Response 154911570

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Which of the following categories best describes you?

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Individual - consumer
Individual - community pharmacist (employee)
Ticked Individual - community pharmacy owner
Individual - consultant pharmacist
Individual - pharmacy employee (non-pharmacist)
Individual - hospital pharmacist
Individual - other health professional
Individual - retired pharmacist
Organisation - Consumer
Organisation - Pharmacy Representative Body
Organisation - Commercial Pharmacy Group
Organisation - Pharmaceutical Wholesaler
Organisation - Medicines Industry
Organisation - Chemotherapy Compounder
Organisation - Other Commercial Entity
Organisation - Other Health Professional
Organisation - Hospital
Government Entity
Other

Chapter 2: Consumer Access and Experience

OPTION 2-1: PRICING VARIATIONS

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Price disclosure and dollar discount were double whammy to pharmacy. If government wants to set up the price, it should consider the cost of running the pharmacy and come up the reasonable remuneration . I am strongly disagree with panel's suggestion of $9-11.50 which is not enough to cover the operating cost of the pharmacy where rural pharmacy heavily relies on supplying PBS medicines and fees paid by government.

OPTION 2-2: $1 DISCOUNT

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Dollar discount is not saving the significant amount of money to the government as patients who would be eligible for safety net are not taking up discount hence government 's idea of delaying safety net is not working.

OPTION 2-3: PBS SAFETY NET

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1. Regular pharmacy maintains the records for safety net. Secondly the confusion arises due to dollar discount. Previously if you are a concession card holder you need to do 60 scripts to reach safety net . Now it depends on amount spent.

OPTION 2-4: LABELLING

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Current labeling is enough with educating the patient. If we provide more information it would confuse patient more. I have seen after reading literature on the web patient refused to take cholesterol lowering medication.

OPTION 2-5: PHARMACY ATLAS

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The information is already available on the internet via website, Facebook page and even google browser. Most of the time pharmacy in question have enough information.

OPTION 2-6: CONSUMER MEDICINES INFORMATION

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OPTIONS 2-7: ELECTRONIC PRESCRIPTIONS

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OPTION 2-8: ELECTRONIC MEDICATIONS RECORD

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OPTION 2-9: ELECTRONIC PRESCRIPTIONS – CONSUMER CHOICE

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I am not agree with "Online pharmacy ".

OPTION 2-10: MANAGING MEDICINE RISKS FOR PATIENTS UPON DISCHARGE

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Chapter 3: The Role of Community Pharmacy in Medicine Supply

OPTION 3-1: COMMUNITY PHARMACIES – MINIMUM SERVICES

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It depends on what minimum service and are they viable in the particular community setting. One size fits all may not work in all circumstances.

OPTION 3-2: COMPLEMENTARY MEDICINES – SUPPLY FROM PHARMACIES

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1. Well consumer are accessing the complementary medicines in the supermarket without no professional advise.
2. Pharmacist is available on site to discuss any issue. Moving the place won't solve the problem and pharmacy which is already under pressure would have to investment more for this new policy.

OPTION 3-4: SALE OF HOMEOPATHIC PRODUCTS

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This is the choice of end consumer. If pharmacy is not allow to sale the homeopathy so the supermarket should. If the professional are so worried about the efficacy they should ban the production of homeopathy.

Chapter 4: Community Pharmacy Remuneration by Government

OPTION 4-1: ACCOUNTING INFORMATION

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Panel can access more efficient data through ATO . All the pharmacy are legally required to submit BAS and tax. Panel should work with ATO to find out statics.

OPTION 4-2: REMUNERATION TO BE BASED ON EFFICIENT COSTS OF DISPENSING

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it should be enough to cover the operating cost and make a little bit margin.

OPTION 4-3: BENCHMARK FOR AN EFFICIENT DISPENSE

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The recommendation is very low and not enough to cove the cost. Rural pharmacy with strong reliance on prescription would be broke in a year or two with this kind of remuneration. What King panel is suggesting for rural pharmacy?
What was the rational for calculating this price range? what were the assumptions?

