The National Health Service (Scotland) Act 1978 (Independent Health Care) Modification Order 2024 will address situations where pharmacists and pharmacy technicians provide services from unregulated clinics.

The Policy Note accompanying the modification order said:

“The instrument aims to increase public safety and avoid situations where pharmacists and pharmacy technicians provide services from unregulated clinics (services provided in registered pharmacies and/or under an NHS contract are excluded) and where wholly online providers are able to provide services to patients in Scotland without being regulated.

“The changes regarding IMAs, including online services, are particularly urgent. Online healthcare services do not currently fall within regulation by HIS. This is considered to pose a public health risk.

“In relation to cancellation of registration, the changes made by this instrument will provide HIS with a meaningful sanction against registered providers who fail to pay their continuation fees. We assess that this deterrent is likely to have a positive impact on the willingness of providers to pay the fees they owe, and is intended to be used as a last resort.”

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