Roughly 93% of AMA members surveyed were opposed to the Pharmacy Board of Australia’s draft prescribing endorsement.
The AMA has come out swinging in its submission to the Pharmacy Board of Australia’s consultation on a prescribing endorsement for pharmacists, accusing the board of failing to provide any substantial evidence for the safety of its proposal.
Published today, the AMA submission warned that passing the pharmacy board proposal as is would lead to “a significant and potentially irreversible change to our healthcare system”.
“Using healthcare access and workforce shortages as reasons to pursue autonomous non-medical prescribing is unacceptable and reckless,” the submission reads.
“It disregards the safety of the patient, which must be placed as the highest priority when providing care.”
The draft endorsement, released by the pharmacy board and AHPRA earlier this year, would essentially introduce a nationally consistent qualification and education standard that pharmacists would need to meet before they could prescribe.
Because there are no minimum standards right now, each state and territory has been able to decide on how much training a pharmacist has to do before prescribing.
The other thing an endorsement does is explicitly state which classes of scheduled medicines the endorsed pharmacists will be able to prescribe.
There were two options included in the pharmacy board proposal: authorising pharmacists to prescribe all schedule 2, 3 and 4 medicines or authorising pharmacists to prescribe all schedule 2, 3, 4 and 8 medicines.
It also recommended that pharmacists self-determine their scope of practice, including which medicines they could autonomously prescribe.
“The pharmacy board is leaping ahead with a choose-your-own-adventure, pick-your-own-scope, anything-is-open [attitude toward] prescribing in terms of the endorsement itself,” AMA president Dr Danielle McMullen told Allergy & Respiratory Republic.
“[This is] leaving even more pressure on the state and territory governments [to decide] … what their prescribing environment would look like.
“We think the pharmacy board needs to go back to the drawing board on this and take much more of a patient safety focus, as the regulator, and be much clearer about the model of care that is appropriate.”
The AMA took specific issue with the lack of detail provided on training, pointing out that the current Australian Pharmacy Council-accredited prescriber training courses only provide for about 150 hours of supervised clinical experience.
Registered nurses and midwives need to have a minimum 5000 hours of clinical experience to qualify for a prescribing endorsement, while even the most junior doctors have around 2000 hours of clinical experience upon graduation from medical school.
The training provided by the current prescriber courses simply would not equip graduates with the competencies needed to prescribe, the medical association argued.
“Pharmacists are not fit to diagnose the variety of conditions in order to understand the most appropriate S4 medications to issue safely and arrange follow-up,” one AMA member is quoted as saying.
“The appropriate qualification to prescribe S4 medications is already available, it’s called a medical degree.”
The AMA also highlighted that many schedule 8 and some schedule 4 medicines (benzodiazepines, opioid analgesic and anabolic steroids) all had potential for misuse.
“Even if future prescriber programs equip graduates with the recommended minimum 5,000 hour of clinical experience, they would still not have the full suite of specialised knowledge and competencies that medical practitioners require for their professions,” the AMA wrote.
“Allowing pharmacist prescribers to autonomously prescribe Schedule 4 and 8 medicines without additional clinical oversight would significantly risk patient safety.”
The consultation did ask that pharmacists not dispense a medicine they had prescribed, other than in “extenuating” circumstances.
Although the AMA welcomed the acknowledgement that there was inherent conflict of interest in the prescriber and the dispenser being the same person, its praise ended there.
“While the AMA appreciates the guideline in the proposal to separate prescribing and dispensing except in extenuating circumstances, we do not think this recommendation is sufficiently robust,” the submission read.
“A pharmacist prescriber who has their prescription dispensed by a colleague working in the same premise could still have the same financial incentive to prescribe greater amounts of or more expensive medicines.
“The endorsement must be more explicit in addressing conflicts of interest to protect pharmacists from workplace coercion and pressure.
“The AMA strongly recommends a minimum requirement in the endorsement of having the prescription of the pharmacist prescriber to be dispensed at an independent pharmacy.”
Another argument from the AMA was that allowing pharmacists to prescribe schedule 8 medicines could expose them to increased risks of workplace violence.
“Doctors have long had to deal with patients seeking drugs of dependence or inappropriate therapies, and pressuring doctors to prescribe,” Dr McMullen said.
“I can only imagine that that would be multiple times harder when they can see the medicine sitting on the shelf behind you.
“There is some protection for doctors in that it’s not immediately available … but we do hold genuine concerns, particularly if this is involving S8s or other drugs of dependency, for the risk that that places pharmacists under.”
