Welcome to the latest edition of the Pharmacy Board of Australia’s (the Board) newsletter in our new email format.
In this newsletter we talk about continuing professional development (CPD) and tools available to help meet the requirements outlined in the Board’s registration standard and guidelines on CPD. We also provide some general advice for pharmacists returning to practice after a break.
In June the Board hosted the pharmacist prescribing forum to consider the need and opportunities for expanding pharmacist involvement in prescribing. You can read more about the forum below.
The Board has also announced the national general registration fee for pharmacists for 2018/19. Read more about the Board’s work and fees below.
The appointment of new members to the Board is anticipated in the near future. As this is my last message as Chair of the Board I'd like to acknowledge the contributions of the other outgoing Board members. I have had the pleasure of working with fellow departing Board members Bhavini Patel, Karen O’Keefe, Rachel Carr and Trevor Draysey, all of whom were members of the inaugural Pharmacy Board of Australia established nine years ago, and during the past six years, Katherine Sloper.
Serving as the Chair of the Board over the last three years has been a very special opportunity and I am proud of the Board’s collaborative efforts and achievements. I especially want to thank all Board members for their unwavering commitment to protecting the public during their terms and I wish the new Board, which will be announced upon its appointment by Ministerial Council, ongoing success in fulfilling its functions.
Chair, Pharmacy Board of Australia
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In June the Board hosted a forum in Melbourne to consider the need and opportunities for expanding pharmacist involvement in prescribing.
The forum explored the potential expanded role of pharmacists in prescribing in order to contribute to supporting access to medicines in Australia, which aligns with the objectives of the National Scheme, including 'to enable the continuous development of a flexible, responsive and sustainable health workforce and to enable innovation in the education of, and service delivery by, health practitioners'.
The day-long forum was an opportunity to explore, identify and articulate the roles of different stakeholders to successfully develop proposals about pharmacist prescribing that could be implemented and sustained as part of a broader range of health services to effectively meet the health needs of the community.
The Board’s facilitation of the forum meant stakeholders could come together to share thoughts and opinions on the three models of non-medical prescribing proposed by the 2013 Health Professionals Prescribing Pathway Project – autonomous prescribing, prescribing under supervision or prescribing via a structured prescribing arrangement – in the context of pharmacy practice.
A report outlining discussions on the day and next steps will be published by the Board shortly.
Next steps will include wider consultation on issues raised at the forum and how stakeholders could be involved to assist in progressing pharmacist prescribing. Examples of this include exploring and defining what pharmacists might do in practice that will better serve the public and identifying what legislative changes would be needed in the eight state and territories to allow pharmacists to prescribe under relevant models.
We remind pharmacists that you must complete a minimum of 40 CPD credits by 30 September before you renew your registration by 30 November. You will also need to plan your CPD for the next 12-month period beginning on 1 October 2018.
The Pharmacy Practitioner Development Committee (PPDC), on behalf of its member organisations1, recently announced the release of tools to help pharmacists meet the requirements outlined in the Board’s registration standard and guidelines on continuing professional development (CPD).
The Board-funded tools include:
We encourage you to access these tools, or tools made available by PPDC member organisations, to help you to meet your annual CPD obligations.
1Pharmacy Practitioner Development Committee member organisations: Australian Association of Consultant Pharmacy; Australian College of Pharmacy, Australian Pharmacy Council, Council of Pharmacy Schools: Australia and New Zealand Inc., National Australian Pharmacy Students’ Association, Pharmaceutical Defence Limited, Pharmaceutical Society of Australia, Pharmacy Board of Australia, Professional Pharmacists Australia, Society of Hospital Pharmacists of Australia and the Pharmacy Guild of Australia.
The Board has released its quarterly registration data. Read the latest report and other statistics on its website. The data profiles Australia’s pharmacy workforce, including information on types of registration held, principal place of practice, registrant age and gender.
