Evidence submitted by the Royal Pharmaceutical
Society of Great Britain (EPR 56)
1. INTRODUCTION
AND SUMMARY
— 27% of medication errors are caused
by poor information availability, costing the NHS £500 million
per year.
— Pharmacists should have appropriate
role based access to any electronic patient records.
— The modernisation agenda of the NHS
is threatened without appropriate access.
— The pharmacy profession has received
no firm assurances that it will have access to the electronic
records.
1.1 The Royal Pharmaceutical Society of
Great Britain (RPSGB) is the professional and regulatory body
for pharmacists in England, Scotland and Wales. It also regulates
pharmacy technicians on a voluntary basis. The primary objectives
of the Society are to lead, regulate, develop and represent the
profession of pharmacy. The Society leads and supports the development
of the profession within the context of the public benefit.
1.2 Pharmacists are the healthcare experts
in medicines and spend four years in University before undertaking
a years pre-registration training. Community pharmacies are located
in the communities in which people live and work, and are the
most easily accessible part of the NHS.
2. INFORMATION
THAT SHOULD
BE HELD
ON THE
RECORD
2.1 A prescription is an almost universal
intervention for patients with Long Term Conditions, and is a
factor in the management of most acute episodes. In most cases
the only accurate description of what has actually been dispensed
to a patient comes from pharmacy computer systems. We would expect
this information to be part of future electronic record systems.
2.2 When considering patients preventing
personal data being placed on systems it is important to consider
the potential consequences of this data not being available. For
example, clinicians may not be aware of drug allergies, duplications
in treatment or previous dose adjustments which could have serious
patient safety implications.
3. PHARMACY ACCESS
TO THE
RECORD
3.1 The RPSGB believes that pharmacists
should have appropriate role-based access to any electronic patient
record. The information they would have access to would be a pre-determined
data set and only information that was required to carry out their
role with regard to the individual patient. This might include
medication, clinical conditions, allergies, laboratory results
and previous adverse reactions.
Effective Treatment
3.2 Currently, pharmacists in community
pharmacy only have access to the information included on the prescription
they dispense and any previous prescription that they have dispensed
for the same patient. If the patient obtains some of their prescriptions
from other pharmacies or from secondary care, the pharmacist may
not have a full picture of all the medicines being prescribed
for the patient. They will also have little information about
the conditions being treated. This makes it difficult to assess
the appropriateness of the medicines prescribed or whether they
may interact with other medicines that the patient is taking.
In turn, it is difficult to advise fully the patient about their
medicines without an understanding of what diagnoses have been
made.
Patient Safety
3.3 The NHS Connecting for Health NHS Care
Records service website[60]
quotes the following figures:
— The root cause of 27% of medication
errors is poor information ability.
— 1,200 people die each year in England
and Wales as a result of medication errors, costing the NHS £500
million a year.
3.4 Other research[61]
shows that 6.5% of admissions to hospital are related to an adverse
drug reaction at an estimated cost of £466 million per year.
Pharmacists have the skill and knowledge to be able to detect
and prevent many of these safety issues, but do not have access
to sufficient patient information to be able use systematically
their knowledge and skills to reduce the number of errors, adverse
drug reactions and admissions to hospital.
3.5 Access to the record would support pharmacists
in helping the Government meet its target of reducing by 40% the
number of serious errors in the use of prescribed drugs as well
as helping reduce the human and financial cost of prescribing
errors.
Modernisation of the NHS
3.6 The Government has been pursuing an
agenda of modernising the role of Health Professionals. Pharmacy
has been at the core of this. New legislation now allows pharmacists
to prescribe independently of GPs. The government has launched
its "Pharmacists with a Special Interest" framework
to allow pharmacists to provide a more specialist service to patients
and to improve access and convenience to patients.
3.7 The new primary care contractual frameworks
allow pharmacy to play a more central role in patient care, with
more scope for making clinical interventions and integration with
the primary health care team. As part of these new arrangement,
community pharmacists undertake Medicines Use Reviews, conduct
public health campaigns and advise patients on self care and the
treatment of minor ailments. Many pharmacists are also involved
in providing other locally commissioned services to meet the needs
of patients in their locality, for example diagnostic testing,
substance misuse, sexual heath and services to care homes.
3.8 Appropriate role-based access to electronic
records could also support the seamless transfer of care between
primary and secondary care, and improved multidisciplinary working
for example with GPs.
3.9 All of these new services have been
designed to fully utilise the pharmacists expertise in medicines
and integrate this into the NHS. These new pharmacy roles are
already improving patient access to services, helping to reduce
waiting times, reducing admissions and increasing capacity in
primary and secondary care and delivering value for money. However,
future success is dependant on appropriate access to electronic
records. Without it, the benefits of all of these recent changes
may never be fully realised.
Pharmacy Access
3.10 To-date there have been no firm assurances
that community pharmacy will have access to the care record database
or to the other IT developments other than those required to operate
the electronic prescription service.
3.11 Access from pharmacy is also supported
by the consumer group "Which?" who have stated "consumers
want and expect continuity of care and all healthcare professionals
(including pharmacists) involved in their care to have access
to their medical record. Without this, how can care be patient
centred?" Access was also supported by MP panel members at
the October 2006 meeting of the All Party Parliamentary Group
on Patient Safety.
4. CONFIDENTIALITY
4.1 Pharmacists are bound by a professional
"code of ethics" produced by the RPSGB. Breaches in
this code can lead to removal from the register, meaning that
person can no longer practice as a pharmacist.
4.2 Pharmacists have operated patient medication
records for a number of years and already have robust systems
in place for handling patient confidential information, and in
addition to the above ethical requirements are subject to a wide
range of legal, ethical and professional requirements.
4.3 Pharmacy contractors are required to
comply with the legal obligations of the Data Protection Act 1998
and the common law duty of confidence and under the NHS community
pharmacy contract, pharmacy contractors and their employees must
conform with the NHS code of practice on confidentiality. The
clinical governance framework ensure compliance by including policies
for ensuring staff are appropriately trained and that all staff
contracts include clauses on patient confidentiality.
4.4 The RPSGB welcomes the additional safeguards
being introduced, including the use of "smartcards"
to control access. It is important that these safeguards, however,
do not impinge on patient safety by unduly restricting access
at the same time respecting an individuals right to confidentiality.
5. PROGRESS OF
CONNECTING FOR
HEALTH
5.1 The RPSGB feels that the CfH programme
would benefit from greater clinical engagement, and welcomes the
recent changes to its structure that are being made to address
this. There are still concerns, however, over the level of engagement
with the pharmacy profession and its involvement with this and
other aspects of the programme.
5.2 Overall the RPSGB is supportive of the
Connecting for Health programme and the progress it is making.
The Royal Pharmaceutical Society of Great Britain
16 March 2007
60 http://www.connectingforhealth.nhs.uk/delivery/programmes/nhscrs
(accessed 15 March 2007). Back
61
Pirmohamed M et al Adverse drug reactions as cuase of admission
to hospital: prospective analysis of 18,820 patients. BMJ 2004;
329: 15-19. Back
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