Response 411709075

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Which of the following categories best describes you?

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Individual - consumer
Ticked Individual - community pharmacist (employee)
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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If would be fairer if there was one price for consumers. However, pharmacies purchase medicines from wholesaler at different prices due to their associations with buying groups where they can get substantial discounts. In order for there to be a single price to consumers, there has to be a single price for pharmacies. Unless there is a system where the government tenders out the price for drug molecules like NZ, it will be difficult to establish such a system. Such system would be good but allowing the patient more preference e.g. different brands would be ideal as patient can have allergies to excipients.

OPTION 2-2: $1 DISCOUNT

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The PBS is supposed to be help eliminate inequalities and inequities between individuals. If only some pharmacies can afford to offer these $1 discount (due to purchasing drugs in bulk from wholesalers at discount), it defeqts the aim of the PBS. Also in terms of medicines access, rural pharmacies are unlikely to offer the $1 discount because they already struggle to remain profitable so it’s unlikely they would be willing to offer the $1 discount, once again leading to inequalities between rural and metro areas. Additionally the $1 is coming from the pharmacies profitability so whether a pharmacy decides to pass on the discount due to their business model is going to affect whether a patient can access this discount. Not to mention, a patient is worse off getting these discounts if they reach the safety net at the end of the year as it will take longer to reach the safety net. An electronic safety net linked to a patients Medicare card where a patient could automatically be placed into the safety net once they reach an annual limit irregardless of which pharmacy they attend would be the most fair solution.

OPTION 2-3: PBS SAFETY NET

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All above options are valid. The current safety net system has become too complex are years of additions and modifications and the purpose of it has slowly been lost. Although probably unaffordable, a system like overseas where children and seniors don’t pay for medications would simplify the system. Otherwise an electronic system where a patient can easily understand how many scripts they need to achieve before reaching the safety net would be ideal as most patients have no idea how much more they need to get to reach be safety net. Additionally, it is a convoluted system to collect stickers if you purchase prescriptions from multiple pharmacies.
Although the electronic system sounds excellent, simplifying the system back to the basics would really aid consumers.

OPTION 2-4: LABELLING

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Having consistency between different drug companies in the order, location, size and appearance of medication boxes would helps. Similar to how boxes are currently labelled with “pharmacy medicine”, “pharmacist only medicine” and “prescription medicine”. In terms of patient safety, the worse thing is when medication boxes look similar and are for completely different purposes so a colour coding system for different disease states e.g. red box for heart and pictures on the box would help a pharmacist to identify quickly if the wrong medicine was being given out. Additionally all pharmacist medicines and prescription medicines should have an area indicated by a box where a prescription label can be attached. Too often are pharmacists forced to cover up important information on boxes and bottle because the manufacture has not left space on the box for a label. Furthermore, it would be ideal if the medication boxes had indications in layman’s terms on the box for what medications are for so consumers don’t get confused what the purpose of the medication is for. Too often I meet patients who have no idea what their medicines are for and this is a worrying sign. Although some people might argue that this would be bad for some medications e.g. on a box of sildenafl, it would say erectile dysfunction, it would be quite easy to cross out the indication with a black permanent marker at the patients request. This would help reduce medication error and maybe even lead to a patient picking up on an error if the medication wasn’t for the indication the doctor had mentioned.

OPTION 2-5: PHARMACY ATLAS

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Agreed but website should be integrated with CMIs, consumer information and also atlas finder for doctors. Ideally this website would all patients to book appointments with doctors. Anything that helps patients access the systems and healthcare is going benefit our economy.