At 30 June 2018, there were 31,108 registered pharmacists in total, classified by registration type:
The Board has announced the national general registration fee for pharmacists for 2018/19.
The Board has increased the fee for general registration to $396. It will cover the registration period for most practitioners of 1 December 2018 to 30 November 2019.
The fee for practitioners whose principal place of practice is New South Wales is $3962.
A full fee schedule which includes fees for interns, limited registration, non-practising registration and other registration types has been published on the Board’s website. This includes the fee arrangements for practitioners whose principal place of practice is NSW.
The National Registration and Accreditation Scheme (the National Scheme) is funded by practitioners’ registration fees. The decision to increase the fee ensures that the Board has the funds required to carry out its duties and to protect the public.
Registration fees are used to meet the full cost of regulating the pharmacy profession and do not cross- subsidise other professions. Part of this cost is a strategic initiative which will change the assessment of notifications process to improve efficiency. This initiative will allow earlier resolutions and result in better outcomes for the notifier and the practitioner.
In 2018/19, the Board is implementing projects and initiatives designed to strengthen our processes for ensuring that only pharmacists who are suitably trained and qualified to practise competently and ethically are registered, and to enable the continuous development of a responsive pharmacist workforce.
The Board has funded:
We also conducted a prescribing forum to engage stakeholders to explore pharmacist prescribing to address public need.
There has been an increase in costs in particular in responding to an increase in complaints and AHPRA is investing in modernising information technology systems in order to meet the public and practitioner expectation of quicker, online services.
Fees support the Board in the continual development of a safe and mobile Australian workforce for health practitioners and the public in the most efficient ways possible. It also allows the Board to facilitate the provision of high quality education and training for practitioners.
Pharmacists have an obligation to ensure that they maintain recent practice and complete the annual CPD requirements. Most pharmacists returning to practice after a break are able to meet these requirements. If returning to practice after a long break (longer than one to three years), it pays to plan ahead to minimise any delays in resuming practice.
The Board’s Guidelines on continuing professional development state:
‘If returning to your previous scope of practice after a long break, you’ll need to:
If you haven’t completed any CPD before returning to practice after a long break, you will be required to complete the annual CPD requirements and provide evidence of completion to the Board.
To assist in ensuring competency to practice, you may consider completing education courses that meet your professional development needs such as courses provided by professional organisations or CPD providers, or other activities.
If you haven’t completed the minimum practice requirement of 150 hours in the last 12 months OR 450 hours in the last three years, you may be required to do supervised practice and demonstrate competence by completing an assessment.
From time to time, the Board publishes case summaries to highlight a range of issues arising in practice that have come to the Board as notifications about pharmacists. These summaries serve as a helpful reminder to pharmacists about their obligations, and about the risks arising in practice that require particular attention and management to ensure safe delivery of pharmacy services to the public.
Application of the Pharmacy Board of Australia’s Guidelines for proprietor pharmacists
Proprietor pharmacists need to maintain an active interest in how the practice of pharmacy is being conducted to ensure that the pharmacy operation is in accordance with any applicable state, territory or Commonwealth law. This was highlighted in a recent case before the Board.
Increasingly pharmacies are involved with dispensing medicines to patients in aged-care facilities. In this case, the pharmacy had one owner and employed a number of pharmacists who dispensed medicines regularly to a local aged-care facility. Pharmacists had supplied Schedule 8 medicines based on requests received via facsimile without the prescriber presenting a valid prescription.
State and territory drugs and poisons legislation sets out the legal requirements for the supply of medicines. On this occasion no attempt was made to ensure that the supply of medicines met these requirements.
In addition, the Board found that the proprietor of the pharmacy had practised the profession in a way that was or may be unsatisfactory in that he failed to properly inform himself of what was going on in his pharmacy. The Board’s Guidelines for proprietor pharmacists state that the proprietor must maintain an awareness of the manner in which the pharmacy business is being conducted and, where necessary, intervene to ensure laws, standards and guidelines are adhered to. If the proprietor is not the pharmacist-in-charge he/she must have in place processes (such as regular staff meetings and discussions about practice issues) so that errors can be identified and practice corrected where required.
