Remote Prescribing Case – Warning but No Restrictions

We acted for a consultant physician who faced a GMC Investigation Committee hearing arising from private online prescribing of weight‑loss medication and Kenalog via an aesthetics prescribing platform. The concerns centred on remote prescribing based on practitioner‑completed questionnaires, absence of conventional clinical records and consent documentation, and apparently excessive quantities prescribed in one patient’s name but delivered to multiple addresses.

Working with the doctor, we provided detailed written submissions and supporting evidence explaining how the platform operated, the practitioner‑prescriber model, and the extent to which the system design and a dishonest practitioner’s misuse contributed to the pattern of prescribing. We demonstrated that our client had stopped this type of remote prescribing, implemented robust new record‑keeping and consent processes, and undertaken extensive CPD on safe prescribing, remote consultations, ethics and data protection, supported by strong colleague and patient feedback demonstrating safe, high‑quality NHS practice.

At the oral hearing the GMC invited the Committee to issue a formal warning, relying on an expert opinion that, on one view of the facts, the prescribing fell seriously below expected standards. We argued that in the specific context of sector‑wide practice, platform flaws and third‑party deception, our client’s conduct did not warrant any restriction and that he had shown meaningful insight and remediation. While the Committee ultimately decided that his actions did not justify restrictions on registration, it concluded that a warning was the proportionate outcome to mark the departure from expected standards and emphasise that any repetition would risk a future finding of impairment.

What this means if you’re facing similar allegations

Where prescribing concerns arise partly from platform design or third-party misuse, that wider context matters to the outcome. Evidencing changed practice, robust new processes and relevant CPD can keep restrictions off your registration even where some criticism is upheld. If you face prescribing allegations, demonstrating meaningful remediation early can be decisive.

Facing a GMC case? Learn more about our General Medical Council (GMC) defence services, or contact us for a free case evaluation.