Evidence submitted by Alliance Boots (EPR
27)
INTRODUCTION AND
EXECUTIVE SUMMARY
Alliance Boots is Europe's largest pharmacy-led
health and beauty group, created following the merger in 2006
of Alliance UniChem and Boots Group. We operate 2,300 pharmacies
across the UK, through our Boots The Chemists and Alliance Pharmacy
stores.
We believe pharmacists' access to patient care
records is important for the benefit of patients; to enhance patient
safety; to benefit other health professionals; for pharmacists
to fulfill their responsibilities under the new contract; and
for pharmacists to reach the full potential of their professional
role. This memorandum explains why pharmacists require access
to certain data, how this access will enhance joint working with
GPs and benefit patients, and how we envisage the system will
work, including protection of patient data and secure access.
What patient information will be held on the new
local and national electronic record systems, including whether
patients may prevent their personal data being placed on systems
1. The new NHS community pharmacy contractual
framework is enabling pharmacy to develop beyond its traditional
role of dispensing medicines into a more service-orientated role.
The development of new health services in pharmacies is highly
beneficial for patients and the NHS, and it is clear that pharmacists
require access to sufficient data to enable them to provide a
safe and effective service to the patients under their care.
2. While local computer systems already
provide a full and comprehensive record of the service that an
organisation has provided to the patient, or Patient Medication
Record (PMR), there is most likely to be relevant information
held within other healthcare providers' systems that would be
of benefit in providing effective care to the patient. Conversely,
information about the service that we provide to a patient would
benefit other healthcare providers (eg GP or hospital) and so
should be uploaded onto the summary care record.
3. The record needs to include all information
about medication that has been prescribed and dispensed to a patient
both in primary and secondary care. It should also include details
of any allergies, active clinical conditions and any previous
adverse reaction information. The care record could also include
information regarding the supplies of selected prescription only
and non-prescription lines supplied from a pharmacy, for example
under a Patient Group Direction.
4. Having access to the full patient medication
history would enable pharmacists to perform a full drug interaction
check with all medicines prescribed and dispensed for a patient
and thus improve the overall safety of the patient. If access
to basic clinical condition information were included, this would
further improve safety by allowing the pharmacist to check that
the dosage was appropriate for the condition being treated.
5. A practitioner will not be in a position
to provide treatment to a patient without access to relevant information
but patients should be entitled to prevent their information being
shared with other healthcare providers or restrict it to a limited
number of individuals through use of controlled access rights
and sealed envelopes. If a patient chooses to limit the sharing
of their information, the implications of doing so should be made
clear to them. Likewise, patients should be made aware of their
responsibility to provide any relevant information at the point
of care.
6. Many members of the public already volunteer
personal data, regarding lifestyle, body weight and health-related
purchases, as part of our company initiatives. For example, over
1.5 million people are signed up to the Boots "HealthClub"
and there are 15 million Boots Advantage Card users. High take-up
for initiatives such as these suggests broad public acceptance
of data holding in a patient's own interest.
Who will have access to locally and nationally
held information and under what circumstances?
7. The NHS care record should incorporate
the patient's medical record, accessible to the healthcare provider,
at the point of care and whenever required. Within community pharmacy,
all pharmacists must have access to a core set of clinical information
as detailed above. This must include a full record of the patient's
medication history and any adverse drug reactions, to support
the pharmacist in conducting a Medicines Use Review (MUR). In
addition, certain pharmacists such as independent prescribers
or pharmacists providing a specific service to a patient, such
as Chlamydia screening, should have access to a fuller data set
to include relevant information, for example laboratory test results.
In pharmacies there will be role-related access, so that healthcare
assistants will only be able to access a patient's records if
this is a necessary part of their job.
8. When providing a repeat dispensing service
to a patient, it is the duty of the responsible pharmacist to
ensure that nothing about the patient has changed since the last
time they made a supply. Having access to the care record would
facilitate the pharmacist carrying out this check rather than
relying solely on information provided verbally by the patient.
Whether patient confidentiality can be adequately
protected
9. This information needs to be stored and
accessed securely to protect the confidentiality of the patient.
Pharmacy contractors and pharmacy systems are already subject
to the controls of the Data Protection Act. Existing security
measures (physical and technical) ensure the security of any patient
information held locally on these systems.
10. Pharmacists already have NHS Smartcards
and PIN numbers to enable them to access the Electronic Prescription
Service (EPS). These same Smartcards can be used to enable access
to the NHS care record and provide a full audit trail of who is
accessing and updating confidential patient information.
11. Should a patient not want their information
shared, he or she must have the ability to limit who sees what
information or to authorize the user to view the information during
a face to face consultation for that one time only.
How data held on the new systems can and should
be used for purposes other than the delivery of care eg clinical
research
12. Unable to comment on this.
Current progress on the development of the NHS
Care Records Service and the National Data Spine and why delivery
of the new systems is up to two years behind schedule
13. Unable to comment on this.
Alliance Boots
March 2007
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