The outcome was that the proprietor and the dispensing pharmacists received cautions.
The Board continues to receive notifications involving expired medicines being dispensed to patients. As the dispensing of expired stock continues to be an issue we are taking the opportunity to highlight advice provided in a previous newsletter. The expiry date of every dispensed medicine must be checked to ensure that the medicine is in date for the expected duration of treatment.
A good dispensing process, with a number of routine checks including an expiry date check, should be in place and observed every time a medicine is dispensed. Review of the Guide to good dispensing by Pharmaceutical Defence Limited and the Australian Journal of Pharmacy may help you evaluate and improve your dispensing practice to minimise dispensing errors, including the supply of an expired medicine, and save you time and expense.
You also need to leave the manufacturer’s expiry date visible when labelling a dispensed medicine to ensure that patients or clients, carers and/or other healthcare providers have access to this information if needed.
To further minimise the risk of supplying an expired medicine, processes should be in place in the pharmacy for the periodic checking of expiry dates of stock, easy identification of near-outdated stock, and appropriate disposal of any expired stock.
The Board’s website has a number of resources that would be helpful to new pharmacists entering the profession as well as pharmacists at other stages in their career. We've listed some of these below.
Are you an intern preparing for the oral examination? Read the Pharmacy oral examination (practice) candidate guide for important information to aid your preparation.
Planning your CPD for 2018-2019? Take at look at the Continuing professional development (CPD) information webpage.
Keep up to date on Board activities. Read our communiqués.
Read the Board’s newsletters for important information relevant to the practice and regulation of pharmacy.
Which guideline will provide the information I need? Have a look at the Board’s Quick reference guide to Pharmacy Board guidelines to help you identify the appropriate document to read.
Do you have the current editions of all essential reference texts? Take the time to check the Board’s list of reference texts and make sure you have access to the latest editions.
The Board invited state and territory pharmacy premises regulators3 to highlight important issues relevant to pharmacy practice by making a contribution to our newsletter. The following advice is provided to address recent concerns expressed to the Board by the Pharmacy Premises Registering Authorities of Australia.
Barcode scanning of pharmacy medicines is critical to ensuring the greatest level of safety in the dispensing process and has become a professional, community and regulatory expectation. Evidence is available to demonstrate a reduction in selection errors by up to 50 per cent through the use of barcode scanners. Barcode scanning not only protects the public by reducing errors but also protects the pharmacist from the anguish that making a mistake can bring.
Professional indemnity insurance companies strongly advocate barcode scanning.
Pharmacy premises registering authorities in all states and territories unanimously support the process of barcode scanning and many prescribe the presence and use of barcode scanners in all pharmacy premises. In jurisdictions where pharmacy premises regulators do inspections, inspectors will observe the established processes and routines for barcode scanning and encourage pharmacists and pharmacy proprietors to self-audit scanning rates. In several states inspectors actively audit and report on scanning rates during inspections.
Pharmacists should aim for 100 per cent of dispensed items to be scanned.
Pharmacy proprietors, pharmacists in charge and pharmacists share an obligation to ensure that functional barcode scanners are available at all dispensing stations in order for barcode scanning to be performed routinely during the dispensing process in accordance with the Board’s Guidelines for dispensing of medicines.
Scanning prescription barcodes during the data entry process can significantly reduce the likelihood of an input error, and this practice should be encouraged whenever prescription barcodes are available. Data from PDL identified input error as the leading cause of error involving 43 per cent of all incident reports to the organisation in 2017.
Some computer software systems print a barcode on the dispensing label allowing the label and medication to be scanned and matched, an additional step to reduce possible errors.
We strongly encourage you to use documented procedures to support the routine use of barcode scanners.
