Pharmacies within the Hola Health ecosystem | Vaxa - Hola Health Review

Pharmacies within the Hola Health ecosystem

Estimated 16 min read

Relationship, role and lifecycle

Pharmacies are a vital part of the Hola Health ecosystem – alongside the telehealth service, pharmacies round out the end-to-end prescribing value and supply chain.

In return, pharmacies gain a new source digital customers, and therefore a new revenue stream.

The lifecycle of a pharmacy on the Hola Health platform is onboard, maintain, offboard. We’ll explore each in greater detail below.

Figure 4: The high-level lifecycle of a pharmacy.


The high-level lifecycle of a pharmacy.

Hola Health’s relationships with pharmacies are long-standing—most pharmacies onboarded to the platform continue to use it, which speaks to the mutually beneficial nature of the relationship.

The relationship is formalised in a contract and service level agreement, which we understand has been provided to Healthylife’s due diligence team for legal review. Hola advised us that this includes verification of the pharmacy’s compliance documents, and ensuring that all individual pharmacists have active registrations with Australian Health Practitioner Regulation Agency (AHPRA).

In What is the process for onboarding pharmacies?, we’ll explore the expectations placed on each pharmacy in greater detail.

How do pharmacies use and benefit from Hola Health?

Pharmacies setup on the Hola Health platform can accept prescriptions for dispensing and sell Over The Counter (OTC) items; Hola Health’s platform exists to broker transactions between patients and pharmacies in a wide-reaching, digital-first manner. This is particularly useful for pharmacies who don’t have their own digital presence, or who want to expand their customer base through other Hola-linked channels (like DoorDash or Uber Eats for OTC items—referred to as Marketplace internally).

To interact with the platform, pharmacies are provided a portal to accept & manage orders. This portal is accessible via a web browser on the pharmacies’ existing computers, and is accessed via shared login for all staff at each pharmacy; this is a small security risk that we’ll explore in How does Hola Health move data between its system and a pharmacy’s dispense systems?.

RSK001: Pharmacies access control to Pharmacy Portal is questionable

Severity

[3]

Likelihood

[4]

Rating

[12]

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Related Recommendations:

Pharmacists are expected to monitor the portal for incoming orders, and to dispense & pack orders in a timely manner (enforced via an Service Level Agreement (SLA)). Part of this process includes verifying stock levels of the requested prescription/OTC item; if items are out-of-stock, the order is rejected or altered (e.g. items removed, order delayed) in collaboration with Hola support and the customer. In a similar vein, pharmacists can always seek support from Hola’s support team via the portal, or via other support channels if required (where the portal isn’t available, for example).

Pharmacists receive notes with each order that detail any special instructions from the patient or doctor—including when a patient has requested a consult with the pharmacists about the drugs—and are expected to follow these instructions as part of the dispensing process. Presently, the effectiveness of these special instructions are not directly measurable by Hola, but works are in place to automatically gather feedback on the quality of the service provided by the pharmacy which will address this concern.

RSK002: Only ad-hoc feedback on pharmacy service quality & limited alignment back to pharmacy performance

Severity

[2]

Likelihood

[4]

Rating

[8]

View in Register

Related Recommendations:

REC003: Bolster customer feedback system

Nature: Tactical
Party: Hola Health
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Related Risks:

Where OTC items are sold for a pharmacy, maintaining accurate stock levels is important to minimise the risk of orders being placed for items that are out-of-stock, particularly damaging for the customer experience and indeed Hola’s & the pharmacy’s reputation on platforms like Uber Eats and DoorDash. We’ll explore this in How does Hola Health move data between its system and a pharmacy’s dispense systems?.

In contrast to some other models, pharmacy’s don’t pay an ongoing monthly fee for the service, but instead pay a per-script and percentage-based fee for each transaction (with the customer picking up the bill for a convenience fee, and a delivery fee if applicable). It’s arguable this is a more equitable model for pharmacies, as it means that they only pay for the service when they’re using it, and that the cost of the service is directly related to the revenue it generates for the pharmacy.

What is the process for onboarding pharmacies?

