PFD report

Deborah Michelle HEADSPEATH · Prevention of Future Deaths report

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Issued 18 Nov 2019•Suffolk

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

View original report
Concerns
4

Raised in this report

Recipients
1

Named on the report

Responses found
1

Of 1 recipient

Stated actions
6

Described in responses

Recipients and published responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised4

  1. Lack of mandatory online-prescription guidance and effective sanctions for non-adherence
    Part of recurring concern: Unreliable pharmacy clinical guidance and procedures
  2. Failure to regulate online suppliers of prescription-only medication
    Part of recurring concern: Inadequate controls on access to prescription-only medicines outside regulated prescribingPart of recurring concern: Medication quantity controls failing to prevent unsafe access to excessive amounts
  3. Lack of a comprehensive database of patients’ prescription-only medication
    Part of recurring concern: Unreliable access to patients’ medication histories
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.2

  1. Action

    Work with regulators to identify options for addressing online providers’ attempts to circumvent regulatory scrutiny.

    Stated by Department of Health and Social CareStated in progressThe respondent said that this action was in progress when they made their response on 27 December 2019.
  2. Action

    Work with regulators to improve oversight of online prescribers and address legislative regulatory gaps.

    Stated by Department of Health and Social CareStated in progressThe respondent said that this action was in progress when they made their response on 27 December 2019.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.1

  1. Position

    Oversight of online providers outside CQC regulation may fall to the General Pharmaceutical Council or Medicines and Healthcare products Regulatory Agency.

    Stated by Department of Health and Social CareRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of mandatory online-prescription guidance and effective sanctions for non-adherence

Wider context from the report

“3. New guidance from the General Pharmaceutical Council was issued in April 2019 and this includes specific advice regarding on-line prescriptions. This is clearly welcome, however some witnesses highlighted that the guidance is advisory and not mandatory. As such there was some uncertainty as to what sanctions would be available against any supplying pharmacist who chose not to adhere to the new guidance? ”

Is this part of a recurring concern?

Yes — Unreliable pharmacy clinical guidance and procedures.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to regulate online suppliers of prescription-only medication

Wider context from the report

“2. Evidence was heard from both the CQC and CQC registered on-line pharmacists of the changes that have been made to the way in which the prescription of opiate based medication (including codeine) is now conducted. CQC registered pharmacies should now not supply opiate based medications unless the patient provides permission for them to contact their registered GP. However, those suppliers who do not want to adhere to this requirement are simply changing their business model (primarily by only using prescribing doctors based overseas) and are relinquishing their CQC Regulated status. These prescribers are therefore still able to provide on-line prescription services (including opiate based medication) in the UK but now fall outside the CQC regulation regime. Clearly this is an area of concern as it will continue to allow patients to access uncoordinated quantities of prescription only medication from unregulated on-line suppliers. ”

Is this part of a recurring concern?

Yes — Inadequate controls on access to prescription-only medicines outside regulated prescribing; Medication quantity controls failing to prevent unsafe access to excessive amounts.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of a comprehensive database of patients’ prescription-only medication

Wider context from the report

“1. There is no single database that allows a prescribing clinician to identify what prescription only medication has already been prescribed to any particular patient. Because there is no central record, in order for the prescribing clinician to identify previous/current prescriptions, they need to personally contact every other prescribing clinician or clinicians. Before being able to do this they would need to obtain the patients express permission. The evidence heard clearly demonstrated that this system was totally ineffective in Debbie’s case, especially so in relation to the supplies of prescription only medication from on-line. It was identified that in relation to the prescription of opiate based drugs on-line that the NHS Business Authority already collates that data for NHS prescribers. However, this information is currently used for statistical purposes only and does not include any prescriptions from third party providers. ”

Is this part of a recurring concern?

Yes — Unreliable access to patients’ medication histories.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to prevent uncoordinated quantities of prescription-only medication from online suppliers

Wider context from the report

“2. Evidence was heard from both the CQC and CQC registered on-line pharmacists of the changes that have been made to the way in which the prescription of opiate based medication (including codeine) is now conducted. CQC registered pharmacies should now not supply opiate based medications unless the patient provides permission for them to contact their registered GP. However, those suppliers who do not want to adhere to this requirement are simply changing their business model (primarily by only using prescribing doctors based overseas) and are relinquishing their CQC Regulated status. These prescribers are therefore still able to provide on-line prescription services (including opiate based medication) in the UK but now fall outside the CQC regulation regime. Clearly this is an area of concern as it will continue to allow patients to access uncoordinated quantities of prescription only medication from unregulated on-line suppliers. ”

Is this part of a recurring concern?

Yes — Inadequate controls on access to prescription-only medicines outside regulated prescribing; Medication quantity controls failing to prevent unsafe access to excessive amounts.

Open source report

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Work with regulators to identify options for addressing online providers’ attempts to circumvent regulatory scrutiny.

