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Since the Board published its position statement on pharmacist prescribing in October 2019, state and territory governments have authorised increased public access to health services delivered by pharmacists. Services include pharmacists administering a wider range of vaccines and supplying medicines in accordance with local government-approved protocols, which don’t require members of the public to present prescriptions to receive these medications.
New pilots and trials involving pharmacists have been announced by state and territory governments and are at varying stages. Some pilots in community pharmacy have concluded with pharmacists authorised to include these public health services in their scope of practice and to deliver them on an ongoing basis.
The Board has monitored the pilots, trials and health programs involving pharmacists legislated by state and territory governments and confirms that it has no regulatory barriers in place for pharmacists to participate in these public health initiatives.
Changes in local medicines and poisons legislation enable pharmacist participation in pilots and trials or to deliver such health services on a permanent basis. A clinical governance framework in a suitably resourced practice setting and pharmacists meeting their existing continuing professional development (CPD) obligations to maintain competence in their scope of practice enables safe delivery of these health services.
Although the National Law includes provisions to regulate health practitioners using measures such as endorsing their registration to prescribe scheduled medicines (subject to approval by Ministerial Council) the Board does not believe it is currently necessary to pursue such regulatory measures.
The Board will collaborate with government, stakeholders and the public as needed to explore the impact of future developments in health service delivery by pharmacists to support safe practice in the public interest.
The NPS MedicineWise Prescribing Competency Framework 2nd Edition (published April 2021) can be viewed as a description of safe and effective prescribing. It reflects the Australian definition of prescribing and describes the practice expectations of Australian prescribers, regardless of profession. The document states that prescribing is:
“an iterative process involving the steps of information gathering, clinical decision making, communication and evaluation which results in the initiation, continuation or cessation of a medicine”.
When administering medicines such as vaccines or supplying medicines in accordance with local government-approved protocols or over-the-counter medicines, pharmacists are prescribing medicines.
State and territory medicines and poisons legislation may use ‘prescribe’ to describe the action of a practitioner who authorises treatment that may be carried out by another person for example by issuing a prescription, writing a chart instruction or authorising administration.
To prepare and provide prescriptions to patients, pharmacists would need to be authorised though the medicines and poisons legislation in the state or territory where they practise.
Under the National Law, the Board registers pharmacists who are qualified and competent to practise. Pharmacists must hold a suitable pharmacy qualification that is approved by the Board, meet registration standards and other criteria to maintain their registration including completing CPD and maintaining recency of practice in their scope of practice. Pharmacists who prescribe medicines in accordance with the current provisions in legislation of the state and territory where the practice occurs, after completing any education and training stipulated in those provisions (as CPD), are not required by the Board to complete any additional prescribing qualifications or other requirements to maintain their registration.
The National Law includes provisions to endorse the registration of health practitioners if an endorsement is approved for a profession by Ministerial Council. An example is an endorsement for scheduled medicines, where if approved by Ministerial Council, the registration of a health practitioner may be endorsed by the National Board as being qualified to administer, obtain, possess, prescribe, sell, supply or use a scheduled medicine or class of scheduled medicines. The Board has not made an application requesting Ministerial Council to approve an endorsement for scheduled medicines for the pharmacy profession.
The Board has monitored changes in pharmacy practice and the corresponding changes in state and territory legislation that authorise these changes. To date, the Board is not aware of a proposal for additional pharmacist prescribing that would need pharmacists’ registration to be endorsed.
The Board believes that there is scope for states and territories to consider authorising further expansion of pharmacy services that are within the scope of practice of pharmacists, to address identified public need. It also believes that changes in local legislation and a suitable clinical governance framework can ensure that such services are delivered safely by pharmacists. Examples may include authorising prescribing according to additional protocols and administering an expanded range of medicines, for example, long-acting injectable buprenorphine to treat opioid dependence approved in some states and territories.
The Board believes there is also scope for harmonisation in states and territories of legislation authorising expanded pharmacy services and any corresponding education and training that pharmacists are required to complete. This would align with the objectives of the National Scheme including facilitation of workforce mobility across Australia by reducing the administrative burden for health practitioners.
In overseas countries where the standard of pharmacy practice and education is equivalent to that in Australia, some pharmacists are qualified and authorised to undertake broader and more complex prescribing. This includes initiating and/or managing ongoing therapy as part of chronic disease management, without being limited to a locally approved protocol or supervised by another authorised prescriber.
The Board maintains its view stated in its 2019 position statement that proposals for appropriately trained and qualified pharmacists in Australia to undertake some types of prescribing that are broader and more complex may reach the threshold for additional regulation, for example, via an endorsement for scheduled medicines, which would need to be approved by Ministerial Council. The development of such a proposal would need collaboration between, and consultation with, governments (Commonwealth, state and territory), the public, stakeholders, the profession and the Board. A proposal would need to clearly demonstrate that an endorsement of registration is necessary to identify the pharmacists on the register of pharmacists maintained by the Board, who are qualified to undertake broader and more complex prescribing.
If the profession and stakeholders explore new proposals for pharmacist prescribing that align with broader prescribing services that are safely delivered by pharmacists in other countries, the underpinning regulatory and professional requirements and processes that ensure safety and protection of the public should be explored and considered as part of any emerging proposals developed for application in Australia.
In 2022, the Board announced its decision to develop accreditation standards for pharmacist prescriber education programs (accreditation standards) that would qualify and equip pharmacists to prescribe in accordance with any emerging authorisations set out in state and territory medicines and poisons legislation.
The accreditation standards have been developed and are able to be used to accredit education programs that ensure that pharmacists who successfully complete a program, meet all the competencies in the NPS MedicineWise Prescribing Competency Framework (2nd Edition). If proposals for pharmacists to undertake broader and more complex prescribing emerge, that warrant an application to Ministerial Council requesting approval of an endorsement for scheduled medicines for pharmacists, the accreditation standards which would be used to accredit qualifications will be included in an application made by the Board.
The definition of prescribing set out in the NPS MedicineWise Prescribing Competency Framework (2nd Edition) should be used where possible when referring to the prescribing undertaken by pharmacists in clinical practice, noting that this may be different to the definition of prescribing provided in the legislation authorising the use of medicines in each state and territory.
The three prescribing models described in the Health Professionals Prescribing Pathway (HPPP) published in 2013 by Health Workforce Australia used terminology which may be interpreted inconsistently by the profession, stakeholders and the public. Also, the NPS MedicineWise Prescribing Competency Framework (2nd Edition) which all health practitioners who prescribe must meet does not describe these or other models of prescribing.
If inconsistent terminology is used by the stakeholders involved in the design, authorisation and delivery of pharmacy services, this risks confusion, including amongst the recipients of those services.
In its 2019 position statement the Board listed a number of important points that the profession and stakeholders should consider if progressing any further work relating to pharmacist prescribing to ensure that safe, sustainable services are developed that meet public need. The Board maintains that these remain important issues for stakeholders to consider.
The Board remains committed to ongoing collaboration and stakeholder engagement about pharmacist prescribing proposals with safety and public protection as its priorities.