For those who have not heard of CQC inspections, they were introduced in 2009 with a clear mandate to visit all manner of NHS-based services. They provide third-party assessment of the facilities and are responsible for assessing the care they provide to their patients. These results are then listed publicly, and any remedial steps are developed and monitored to ensure the highest standard of practices across the health industry.
Unfortunately, this move has understandably created a variety of new concerns within a healthcare network which is already stretched to full capacity. In addition, the CQC Inspections, and the rules they enforce, apply to such broad range of places that meeting the full scope of requirements can be a really demanding exercise.
To combat this, we thought we would provide some core information to ensure some key elements of the inspections are properly managed, specifically those elements which involve the security of prescription paper.
The following guidelines come from official CQC guidance sources, broken up to specifically cover the areas which concern the need for robust locks. There is a link to the full guide at the end of this article.
Controlled Drug Governance Arrangements
GP practices should have systems in place to ensure the safe management of controlled drugs. The following points will help practices ensure they pass CQC Inspections, by ensuring they can demonstrate that they have systems in place to minimise risk when managing CDs:
- Each practice should have clear, written standard operating procedures (SOPs) covering all aspects of CD management that are known, understood and followed by all relevant staff.
- The SOPs should cover the ordering, storing, administering, recording, and destruction of CDs
- Staff should be trained to ensure they have the relevant knowledge and skills to undertake the CD related tasks required of them
- Staff should know what to do and who to contact if they have a concern about an incident or the performance or practice of other healthcare professionals / staff
- Staff should know how to contact the Area Team controlled drugs accountable officer (CDAO).
Prescription stationery for CDs, including printer paper, must be stored securely to prevent theft and misuse to fraudulently obtain controlled drugs. This is a set requirement of CQC Inspections.
What’s the problem?
The problems associated with traditional pre-printed prescription pads are well known. A prescription form can be seen as a “blank cheque” and in the wrong hands misuse can lead to loss of valuable NHS resources and potentially result in serious harm. Forms can be used to illegally obtain controlled drugs (CDs), as well as other medicines, either for illegitimate personal use or to sell on.
Cases of fraud or theft using these forms are not always complex or on a large scale; forms can be stolen from the prescriber’s bag, car, home or desk.
In the past, blank computer prescription paper has been seen as a lower risk. However, we are now starting to hear of an increasing number of instances where blank computer- generated prescription forms are used fraudulently. The theft often only becomes apparent when fraudulent prescriptions are presented at pharmacies and work is carried out to identify how and from where they have been stolen.
Methods used to obtain the blank computer prescription forms have included tactics based on distracting busy staff with what appear to be genuine patient requests. The offender gains access to, or is left in, a consulting room and steals blank prescription paper from an unattended computer. The offender then scans a genuine prescription and prints out copies on the stolen forms. These can be very difficult to detect.
A Pragmatic Approach to CQC Inspections
GPs (including locums), other prescribers in the practice and all staff involved in the management of prescription forms need to be able to tell us how the practice manages and secures blank prescription forms and paper. This includes being able to prove that the paper has been stored securely.
For CQC Inspections, we would expect that:
- Clear and unambiguous records are maintained of prescription stationery stock received.
- Prescription form stock is checked on delivery and then securely stored as soon as possible. As a minimum this should be in a locked cabinet within a lockable room or area. Access to forms should be restricted to authorised individuals.
- A record is kept of the distribution of pre-printed prescription form stock within the practice including the serial numbers, where, when (date/time) and to whom the prescriptions have been distributed.
- For prescribers using individualised forms, there is a clear system for where forms are stored (not with patients’ notes, and in a locked space) and a record is made at the end of each session (serial number of first remaining form).
- Measures are in place to maintain the security of forms used in printers when the printer is left unattended such as overnight or when the surgery/consulting room is not in use. The simplest solution is that rooms are locked when unoccupied. Alternatives include using a lockable printer cover, storing a printer in a lockable drawer or storing forms in a lockable drawer and only placing them in a printer when needed.
- Regular stock checks on prescription forms are undertaken and where possible there is a separation of duties between ordering, receiving and stock checking the prescription forms.
- There is a system in place that addresses how prescription forms will be stored when the prescriber sees patients outside of the practice premises.
- Staff know what to do if they suspect that prescription forms/paper have gone missing.
Security of Blank Computer Prescription Forms
Blank computer prescription forms were originally considered to be of a low security risk but there are now an increasing number of instances when theft and computer software has been used to generate fraudulent prescriptions.
NHS Protect has published guidance to help develop local systems to ensure the security of prescription forms against theft and misuse. These systems need to be designed with the needs of local staff and their working environment in mind. The guidance supports providers, both NHS and private, authorised by their commissioner to order prescriptions.
Organisations holding stocks of prescription forms are responsible for their management and use by:
- Preventing theft and misuse through secure storage
- Developing an organisational policy outlining roles and responsibilities
- Developing local protocols outlining what actions to take in the case of loss, theft or missing prescription forms/paper
- Controlling and recording prescription form movement, including recording serial numbers.
CQC Inspections ensure there are measures to prevent and tackle the problem of prescription form theft and misuse and outlines the recommended actions when an incident occurs. It is intended for the following roles in all settings:
- Prescribers of medicines (including contractors and locum staff)
- Independent prescribers
- Supplementary prescribers
- Dispensing staff
- Staff who manage and administer prescription form stock
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