The legal framework for PGDs does not state the patient 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 patient. In both scenarios a telephone or other remote consultation with the patient should be sought. Where it is not possible to speak with the patient directly (i.e. where it concerns a young child or where an adult lacks capacity) then assessment should include discussion with a parent/relative/carer where appropriate.
The process that the practitioner follows in such circumstances would need to ensure that an adequate assessment can still be conducted, in line with the requirements for PGDs.
The act of making a supply to the patient’s representative or posting a medication supplied under a PGD to a patient does not constitute delegation. The health professional supplying the medicine must undertake the whole episode of care under the PGD. This includes the handing over of the medicine to the patient’s representative or personally undertaking the packaging and posting/dispatch of the medicine – this responsibility cannot be delegated (see Q&A on PGDs and delegation).
Where remote consultation is undertaken and supply is made without the patient being present organisations are encouraged to have relevant governance and operating procedures for such practice in place.
APRIL 2020 update – we have confirmed the following with the CQC and MHRA which may assist organisations during the current COVID-19 pandemic
Where it is not appropriate or timely to post the medicine to the patient/client (e.g a sexual health client may not wish to have medicines posted to their home as this could mean that confidentiality is not maintained) the healthcare professional who undertakes the consultation and then prepares the medicines for dispatch (i.e packages them) under the PGD, can then allow another healthcare professional to identify the patient or their representative and hand over the package. This may be necessary because the individual who undertook the telephone consultation may not be available to physically issue the medication to the patient/client when they collect it. A representative of the patient/client may collect the medication on behalf of the patient/client as they may be ill themselves/self-isolating. It is recommended that organisations support such activity with a short SOP.