3 The approval and regulation of pharmacy premises are matters not covered by the Health Practitioner Regulation National Law, as in force in each state and territory and are therefore not the responsibility of the Pharmacy Board of Australia. These matters are the responsibility of pharmacy premises regulators in each jurisdiction.
The Therapeutic Goods Administration (TGA) does not regulate the advertising of health services but if an advertisement for a vaccination service also promotes the use of a therapeutic good it may then become an advertisement of a therapeutic good.
Advertisements for vaccines are subject to the therapeutic goods legislation and must comply with the Act and the Therapeutic Goods Advertising Code (the Code).
The TGA has recently published Guidance for advertisers that outlines what to avoid and what to include when advertising vaccination services.
Access to the Free Interpreting Service for pharmacies has been permanently expanded. Access was previously restricted to ‘dispensing PBS medication’. The Department of Social Services (DSS) has expanded this so that pharmacists and other pharmacy staff can now access the Free Interpreting Service to provide community pharmacy services. In practice this means that pharmacies can use the Free Interpreting Service to:
In addition to the permanent change, DSS will pilot a one-year expansion from 1 July 2018, which will include all activities carried out under the 6th Community Pharmacy Agreement, including:
More information is available on DSS Free Interpreting Service webpage.
AHPRA and National Boards have been working on making it easier to understand the legal obligations of advertising a regulated service, which apply to registered practitioners and people who are not registered, as well as corporate entities.
The latest resources published are a self-assessment tool that helps practitioners and advertisers check and correct their advertising and a testimonial tool to help them understand why testimonials can’t be used in advertising.
The self-assessment tool asks users to consider some questions about their advertising, which can help them understand if it is in breach of the National Law4 and if changes must be made.
The testimonial tool includes information and flow charts to help users understand why testimonials are not allowed and which reviews or feedback can be used in advertising.
In the context of the National Law, advertising includes any public communication that promotes a regulated health service such as all forms of printed and electronic media and a testimonial includes recommendations or statements about the clinical aspects of a regulated health service.
Using testimonials to advertise regulated health services is prohibited under the National Law because they are not usually a balanced source of information, and typically include a narrow selection of positive comments about patient experiences. Also, the outcomes experienced by one patient do not necessarily reflect the likely outcomes for others, so a testimonial doesn’t tell the whole story.
For these tools and other resources, visit the Advertising resources section on the AHPRA website.
4 The Health Practitioner Regulation National Law, as in force in each state and territory (the National Law).
In January, National Boards and AHPRA published a research framework to help transform health practitioner regulation to improve patient safety.
A research framework for the National Scheme: Optimising our investment in research sets out the research priorities and principles for National Boards and AHPRA to focus their research efforts.
The framework includes the priority research areas of: defining harms and risks related to the practice of regulated health professions, regulatory taxonomy or classification scheme, risk factors for complaints and/or poor practitioner performance, evidence for standards, codes and/or guidelines, evaluating regulatory interventions, stakeholder satisfaction and engagement, work readiness and workforce capacity and distribution.
It has been published to provide a solid base to facilitate risk-based research and evaluation activities, with a clear focus on translating the outcomes of research into initiatives that will inform regulatory policy development and decision-making to maximise the public benefit.
New independent research commissioned by AHPRA has looked internationally at vexatious complaints, finding these are very rare and that there is more risk from people not reporting concerns than from making complaints in bad faith.
The report found that the number of vexatious complaints dealt with in Australia and internationally is very small, less than one per cent, but they have a big effect on everyone involved. The research also confirms that the risk of someone not reporting their concerns is greater than if the complaint turns out to be vexatious.
Most of Australia’s 700,000 registered health practitioners provide great care, but patients also have the right to make a complaint when things don’t go so well.
The best available evidence suggests that truly vexatious complaints are very rare, and that under-reporting of well-founded concerns is likely a far greater problem.
There is a common misconception that a complaint must have been vexatious if it resulted in no regulatory action. However, a decision by a National Board not to take regulatory action does not mean that the complaint was unfounded or made in bad faith. For example, a risk to the public may have been adequately addressed between the time the complaint was made and when the investigation concluded.