As best practice, we suggest the following documented information is appropriate for the management of the lifecycle of a pharmacy’s relationship with Hola Health:

Item Justification Status
A contract granting Hola Health enforcement rights and risk transfer to the pharmacy. The contract legally formalises the obligations, rights, and liabilities of both parties, ensuring clarity and accountability in their relationship.
A policy outlining the criteria for pharmacies partnering with Hola Health, roles/responsibilities, and ongoing expectations. This policy sets clear guidelines for collaboration, ensuring alignment and understanding between the pharmacy and Hola Health throughout their engagement.
A process detailing the steps for pharmacy onboarding, specifying responsibilities for both Hola Health and the pharmacy. This process streamlines onboarding, reducing ambiguity and ensuring efficient execution by delineating tasks and responsibilities for each party involved. Further, it reduces the chance that key controls are missed in the onboarding process. ⚠️
A procedure for setting up pharmacies within Hola Health’s systems during onboarding. This procedure ensures consistency and accuracy in system setup, facilitating seamless integration and operational readiness for the pharmacy within Hola Health.
A process and procedure for ongoing maintenance, including auditing and performance reporting against SLAs. These ensure continuous quality assurance, allowing Hola Health to monitor and uphold service and compliance standards. ⚠️
A process and procedure for offboarding pharmacies in cases of non-compliance or non-renewal of contract. This ensures a structured and fair approach to ending partnerships, safeguarding Hola Health’s interests and maintaining accountability in compliance matters.

The last two items are discussed in Once onboarded, how are pharmacies managed whilst live on Hola Health? and How are pharmacies offboarded from Hola Health?, as our focus here is on the onboarding stage of the pharmacy lifecycle.

Beyond the basic legal and regulatory requirements set out above, Hola Health doesn’t have any further documented requirements for pharmacies; there’s no documentation requiring consideration be given to the customer service experience (e.g. by validating reviews) or alignment of brand values. While we appreciate that Hola Health merely acts as a broker between the pharmacy and the customer, we believe that Hola should still consider other elements when assessing the suitability of a pharmacy for the platform to ensure that the customer experience remains high quality.

It should be noted that there’s likely little risk (beyond customer experience concerns) arising from this current process; pharmacies already operate in a well-controlled regulatory environment, and Hola is essentially only a “lead generator” that connects customers to pharmacies. From a pure legal standpoint, there is arguably little additional risk exposure here. However, there is reputational risk, stemming from poor customer service standards, potential misuse of the platform (although this would be very difficult in such a regulated environment anyway) and association with pharmacies with underlying issues (e.g. insolvent) – refer to the discussion in Key theory and concepts. A more robust assessment process would help to mitigate these risks.

RSK004: No documented requirements for pharmacy onboarding beyond legal standards

Severity

[3]

Likelihood

[4]

Rating

[12]

View in Register

Related Recommendations:

REC005: Implement robust pharmacy assessment process

Nature: Operational
Party: Hola Health
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Related Risks:

Hola onboards both independent pharmacies and those that fall under a larger banner (e.g. a chain of pharmacies). The process for onboarding is essentially the same for both, with the only difference being that the larger banner pharmacies are:

  • Slightly easier to onboard as the relationship is already established with the banner brand
  • Able to be setup with a Pharmacy Group Admin role in the system, which allows a representative from the banner brand to view order flow and performance across all pharmacies in the group

The process for onboarding a pharmacy is as follows:

Figure 5: The process to onboard an pharmacy to the Hola Health platform.


The process to onboard an pharmacy to the Hola Health platform.

Generally speaking, the actual process for onboarding a pharmacy is straightforward and well-documented, with primary responsibility falling on the Pharmacy Coordinator role, with contribution from the technical team in setting up data feeds to extract inventory from the pharmacy’s Point of Sale (POS) system.

As Hola is uniquely situated to receive inventory data from pharmacy’s—including commercially sensitive data—it’s important that Hola not only secures this data, but also ensures that it’s only used for purposes of operating the platform (assuming pharmacies aren’t agreeing for further use). While we’re reasonably comfortable with the security of this data, it was advised that no policy restricts Hola from using this data for other purposes, and that this is a risk that should be mitigated by Hola Health, or at the very least disclosed to pharmacies explicitly.

RSK003: No clear position on use of 3rd party's data

Severity

[3]

Likelihood

[3]

Rating

[9]

View in Register

Related Recommendations:

REC004: Establish internal data usage policy for non-patient parties

Nature: Strategic
Party: Hola Health
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Related Risks:

Once onboarded, how are pharmacies managed whilst live on Hola Health?

Pharmacies on the Hola Health platform are managed by the Pharmacy Coordinator role and the support team. The primary measurement of a pharmacy’s performance is their ‘on-time’ rate—pharmacies are obligated to accept, dispense and pack orders within a certain timeframe (depending on OTC vs prescription) under their SLA.

This is a reasonable metric for measuring the performance of a pharmacy, as it directly impacts the customer experience. However, it’s worth noting that this metric doesn’t capture the quality of the service provided by the pharmacy, or the accuracy of the dispensing process. While Hola Health has plans to implement a feedback system that will allow customers to rate the service provided by the pharmacy, this is not yet in place.