Verbatim wording from the response

“In relation to your concern that online providers are changing their business model to circumvent regulatory scrutiny, the Department is working with the CQC and other regulators to understand what the options might be to address this.”

Source location

2019-0387-Response-from-The-Department-of-Health-and-Social-Care
Page 3 · response
Published 27 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Work with regulators to improve oversight of online prescribers and address legislative regulatory gaps.

Verbatim wording from the response

“The Department is working closely with the Care Quality Commission (CQC) and relevant professional regulators to look at how they can better regulate online prescribers and close the loopholes in legislation that allow a small number of online organisations to operate without the necessary oversight.”

Source location

2019-0387-Response-from-The-Department-of-Health-and-Social-Care
Page 1 · response
Published 27 December 2019

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Oversight of online providers outside CQC regulation may fall to the General Pharmaceutical Council or Medicines and Healthcare products Regulatory Agency.

Verbatim wording from the response

“Where a provider is outside the scope of CQC regulation, oversight might fall to other regulators, namely the GPhC and the Medicines and Healthcare products Regulatory Agency (MHRA), and I am assured that all three regulators are working collaboratively to share information where there are concerns about a provider.”

Source location

2019-0387-Response-from-The-Department-of-Health-and-Social-Care
Page 3 · response
Published 27 December 2019

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.4

  1. 1

    Ask NICE to develop guidance on safely prescribing dependence-associated drugs and managing withdrawal.

    Stated by Department of Health and Social CareStated completedThe respondent said that this action was complete when they made their response on 27 December 2019.
  2. 2

    Ask the Chief Pharmaceutical Officer to review NHS overprescribing, problematic concurrent medication use and stopping unnecessary repeat prescriptions.

    Stated by Department of Health and Social CareStated completedThe respondent said that this action was complete when they made their response on 27 December 2019.
  3. 3

    Ask Public Health England to review the scale, distribution, causes and possible responses to prescription drug dependence.

    Stated by Department of Health and Social CareStated completedThe respondent said that this action was complete when they made their response on 27 December 2019.
  4. 4

    Announce prominent addiction warnings on all opioid medication labels.

    Stated by Department of Health and Social CareStated completedThe respondent said that this action was complete when they made their response on 27 December 2019.

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Ask NICE to develop guidance on safely prescribing dependence-associated drugs and managing withdrawal.

Verbatim wording from the response

“In addition, we asked the National Institute for Health and Care Excellence (NICE) to develop guidance on the safe prescribing of drugs associated with dependence (such as opioids) and the careful management of withdrawing from these drugs¹¹. NICE is also developing guidance on Chronic pain: assessment and management¹².”

Source location

2019-0387-Response-from-The-Department-of-Health-and-Social-Care
Page 5 · response
Published 27 December 2019

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Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Ask the Chief Pharmaceutical Officer to review NHS overprescribing, problematic concurrent medication use and stopping unnecessary repeat prescriptions.

Verbatim wording from the response

“The report acknowledged that work to tackle this issue has already started or is planned. For example, England’s Chief Pharmaceutical Officer, Dr Keith Ridge, was asked by the Secretary of State for Health and Social Care, Matt Hancock, to review overprescribing in the NHS, problematic use of multiple medications concurrently, and how to help patients come off repeat prescriptions they no longer need.”

Source location

2019-0387-Response-from-The-Department-of-Health-and-Social-Care
Page 4 · response
Published 27 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Ask Public Health England to review the scale, distribution, causes and possible responses to prescription drug dependence.

Verbatim wording from the response

“Turning to the wider issues raised in your report, you explain that Ms Headspeath had a long-standing dependence on the opioid, codeine. We are very concerned about the recent increase in people addicted to opioid medicines and, in 2017, the Government asked Public Health England (PHE) to conduct an evidence review to identify the scale, distribution and causes of prescription drug dependence, and what might be done to address it. PHE’s report of the review was published in September 2019¹⁰ and made the following recommendations:”

Source location

2019-0387-Response-from-The-Department-of-Health-and-Social-Care
Page 4 · response
Published 27 December 2019

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Announce prominent addiction warnings on all opioid medication labels.

Verbatim wording from the response

“The MHRA is currently undertaking a review of opioid medicines and the risk of addiction and dependence. Following initial recommendations of an Expert Working Group, endorsed by the Commission on Human Medicines, in April 2019, we announced that all opioid medications will carry prominent addiction warnings on their labels. Furthermore, the MHRA is working with stakeholders to better support appropriate use of prescription opioids and provide better guidance and consistent information for healthcare professionals. In addition, a leaflet for patients is expected to be available in the coming months, either directly from pharmacists or online.”

Source location

2019-0387-Response-from-The-Department-of-Health-and-Social-Care
Page 5 · response
Published 27 December 2019

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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
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Data last updated 7 September 2026