Regulation of Health and Social Care Professionals Consultation

Provisional Proposal 13-6: The regulators should be given an express power
to approve and accredit overseas education institutions and courses and
issue rules and guidance for the purpose of such activity.
Question 13-7: What are the practical difficulties which arise as a result of the
requirement to quality assure UK qualifications which are awarded by
institutions based overseas?
Distance service provision
13.35 There is an increasing trend towards the remote provision of certain health care
services. 33 An obvious example of this is the internet in the pharmaceutical
context, which allows prescription medicines and other drugs to be ordered online
and delivered directly to individuals’ homes.
13.36 This presents a regulatory challenge, particularly for the General Pharmaceutical
Council and the Pharmaceutical Society of Northern Ireland given the growth of
internet pharmacies. The General Pharmaceutical Council deals with this issue
by operating a scheme which allows approved pharmacies to use a logo to
identify them as registered pharmacies. 34
13.37 However, the problem remains that non-UK based websites may still provide
prescription-only medicines without a prescription, or without checking whether
the medicine is suitable for the person concerned. Although an individual can
raise a concern with the Medicines and Healthcare products Regulatory Agency,
its remit is limited by resources and the difficulties of enforcement outside of the
EU. This is particularly difficult because not all prescription drugs are “controlled
drugs” for the purposes of the Misuse of Drugs Act 1971. Individuals may
personally import non-controlled drugs without a licence. 35
13.38 A further example of distance service provision is the development of telehealth
and telecare. These terms refer to the use of technology to allow health and
social care services to be delivered into patients’ and service users’ homes
without needing a practitioner to be physically present. This can take a variety of
forms. For instance, a patient could take a photo of themselves using a digital
camera and then send the image to a doctor. The doctor could then remotely
diagnose the patient and suggest a treatment. Similarly, devices can be used to
monitor health signs remotely and readings are sent to a practitioner who can
then decide whether to intervene, without the patient needing to attend a clinic.
33 For instance, see Social Care Institute for Excellence, Ethical Issues in the use of Telecare
(2010) p 2 and Parliamentary Office of Science and Technology, Postnote: Changing Role
of Pharmacies (2005).
34
See http://www.pharmacyregulation.org/registration/internet-pharmacy (last visited 15
February 2012).
35 C George, “Internet Pharmacies: Global Threat Requires a Global Approach to Regulation”
Hertfordshire Law Journal 4(1), p 12 to 25.
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