OPTION 2-6: CONSUMER MEDICINES INFORMATION

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This would be an excellent idea. However this website would ideally include resources for patients as well. Although there are existing resources such as the better health from Victorian state government, there is no single source of information from the federal government for consumers. Something like the UK NHS webpage combined with the pharmaceutical society of Australia’s self care pamphlets where consumers could go look up a reliable source of information which had references to journals would be ideal as it would lead to a lot less patients going to GPs saying dr google said this. Additionally patients could be encouraged to visit this page to help reduce visits to pharmacies and doctors for simple information but also know when it would be a good idea to visit one would help triage patients better; helping to reduce the burden on taxpayers. A single portal to access CMI through the same website would really help consumers. Furthermore, a health information website will help improve health literacy for patients. Furthermore, manufacturers should be force to update information on these CMIs as some information as not been updated for years although changes have occurred. Additionally an online directory portal for health professionals and prescribers (e.g. doctors, nurses, dentist etc) with links to recommended databases and how to subscribe to them (e.g. AMH, crush or not mims, complementary medicines interactions guide) to find information relevant to Australia would help reduce medications errors.

OPTIONS 2-7: ELECTRONIC PRESCRIPTIONS

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An electronic prescription service which integrates to electronic health records would help reduce medication error. Currently when a patient leaves hospital, they are given a discharge prescription. many times when a patient is given a script which is difficult to read, has errors doesnt meet legal requirements etc, so the benefits of such a system would be numerous. However this system needs to be integrated into doctors prescribing software and pharmacies dispensing software as well as real time monitoring systems for pseudoephedrine and opioids and other drugs of addiction. Previous systems where you have to log into an online portal are not user friendly and no health professional is going to access these systems voluntarily to make clinical decisions unless they are easy to use and in the forefront. Therefore it is imperative to involve all stakeholders and ensure such system is integrated and planned for from the outset. Also the system needs to be opt out for patients because unless everyone uses it, no health professional will transition to such systems. Additionally the patient needs to be able to pick up an electronic prescription up from anywhere, perhaps with some form of ID. E.g. how would a family member pick up a prescription? Maybe using their own Medicare card and if they want to allow someone else to pick up the prescription they could specify that they have given prior approval via an online portal or a pharmacy could help set it up with express consent. Unless the electronic system is as versatile as a paper system, prescribers and pharmacist will not use it. Additionally prescribers should be allow to say patients can pick up medicines from one pharmacy only in certain cases e.g. staged supply/ opioids

OPTION 2-8: ELECTRONIC MEDICATIONS RECORD

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Agreed. Such system needs to be opt out and integrated into prescribers and pharmacists dispensing software. E.g.for pharmacy dispensing software when you press the history button it should not be a separate area for prescriptions from your own pharmacy and another area for scripts dispensed elsewhere. It should bring up everything and let you filter it out. Otherwise such system is not useful to pharmacists as if it takes longer than a few minutes to find the information you are trying to find, no ones is going to use it

OPTION 2-9: ELECTRONIC PRESCRIPTIONS – CONSUMER CHOICE

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Patient shouldn’t have to ask to direct a prescription to a pharmacy. Should be a system where the patient presents with some form of ID (Medicare card) or electronic authorisation (e.g. through online portal linked to Medicare card - also could be set up by any health professional).
This is of course unless the prescriber has a valid reason fir directing the patient to a particular pharmacy e.g. staged supply.
The system needs to be integrated into real time monitoring and prescribing/dispensing software.

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

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An Australia wide protocol with local protocols for getting patients from hospital to community safely so nothing gets missed in between needs to be set up. This protocol should establish who is responsible for what.

Chapter 3: The Role of Community Pharmacy in Medicine Supply

OPTION 3-2: COMPLEMENTARY MEDICINES – SUPPLY FROM PHARMACIES

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Unless there is evidence based medicine to support the complementary medicines

OPTION 3-4: SALE OF HOMEOPATHIC PRODUCTS

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Option 3-3 wasn’t able to be commented on, thus doing it here.

In regards to S2, S3, there needs to be standardisation between state legislations. When patients visits QLD they always question the need to label S3. For ease to patients, there should be a national standard on how S2 and S3 request are dealt with. Patients do not understand why one pharmacist will refuse to supply something and another will supply (e.g. chlorsig - antibiotic resistance) so creating as much standardisation will help improve accessibility to medicines.

