healthcare providers involved in their care.
   
   d. If they can’t prescribe because it’s unsafe they will signpost to other appropriate services.
   
   
5. Obtain informed consent and follow relevant mental capacity law and codes of practice.
6. Undertake an adequate clinical assessment and access medical records or verify important information by examination or testing where necessary.
7. Give patients information about all the options available to them, including declining treatment, in a way they can understand.
8. Make appropriate arrangements for after care 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.
9. Keep notes that fully explain and justify the decisions they make.
10.  Stay up to date with relevant training, support and guidance for providing healthcare in a remote context.

Working in safe systems

Responsible employers and providers of remote services will have systems in place to check patients’ identity and identify patterns of behaviour which may indicate serious concerns so that appropriate steps can be taken to protect patients. Particularly vulnerable patients may include those at risk of self-harm, substance or drug use disorders, those with long term conditions, and children attempting to access services intended for adults.

Healthcare professionals who are responsible for leading a team or service offering remote care are expected to make sure that staff are clear about their roles, their personal and collective responsibilities for individual patients, and the quality and safety of care provided by the team or service.

They have a responsibility to contribute to setting up and maintaining effective systems to identify and manage risks, and to act quickly where patients may be at risk of harm.

Recognising the limitations of remote prescribing

It is important for healthcare professionals and employers to consider the limitations of remote services when deciding the scope of practice and range of medicines prescribed.

Some categories of medicines are not suitable to be prescribed remotely unless certain safeguards are in place.

The General Pharmaceutical Council has produced guidance which explains that pharmacies based in England, Scotland and Wales may not supply these categories of medicine without having an assurance that these safeguards are in place.

The Pharmaceutical Society Northern Ireland provides standards and guidance on internet pharmacy services for pharmacies based in Northern Ireland.

Offering remote services to patients overseas

If UK based healthcare professionals are considering working for service providers based in other countries, it’s important to be aware that there may not be established local mechanisms to provide effective systems regulation and this may impact on patient safety.

Before providing remote services to patients overseas the healthcare professional should check if they are required to register with regulatory bodies in the country where they are based, and where the patient is based and where any medicines they prescribe are to be dispensed.

They also need to check they have an arrangement in place to provide indemnity or insurance to cover their practice in all relevant countries.

When prescribing to a patient overseas, UK based healthcare professionals are expected to consider how they or local healthcare professionals will monitor the patient’s condition.

The healthcare professional needs to take account of any legal restrictions on prescribing or the supply of particular medicines, and any differences in a product’s licensing or accepted clinical use in the destination country.

They should follow UK and overseas legal requirements and relevant guidance on import and export for safe delivery, including from the Medicines and Healthcare products Regulatory Agency.

Offering remote services to patients in the EU, Iceland, Liechtenstein, Norway, or Switzerland

Following the UK’s exit from the European Union, UK based healthcare professionals must abide by the individual rules and regulations of the relevant EU Member State. If their patient is based in the EU, Iceland, Liechtenstein, Norway, or Switzerland, they will need to check the national regulations of that country to understand how best to operate. Individual EU states reserve the right to stipulate conditions for non-EU nationals providing services in their countries. For example, by requiring local residency as a condition of providing some types of services. Austria is one country that only permits telehealth services to be provided to patients in Austria if the healthcare professional is resident in Austria.

The HCPC does not maintain a list of countries which have reservations in place which could impact UK based professionals. If a professional wishes to provide services to someone based in the EU, we would strongly urge them to check with the relevant body or to seek independent advice to ensure they are working within that country’s laws.

Further information and guidance

Links to relevant information and guidance published by professional and system regulators, royal colleges and faculties, professional bodies and other stakeholders are provided below.