The role of the Pharmacy Board of Australia (the Board) is to regulate pharmacists, while keeping public safety at its core. Under the National Law1 the Board is responsible for ensuring that only competent pharmacists are registered and for regulating pharmacists in the public interest.
In 2015, given the developments in prescribing2 the Board set out to consider what implications there are for the public if states and territories were to authorise pharmacists to prescribe. The Board also explored whether it has any regulatory barriers in place that would impact pharmacists’ ability to prescribe in the Australian healthcare setting.
The Board’s work around pharmacist prescribing included mapping current pharmacist capabilities3 and Australian pharmacy curriculums to the NPS Prescribing Competencies Framework 20124, extensive stakeholder engagement and consultation (see Diagram 1: Timeline to position statement).
The three models of non-medical prescribing, as defined by the Health Professionals Prescribing Pathway 2013 (HPPP), were considered:
The HPPP is based on a number of principles including that “health professionals prescribe within their scope of practice and a safe model of prescribing, working collaboratively with the person, their carer(s) (if applicable) and healthcare team for quality care of the person taking medicine.”5
Under the National Law, the Board has no regulatory barriers in place for pharmacists to prescribe via a structured prescribing arrangement or under supervision within a collaborative healthcare environment. However, prescribing under these models requires changes in state and territory medicines and poisons legislation to authorise pharmacists to prescribe and these are matters to be determined by state and territory governments.
The Board’s view is that autonomous prescribing by pharmacists requires additional regulation via an endorsement for scheduled medicines. This would require the Board to make an application to the Ministerial Council for approval of endorsement for scheduled medicines under section 14 of the National Law and to develop a registration standard for endorsement of registration. An application could only occur after completion of preparatory work to develop a case proposing the need for an endorsement as outlined in the AHPRA Guide1. The Board is not making an application for approval of endorsement for scheduled medicines at this time.
Based on the mapping work, the Board is of the view that pharmacists do not need to complete any additional formal post graduate studies to prescribe under a structured prescribing arrangement or under supervision. Any gaps in competencies could be addressed through suitable continuing professional development (a requirement to maintain general registration), by completing short courses and/or local site credentialing. Current pharmacy programs of study may only require minor changes to equip graduates to prescribe via these models.
Successful implementation of pharmacist prescribing via a structured prescribing pathway or under supervision requires an appropriate clinical governance framework to be in place in the relevant practice setting to ensure patient safety. Should pharmacist prescribing progress, the Board will assess the need for development and publication of guidance for pharmacists who prescribe.
To facilitate workforce mobility, a key objective of the National Registration and Accreditation Scheme, the Board encourages national consistency in the approach to any legislative changes to authorise pharmacists to prescribe.
The Board asks the pharmacy profession and stakeholders to consider the following points if progressing any further work relating to pharmacist prescribing:
Refer to our FAQ’s for more information relevant to the Board’s position statement on pharmacist prescribing.
1The Health Practitioner Regulation National Law, as in force in each state and territory (the National Law).
2The NPS Prescribing Competencies Framework 2012 and the Health Professionals Prescribing Pathway 2013 both define prescribing as ‘an iterative process involving the steps of information gathering, clinical decision-making, communication, and evaluation that results in the initiation, continuation or cessation of a medicine.
3Current pharmacist capabilities are outlined in the National Competency Standards Framework for Pharmacists in Australia 2016, published at www.psa.org.au/practice-support-industry/national-competency-standards/
4NPS: Better choices, Better health. Competencies required to prescribe medicines: putting quality use of medicines into practice. Sydney: National Prescribing Service Limited, 2012. Refer to www.nps.org.au/
5Health Professionals Prescribing Pathway 2013
6The Poisons Standard is the legal title of the Standard for the Uniform Scheduling of Medicines and Poisons (SUSMP)
7AHMAC Guidance for National Boards: Applications to the Ministerial Council for approval of endorsements in relation to scheduled medicines under section 14 of the National Law