The report will be used to inform best practice for reducing, identifying, and managing vexatious complaints and helps to identify opportunities to work with others to help reduce their frequency and adverse consequences.
The report is available on the AHPRA website under Published research.
National Boards and AHPRA have completed a scheduled review of accreditation arrangements. The review informed National Board decisions about the assignment of accreditation functions from mid-2019, when the current terms end. All National Boards, except for the Paramedicine Board of Australia, participated in the review.
After considering a range of factors, including the multi-profession analysis and responses to consultation, 13 National Boards decided to continue to assign the accreditation functions to their current accreditation authority for the period 1 July 2019 – 30 June 2024, and in the case of pharmacy, the Board reassigned the accreditation function to the Australian Pharmacy Council.
The National Law sets out the accreditation functions in the National Scheme; these include developing accreditation standards, accrediting programs of study against approved accreditation standards and assessing overseas-qualified practitioners.
National Boards and AHPRA thank stakeholders for their feedback about the current and future accreditation arrangements in the National Scheme, and look forward to continuing work to make the National Scheme as effective as possible.
After public consultation, the Board has published the Guideline - Informing a National Board about where you practise.
In September 2017, the Queensland Parliament passed the Health Practitioner Regulation National Law and Other Legislation Amendment Bill 2017. The Bill contained a set of amendments to the Health Practitioner Regulation National Law (the National Law), as in force in each state and territory except Western Australia. Corresponding legislation has also been passed in Western Australia. These amendments include changes to the information a registered health practitioner is required to provide about their practice arrangements when requested by the National Board (referred to as ‘practice information’).
The guideline will help pharmacists and other health practitioners provide practice information in a way that meets their obligations under the National Law.
AHPRA’s commitment to best practice and learning from others has received a boost, with an official designation from the World Health Organization (WHO) as a Collaborating Centre for health workforce regulation. This designation means that AHPRA, in partnership with National Boards, will work with WHO and its Member States in the Western Pacific to strengthen regulatory practice across the region.
Crucial to the work of the Collaborating Centre is establishing a network of regulators across South East Asia and the Western Pacific. The network is expected to work on improving regulatory standards.
The designation as a Collaboration Centre is timely, with the Australian Government Department of Health and WHO recently beginning a four-year Cooperation Strategy. Strengthening regulation in health services, health workforce, radiation, food safety and health products is an identified priority for the joint work in this Cooperation Strategy. You can access the Cooperation Strategy on WHO’s information-sharing site. Queries about AHPRA’s work as a Collaboration Centre can be directed to WHO_CC_HWR@ahpra.gov.au.
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The National Scheme has made a landmark commitment to help achieve equity in health outcomes between Aboriginal and Torres Strait Islander Peoples and other Australians to close the gap by 2031.
Launched at the Melbourne Museum on Thursday 5 July 2018, the National Registration and Accreditation Scheme Statement of Intent is a joint commitment between 37 health organisations, including leading Aboriginal and Torres Strait Islander health organisations and entities, AHPRA, all National Boards and all accreditation authorities.
AHPRA’s Aboriginal and Torres Strait Islander Health Strategy Group is leading this work, in close partnership with a range of Aboriginal and Torres Strait Islander organisations and experts.
The group shares a commitment to ensuring that Aboriginal and Torres Strait Islander Peoples have access to health services that are culturally safe and free from racism so that they can enjoy a healthy life, equal to that of other Australians, enriched by a strong living culture, dignity and justice.
To help achieve this, the group is focusing on:
AHPRA’s first Reconciliation Action Plan (RAP) was also launched with support from Reconciliation Australia. The RAP is an important document outlining what AHPRA will do to start addressing the imbalance in health outcomes between Aboriginal and Torres Strait Islander Peoples and other Australians.
More information is available in the news item, the Statement of Intent and AHPRA’s Reconciliation Action Plan.