Background

The legal framework for PGDs does not state that an individual must be present for a supply of a medicine to be made. Therefore remote consultation prior to making a supply under a PGD is permissible and a supply can also be made in the absence of the individual themselves. As with all consultations the healthcare professional undertaking a remote consultation must ensure that the principles of shared decision making are upheld.

Remote consultations under a PGD – clinical assessment

A remote consultation may be undertaken by telephone, video appointment or via an online assessment.

In all scenarios a direct remote consultation with the individual should be sought.  Where it is not possible for the individual to carry out the remote consultation directly (i.e. where it concerns a young child or where an adult lacks capacity) then the assessment should include a consultation with a parent/relative/carer where appropriate.

Online screening questionnaires, completed by the individual, are used by some organisations to assess the individual’s suitability for a particular intervention (e.g. oral contraception).  A PGD can be used to make a supply following the screening of an online assessment by a healthcare professional listed within the PGD legislation.

The process that a healthcare professional follows in any of the above circumstances would need to ensure that an adequate assessment can still be conducted, in line with the requirements for PGDs, to the same standard as a face to face consultation.  No part of the clinical assessment process, or the decision on suitability for a medicine to be supplied, can be delegated to or undertaken by another person.

Organisations must also consider how informed consent during remote consultations is obtained and documented and reflect this in local policies as required.

Remote consultations under a PGD – making a supply

Following a remote consultation a medicine may be collected by an individual/their representative or it may be posted/couriered to them.

The health professional supplying the medicine under a PGD must undertake the whole episode of care. This includes:

• the handing over of the medicine to the individual/their representative;
• personally undertaking the packaging and posting/dispatch of the medicine;
• personally undertaking the packaging of the medicine if to be collected at a later time. Where it is not possible for the healthcare professional who undertakes the remote consultation to physically be present to hand the medicine over to an individual/their representative/an arranged courier they must personally prepare the medicines for dispatch under the PGD (i.e. package the medicine in a sealed packaging showing only the required identifiable information such as name, DoB, delivery address); another healthcare professional can then identify the individual/their representative/arranged courier when they present to collect the medication and hand over the sealed package. Where this process is in place it is recommended that organisations have local operating procedures/governance processes in place and all persons involved are appropriately trained and assessed as competent to undertake the required tasks.

Useful Links

NHS England – Shared Decision Making 

CPPE Shared Decision Making

NICE guidance – Shared Decision Making 

CPPE Remote Consultation Skills

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