REC003: Bolster customer feedback system

Nature: Tactical
Party: Hola Health
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Related Risks:

Support staff also closely monitor each order as it progresses through the Hola system—from placement to delivery—and so they’re able to intervene reasonably early when things go awry (e.g. due to a delayed delivery driver). In this respect, it’s difficult for things to go too far off track, but it’s worth noting that the system is still reliant on human intervention to catch these issues and so isn’t infallible.

Figure 6: How pharmacies are maintained on the Hola Health platform.


How pharmacies are maintained on the Hola Health platform.

In a best practice environment, coupled with a solution for

to uniquely identify the pharmacists using Hola’s portal, we would like to see regular checks of the pharmacists’ registrations. This is a low priority though, as the pharmacy (as a business) is responsible for ensuring their pharmacists are registered, and Hola is only responsible for ensuring the pharmacy is compliant with their contract. This is in contrast to the telehealth service, where the doctors are directly employed by Hola Health and so Hola is directly responsible for keeping this information current.

REC018: Implement more frequent AHPRA registration checks

Nature: Tactical
Party: Hola Health
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Related Risks:

How are complaints against a pharmacy handled?

Complaints against a pharmacy are handled by the support team, who are responsible for investigating the complaint and taking appropriate action. This may include refunding the customer, providing a discount on a future order, or escalating the issue to the pharmacy for further investigation.

Documented processes exist as to this complaint resolution process, including escalation to the pharmacy if required.

Figure 7: How underperforming pharmacies are managed when complaints are raised.


How underperforming pharmacies are managed when complaints are raised.

It’s good to see that Hola follows up with customers even after the complaint has been escalated to the pharmacy, to ensure that the issue has been resolved to the customer’s satisfaction. This is a good practice that helps to ensure that the customer is happy with the outcome, and that the pharmacy has taken appropriate action to address the issue at hand.

Additionally, in our discussions with Hola, we discussed how they feel about their ability to scale their support team as more pharmacies are onboard and more orders are placed. They advised us that their intention is to actually reduce the ratio of support staff as they scale, by implementing more automated systems to firstly reduce the incidence of adverse events, and then also by handling common queries and issues. This highlights Hola can keep both scale and customer service quality in mind as they grow.

To achieve a gold standard, we’d suggest Hola document how they would handle repeated or gross violations of the SLA between Hola and a pharmacy—up to and including removal from the platform. This would ensure that all staff are aware of the process, and that it’s consistently applied across all pharmacies (particularly as this is a very rare event, it’s important that the process is well understood). This could broadly take the form of:

  • Thresholds hit (via metrics) that trigger a review of the pharmacy’s performance, or gross violations that trigger immediate action
  • Start case and review past performance
  • Escalate to the pharmacy for a response within X days
  • Pharmacy to provide a written rectification plan within Y days
  • Hola to monitor implementation of the rectification plan and make a decision on the pharmacy’s future on the platform

REC023: Document process for underperforming pharmacies

Nature: Strategic
Party: Hola Health
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How are pharmacies offboarded from Hola Health?

As expected, Hola noted they try to avoid offboarding pharmacies where possible and would rather resolve issues with the pharmacy to keep them on the platform—e.g. working through why they’re unable to meet their order timeframe SLAs.

However, in cases where a pharmacy is non-compliant with the terms of their contract, or where the pharmacy has requested to be offboarded, Hola is able to deactivate the pharmacy’s account in the system. The pharmacy will exist in a deactivated state in the system, and will no longer be able to accept orders or access the portal until reactivated by Hola.

This is an effective practice to ensure the pharmacy can’t continue to operate on the platform if they’re not meeting their obligations, but also allows for the pharmacy to be reactivated if they resolve the issues that led to their deactivation and retains their data in the system for any future audit requirements.

While we were unable to sight a documented process for offboarding pharmacies, our discussions indicate this is a well-understood process within the organisation, and that this is exceedingly rare—so at this stage the lack of a formal offboarding process only presents a very minor risk.

RSK005: No formal documented process for pharmacy offboarding

Severity

[1]

Likelihood

[2]

Rating

[2]

View in Register

Related Recommendations:

REC006: Document formal offboarding process for pharmacies and their staff

Nature: Operational
Party: Hola Health
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Related Risks:

How does Hola Health move data between its system and a pharmacy’s dispense systems?

There are two primary data flows between Hola Health and a pharmacy:

  1. Order data from Hola Health to the pharmacy’s dispense/POS system
  2. Inventory data from the pharmacy’s POS system to Hola Health

Data to the pharmacy from Hola Health

As mentioned above, pharmacists receive orders (both OTC and prescription) via the Pharmacy Portal provided by Hola.

Figure 8: Conceptual flow of data between the systems used in the prescription fulfilment workflow.


