Vaxa | Medmate Clinical Governance and Pharmacy Review​

Introduction

In April 2024, Healthylife engaged Vaxa to undertake a holistic review of one of their suppliers, Medmate. The scope of the review was centred on on Medmate's governance across the areas in which they support Healthylife, including:

  • Pharmacy - existing pharmacies are forwarded orders by Medmate for products like prescription medicine or supplements etc.
  • Telehealth - contracted GPs delivering telehealth for acute issues and repeat prescriptions via the Medmate platform and it's clinical systems (Medical Director); and
  • Quitmate & similar programs - individualised, "subscription" health programs developed by and delivered by Medmate as a service using its platform and service network.

We've made observations in the risks and recommendations registers; our review was time-limited, so we have suggested further compliance analysis as a next step.

On the basis of our findings in the attached report, the position that Medmate finds itself is not dissimiliar from businesses of a similar size, if not better.

Regardless, we must consider two things: a) Medmate operates a health service, so is particularly vulnerable to many more forms of risk and b) Medmate's size is not a mitigiating factor for Healthylife, who require a certain standard to be upheld. In general, Medmate does adequately treat most obvious risks, but without a formal risk management or quality management approach in place, it's difficult to suggest that all risk is understood and appropriately treated; there are some identified carried risks that should be resolved.

We must also recognise than many of the risks we've identified are inherent in the operating a business in the telehealth/medical industry; some of the identified risks would exist in the same way whether it was Medmate or any other operator delivering the same service.

To this end, our recommendations register steps out a number of small, medium and large recommendations to further improve the posture of Medmate, and therefore further solidify the working relationship between Healthylife and Medmate.

To reconfirm the scope requested of us in this report, and where that information may be found within this report, please see the following table. We're pleased to deliver a comprehensive review beyond this scope as well; additional discussions are made available throughout the report where appropriate.

Requirement Agreed Approach Delivered in
Overall map for script fulfillment of the operational process from ordering a script via a pharmacy through to delivery Detail the workflow processes involved in ordering a script and its delivery, including:​
  • Identification of software utilised at each step​
  • Explanation of how and where the information is stored
Various, but primarily in How does a patient’s data flow end-to-end through the platforms?, How do patients get a script renewal?, and How do patients get scripts filled?
Process on how SaaS/OMS integrates with established pharmacy dispense systems - and include which dispense systems Medmate integrates with ​Provide an overview of pharmacy dispensing systems and the integration of Software as a Service (Saas) or Order Management Systems (OMS) utilised by Medmate and the pharmacies they have partnered with.​ Specifically covered in How does Medmate move data between its system and a pharmacy’s dispense systems?, but also of relevance is Who can integrate with Medmate?
Process for onboarding pharmacies (including requirements) Outline the requirements for pharmacies to become a Medmate provider and the associated onboarding process.​ Covered in detail within What is the process for onboarding pharmacies?
Internal audit process related to pharmacies on your platform Provide an overview of the processes utilised by Medmate for pharmacy review and compliance post-onboarding, as well as Medmate's internal auditing procedures concerning pharmacies on their platform. Discussed in both Once onboarded, how are pharmacies managed whilst live on Medmate? and How are complaints against a pharmacy handled?
Process for standards for pharmacies to stay on the system? e.g. Does anything disqualify them once live?​ Describe how pharmacy requirements and compliance are assessed, and the actions taken if a pharmacy fails to meet Medmate's standards for service provision.​ As above.
Flow of personal data/ health information (e.g. script token) and how MM ensures that it stays within the pharmacy systems?​ Evaluate the flow of personal information from the issuance of a script to the delivery of medication.​ Mapped in How does a patient’s data flow end-to-end through the platforms?
Individual program review:​ Weight management program​ Provide a high-level report that maps the potential risk exposure for Healthylife.​​ Discussed specifically in How do doctors prescribe drugs? and How do doctors participate in and run programs like Quitmate? and then more broadly from a managerial perspective in How does Medmate decide on pilot programs or ventures?
Review of Quitmate Provide a high-level report that maps the potential risk exposure for Healthylife.​​ Discussed specifically in How do doctors prescribe drugs? and How do doctors participate in and run programs like Quitmate? and then more broadly from a managerial perspective in How does Medmate decide on pilot programs or ventures?
Future/broader review Document the subsidiaries of Medmate and any other associated companies.​ Mostly folded into recommendations - see REC22 and REC27.