OPTION 4-4: REMUNERATION FOR DISPENSING – FORMULA

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It should be enough to cover the operating cost and definitely not $9-$11.50. The fees should be indexed every year to cover inflation.

OPTION 4-5: REMUNERATION LIMITS

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OPTION 4-6: REMUNERATION FOR OTHER SERVICES

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Chapter 5: The Regulation of Pharmacy for Medicine Supply

OPTION 5-1: LOCATION RULES – REMOVAL AND REPLACEMENT

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It would create a cluster of pharmacy in metropolitan area and consumer may have to travel more to get quality pharmacy service. Market would dominate with cheap discounters who are only interested in the retail and profit and lobbying for a long time to remove location rules.

OPTION 5-2: LOCATION RULES – ALTERNATIVE 1 FOR URBAN LOCATIONS

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Pharmacy are widely distributed and easily accessible in the current model. It wouldn't be a good suggestion to abolish a existing working structure to suit a merely economic theory. Removing location rule will not make medication cheaper. It would degrade the pharmacy profession to lowest level. With the same economic theory of free market....1. supermarket ended up in duopoly in Australia 2. Electricity price are highest in the world. These are two classical example of failure of economic theory on which panel is suggesting to remove location rule.

OPTION 5-2: LOCATION RULES – ALTERNATIVE 2 FOR URBAN LOCATIONS

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Current system is more efficient than suggested by the panel.

OPTION 5-2: LOCATION RULES – ALTERNATIVE 3 FOR URBAN LOCATIONS

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If there is any anomalies in the current system improve it with taking stakeholder in the loop.

OPTION 5-3: LOCATION RULES – ALTERNATIVE 1 FOR NON-URBAN LOCATIONS

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What is the rationale behind suggesting the tender process?
As said earlier, tender process would create a monopoly and would break the tested current system.
If the rationale behind merely a economic theory which was failed in the past wouldn't work in this scenario as well.
Has panel estimated the cost for breaking the current system and implementing untested unreliable monopolistic tender process with uncertainty in job (every time tender expires employee would be worried about the job) ?

OPTION 5-3: LOCATION RULES – ALTERNATIVE 2 FOR NON-URBAN LOCATIONS

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Do we destroy the proven system for sack of economic theory?
If there is an anomalies, it could be fixed with taking all stakeholders (PGA and Dept of Health) on the table.

OPTION 5-4: LOCATION RULES – POLICY OBJECTIVE

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The current system proved that it is working efficiently and providing the easy access to all Australian. The study conducted by PGA proves that Pharmacy are more closer compare to medical center in terms of travelling time to access the service in current system.

OPTION 5-5: LOCATION RULES – OWNERSHIP & LOCATION

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There won't be enough population to sustain additional pharmacy.

OPTION 5-6: INFORMATION ON PHARMACY OPENING HOURS

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Government should pay for extended hours and for atlas creation and maintenance.

OPTION 5-7: 24 HOUR PHARMACY INFORMATION AND RELATED SERVICES

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OPTION 5-8: RURAL PHARMACY MAINTENANCE ALLOWANCE

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It would breach the equal access of healthcare to all Australian.
Most of rural pharmacy are very small and RPMA helps to survive. This would lead to closure of several small pharmacy in small community town which are closer to each other.
According to panel's economic theory closure of one pharmacy would lead to more travel to access the pharmacy.
One size fits all doesn't work in all circumstances.

OPTION 5-9: HARMONISING PHARMACY LEGISLATION

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Similar to AHPRA, Australia needs federal level agency to monitor the pharmacy legislation.

Certain big discounter taking advantage of the different regulation across the border and play around and owns more than 200 pharmacies. While regulation in SA states that pharmacist can't own more than 6 pharmacy at a time.

OPTION 5-10: TRANSPARENCY

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It is up to government to publish the data.