Conceptual flow of data between the systems used in the prescription fulfilment workflow.

In the event of a prescription, this can be Electronic Prescription (eRx) or paper-based. The vast majority are eRx, but paper scripts are accommodated (but for delivery orders, this requires Hola to dispatch a courier to collect the script from the patient prior to dispensing).

There is no direct integration between Hola Health and the pharmacy’s dispense system. This greatly simplifies the development/onboarding process, and limits any risk of a breach of the pharmacy’s system.

To get eRx scripts into the dispensing system, there’s two options:

  1. Scan the QR code of the script within the Hola portal using the existing scanners in the pharmacy; or
  2. Manually enter the script’s token into the dispensing system

eRx scripts are verified within Hola against the eRx Script Exchange, so only valid scripts are sent to the pharmacy. Paper scripts are verified by the pharmacist through their usual business (no different to a walk in), so the additional risk arising here is low.

In either case, the net result is the same—the pharmacy relies on the data within the script to make their assessment to dispense the medication; the risk here is exceedingly low.

With OTC orders, the process is even simpler—the pharmacy receives a list of items to dispense, and they’re expected to verify stock levels and dispense the items as required, generally assigning it back to a “Hola Health” account which is reconciled fortnightly (because Hola collects payment on behalf of the pharmacy). This is a low-risk process given the items involved, but is probably more likely to bring about customer service issues given the breadth of items available and fewer controls in place; collecting feedback on the quality of the service provided by the pharmacy would be a good way to mitigate this risk.

REC003: Bolster customer feedback system

Nature: Tactical
Party: Hola Health
View in Register

Related Risks:

Data from the pharmacy to Hola Health

Where a pharmacy sells OTC items through Hola Health, they’re required to provide inventory data to Hola Health to facilitate the listing of their items online.

Figure 9: Conceptual flow of data between the systems used in the marketplace functionality.


Conceptual flow of data between the systems used in the marketplace functionality.

This is done via a data feed from the pharmacy’s POS system to Hola Health, which is then used to populate the Marketplace with the items available for sale. Hola indicated there are essentially 3 ways this is currently done:

  • Manual data provided by email — exceedingly rare
  • Data dropped into an Secure File Transfer Protocol (SFTP) server — common
  • Automatic data feed dropped into an SFTP server — less common

In all cases, data from pharmacies remain segregated from other pharmacies which is a good practice to ensure data privacy. Hola indicated they have assisted with some pharmacists—particularly those without internal development teams, but with an outsized growth potential—with the development of these data feeds to ensure they’re able to list their items on the Marketplace; it’s reasonable to assume that Hola may one day reach a point where the majority of pharmacy POS systems are integrated with Hola Health, but in the meantime this doesn’t present a significant risk nor hamper the ability of the pharmacy to list their items. Hola could also explore partnering with a third-party vendor who maintains these types of integrations given this isn’t a core business function.

Hola ingests this data and uses it to populate the Marketplace with the items available for sale. This is a low-risk process, as the data is essentially a list of items and their prices, but should still be managed with due care and to a reasonable standard.

RSK003: No clear position on use of 3rd party's data

Severity

[3]

Likelihood

[3]

Rating

[9]

View in Register

Related Recommendations:

Does Hola Health use compounding pharmacies or work with nicotine vapes?

Hola indicated that they generally don’t work with compounding pharmacies however this is seemingly not a standing rule; we were told that where a valid prescription is received for a compounded medication and the pharmacy is able to dispense it, they will do so.

On the topic of prescribing Ozempic and similar drugs, we were advised that, because there is no permitted on-label use of this for weight-loss, their doctors wouldn’t be prescribing it for this purpose. However, as we’ll see in the Doctors discussion, doctors are effectively given free reign over their prescribing practices, and so it’s possible that a doctor could prescribe this off-label.

Nicotine replacement therapy is supported through the platform, which similarly may include nicotine vapes where the doctor feels it’s the best course of treatment. We were advised this is generally discouraged, however, and that many doctors opt not to participate in this part of the platform.

Hola doesn’t offer any ‘weight-loss’ or ‘smoking cessation’ programs like other providers, and so are not actively marketing these services to customers. We feel this is a good practice, as it ensures that customers are only receiving these medications where they’re medically necessary, rather than as part of a packaged bundle intended to drive sales.

Case studies

Vaxa was asked to interview 5 pharmacists using the Hola Health platform to understand their experiences and gather feedback on the service. Selection of pharmacists was made by Hola Health, who also scheduled the interviews. The interviews were conducted by Vaxa staff and recorded for transcription and analysis.

Only four pharmacists were scheduled, and only three were available at the time of the interviews. The following case studies are based on the interviews conducted with these pharmacists.