Chapter 4: Community Pharmacy Remuneration by Government

OPTION 4-4: REMUNERATION FOR DISPENSING – FORMULA

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Focus on remuneration should be less focused on per a prescription item and more about holistic patient care and patient outcomes. As it stands at the moment in pharmacy, pharmacist are not remunerated for their time, which they should be. For example, what is the motivation for a pharmacist to do their job well and counsel a patient so they fully understand their disease, what medicine they are being given and how to take it when they won’t be paid for their time and quality of counselling. The current system encourages pharmacist to dispense more scripts. In order to optimise patient outcomes, the current remuneration system should continue to reimburse pharmacist for medications at a fair rate, covering cost e.g. hiring pharmacy assistants, but also encourage pharmacist to use the skills they are taught at uni and spend quality time with the patient helping them to achieve optimal outcomes.

Chapter 5: The Regulation of Pharmacy for Medicine Supply

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

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

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The purpose of pharmacy location rules were to ensure equal access. Removing the location rules as per option 5-1 would lead to a buildup of pharmacies in cities and a reduction in rural areas. However the current system is not ideal. A PLB would help ensure equality.

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

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

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OPTION 5-4: LOCATION RULES – POLICY OBJECTIVE

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OPTION 5-5: LOCATION RULES – OWNERSHIP & LOCATION

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However, allowing a corporate such as coles or Woolworths would not help competition. Look st what happened with petrol prices once the duopoly infiltrated the market. Medicines are not a commodity and should not be treated like such

OPTION 5-6: INFORMATION ON PHARMACY OPENING HOURS

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

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OPTION 5-9: HARMONISING PHARMACY LEGISLATION

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With so many state legislations, this often leads to confusion for patients as well as pharmacists (e.g. interstate scripts for certain classes of drugs with more restrictions). Also destroying controlled drugs differs between different states.

OPTION 5-10: TRANSPARENCY

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OPTION 5-11: EVALUATION MECHANISMS

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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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Chapter 7: Future Community Pharmacy Agreements

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

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

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Government should take a bigger role in regulation of wholesaling. As it stands at the moment, independent pharmacies cannot survive as chemist warehouses get unfair terms from wholesalers. The independent ‘local’ pharmacy where patients knew their pharmacist is slowly being eroded. Unfortunately this from anecdotal evidence led to better patient outcomes as patients were happier to discuss their personal information leading to better counselling.

Chapter 8: Health Programs Offered by Community Pharmacy

OPTION 8-1: DOSE ADMINISTRATION AIDS – STANDARDS

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OPTION 8-2: COMMUNITY PHARMACY PROGRAM – KEY PRINCIPLES

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Chapter 9: Indigenous Medicine Access

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

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Should linked to Medicare card and automatically applied. Have had patients write CTG on the script themselves rather being endorsed by the prescriber. It should be up to Aboringinal community elders to identify those of ATSI descent, not health professionals to police it

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

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As long as a pharmacist is in charge of daily running of the pharmacy and is able to make clinical decisions.

Chapter 10: Specific Issues

OPTION 10-1: s100 HIGHLY SPECIALISED MEDICINES

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OPTION 10-5: GENERIC MEDICINE - LISTING ARRANGEMENTS

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Agreed. There should be an option of getting an exception to the listen generic if the patient has a particular problem (e.g. allergic to excipients, generic tablet size is too large and can’t swallow etc) if necessary

OPTION 10-6: MACHINE DISPENSING

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With the current technology, it would be difficult to setup such system with the risks. Although a big role of pharmacies is the supply of medicines, who would be responsible for checking interactions, safety and appropriateness of a medicine etc. a pharmacist role is more than a dispensing robot, there is clinical component. Until such risk can be overcome, even a trial would be risky for the government. Who would be responsible if a patient died because no one counselled a patient that the medication was once weekly dosing :
(Methotrexate). Unless the government wants blood on their hands, more research is required