OPTION 5-11: EVALUATION MECHANISMS

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QCPP is in place to monitor and accredit the pharmacy.

Chapter 6: The Distribution of Medicines to Community Pharmacy

OPTION 6-1: COMMUNITY SERVICE OBLIGATION REMOVAL, RETENTION OR REPLACEMENT ALTERNATIVE 1

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Current system is work very effectively and with price disclosure government is saving money.

This new model would create more work for pharmacy to deal with and expensive.

OPTION 6-1: COMMUNITY SERVICE OBLIGATION REMOVAL, RETENTION OR REPLACEMENT ALTERNATIVE 2

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OPTION 6.1: CSO REMOVAL, RETENTION OR REPLACEMENT ALTERNATIVE 3

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As long as pharmacy doesn't have to deal with 1000 different suppliers and no added extra cost, review is welcome.

OPTION 6-2: SUPPLY OF HIGH COST MEDICINES

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Cap should be $200.0 for small pharmacies and rural and remote pharmacies. The remuneration is not enough for supplying high-cost medications and locking of GST for a quarter. Prescription Medicine from wholesaler should be GST free.

Chapter 7: Future Community Pharmacy Agreements

OPTION 7-1: SCOPE OF COMMUNITY PHARMACY AGREEMENTS – DISPENSING

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Disagree

OPTION 7-2: SCOPE OF COMMUNITY PHARMACY AGREEMENTS – WHOLESALING

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OPTION 7-3: SCOPE OF CPA – PROGRAMS AND SERVICES

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OPTION 7-4: COMMUNITY PHARMACY AGREEMENTS – PARTICIPANTS

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The agreement should be between PGA and Commonwealth government.
The agreement should be between the supplier Representative (PGA) and consumer representative (Government).
I haven't seen any consumer body directly involved in other sectors.
1. Electricity price and regulation : what is the role of consumer forum?
2. MBS items and doctor gap charge : Has consumer forum involved in discussion between medical association and commonwealth government?
3. Petrol price!! list goes on.
Motto of the story is agreement should be between two parties PGA and Commonwealth government.

Chapter 8: Health Programs Offered by Community Pharmacy

OPTION 8-1: DOSE ADMINISTRATION AIDS – STANDARDS

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Current compensation is not enough to cover the cost.

OPTION 8-2: COMMUNITY PHARMACY PROGRAM – KEY PRINCIPLES

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I am disagree with C. Funding should be available to all pharmacy. Small pharmacy would miss out the payment as the conditions in the tender would be so tight that small pharmacy won't be able to fulfill the conditions.

Chapter 9: Indigenous Medicine Access

OPTION 9-1: ACCESS TO MEDICINES PROGRAMS FOR INDIGENOUS AUSTRALIANS

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OPTION 9-2: ABORIGINAL HEALTH SERVICE PHARMACY OWNERSHIP AND OPERATIONS

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It won't be viable on the long run

Chapter 10: Specific Issues

OPTION 10-1: s100 HIGHLY SPECIALISED MEDICINES

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It would clear confusion.

OPTION 10-2: CHEMOTHERAPY COMPOUNDING – PAYMENTS

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OPTION 10-3: CHEMOTHERAPY COMPOUNDING - UNIFORM MINIMUM STANDARDS

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OPTION 10-4: CHEMOTHERAPY COMPOUNDING PRACTICE MODELS

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OPTION 10-5: GENERIC MEDICINE - LISTING ARRANGEMENTS

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This would discourage pharmaceutical companies to market their products in Australia. Registration with TGA and PBS listing is a very expensive procedure. After TGA registration, if there is no chance of PBS listing, pharmaceutical companies would think about viability of their business. Secondly, even we have unrestricted listing in the current system, supply of stock sometime becomes cumbersome when all supplies run out of the stock. With proposed restriction, we need to be ready for supply shortage very often than usual.

OPTION 10-6: MACHINE DISPENSING

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If new pharmacy got established in the area where community is getting machine dispensing than remote supply should cease.