All clinics, pharmacies and producers operating in the medical cannabis space have to adhere to strict rules, regulations and submit to oversight from numerous regulatory bodies. Here we'll attempt to explain the process for each, as well as providing advice on official complaint and reporting mechanisms in-place.
Clinics & Care Quality Commission
Clinics across the UK must register with the Care Quality Commission, a legal requirement under the Social Care Act 2008. Clinics must undergo periodic inspections by the CQC which measure performance across 5 key areas, we report on and update each clinics score here on our website:
- Is a practice safe?
- Is it effective?
- Is it caring?
- Is it responsive to people's needs?
- Is it well led?
When handling patient issues, all clinics must have a formal complain process in-place and must further ensure it's accessible. If and when a patient ever feels the need to provide feedback directly to the CQC, one of the first questions asked will be whether the formal complaints process in-place has been followed - and any outcome from it.
We feel patients should always provide a clinic with opportunity to resolve any issues, before immediately complaining to the regulatory body. The CQC takes reports received seriously, and potentially will specifically check into concerns raised as part of their process for any future clinic inspection. It's known that clinics receiving frequent complaints may be prioritised for inspection.Provide Clinic Feedback to CQC
Recently, MedBud has been made aware of a new medical cannabis specialist at the CQC who will be a part of reviewing scoring for all existing clinics - specifically rechecking each measured key area of performance.
Pharmacies & General Pharmaceutical Council
Pharmacies and pharmacy professionals are regulated by the General Pharmaceutical Council, the main powers and responsibilities of the GPhC are derived from the The Pharmacy Order 2010. In addition, the council has powers and responsibilities for the registration of pharmacy premises and for enforcing certain provisions under The Medicines Act 1968 and The Poisons Act 1972. GPhC:
- promote professionalism within pharmacy;
- help make sure pharmacists and pharmacy technicians have the appropriate knowledge, attitudes and behaviours;
- assure the quality of pharmacy, including its safety;
- support the improvement of pharmacy.
One issue that regularly occurs for patients, is being charged for medication which is unavailable. Then requiring both a prescription rewrite, several days of delay for the patient, and the potential to directly cause gaps in a patient's medication against the direct instructions of the prescribing specialist. Pharmacies should work hard to ensure payment is not requested for products that are not available after receiving a patient's prescription, and should ensure 'stock checks' are part of their prescription handling workflow. We consider this a valid and serious concern worth reporting to the GPhC in all instances, with numerous patients being left both out of pocket, and out of medication, for sometimes days at a time - any card refunds typically taking 3-5 working days alone.
Your medication should always arrive with prescription labels attached to product packaging (ideally signed), and with either a tamper-proof seal for flower pots, a bottle seal on oils, or cellophane wrapping covering the medication packaging itself. If your medication arrives unsealed, please immediately arrange a return with your pharmacy. Aside from the potential of contamination, where flower is concerned it will have been exposed to air and environmental conditions which fall outside of general best practices for storing cannabis flower. There have been instances of one pharmacy blaming another for missing tamper-proof seals, but this scenario should not occur whatsoever, and fault would lie with both pharmacies in this instance as medication should not ever be dispensed in this fashion.
If you have an issue with medication itself, while wanting to inform your specialist during your next medical consultation, it's the responsibility of a pharmacy to handle direct issues with any dispensed medication. Some patients have found pharmacies willing to help fill out 'Yellow Card' adverse reaction reports, and liaise with the product supplier in flagging concerns. In most instances pharmacies themselves are not responsible for packaging cannabis medications, while some oils are formulated here in the UK, and some flower is packaged from bulk into individual pots here in the UK - in most circumstances the quality of the product overall lies with the producer. Please review our separate advice below for product issues, though note that as a patient, your pharmacy is your primary point of contact for any abnormalities in your medication and has a responsibility to ensure issues are dealt with appropriately. This isn't to be confused with any medication being unsuitable for you personally as a patient, which in all instances needs to be handled by your clinic and prescribing specialist.Report a Concern to GPhC
Products, MHRA & Yellow Card
List COA metrics and safety checks in place. Background on MHRA oversight.
Still being written.
We recommend weighing each and every pot of flower received, while measuring out oil bottles is likely lead to wastage, it's best practice to ensure the amount of flower prescribed is as received not being so easily visually measurable. The author of this article has received 10g pots weighing from 9.3-10.7/g in the past. In all instances of a product being underweight it should be reported to the pharmacy, with most then issuing a partial refund for the exact amount missing.