Response 735863561

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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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Ticked Agree
Disagree
make a comment
Agree however the price set has to be commercial and take into account all the factors in dispensing the prescription ie. the technical time in assembling the medication and also the time taken to counsel the patient. It can't be just a set fee based on a robotic process as this doesn't take into account the time taken to counsel the patient which is the most valuable and under-funded part of the dispensing process

OPTION 2-2: $1 DISCOUNT

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Ticked Agree
Disagree

OPTION 2-3: PBS SAFETY NET

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Ticked Agree
Disagree
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However it can only be made more transparent by a universally accessed eHealth record which currently seems to be difficult to implement

OPTION 2-4: LABELLING

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Ticked Agree
Disagree

OPTION 2-5: PHARMACY ATLAS

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Ticked Agree
Disagree
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The Guild already has such a database accessible by the public. Some government funding to fill any gaps would be preferable than re-inventing the wheel

OPTION 2-6: CONSUMER MEDICINES INFORMATION

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Ticked Agree
Disagree
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Totally agree however the fee to provide these has to be commercial. The cost and time taken to print these and then the counselling process has to be built into the fee

OPTIONS 2-7: ELECTRONIC PRESCRIPTIONS

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Ticked Agree
Disagree
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Totally agree. It all starts with GP's. However if GP's are to be paid an incentive to write prescriptions electronically then Pharmacy's should also be paid an incentive to dispense prescriptions electronically

OPTION 2-8: ELECTRONIC MEDICATIONS RECORD

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Ticked Agree
Disagree
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Totally agree. The current eHealth record has been slow and cumbersome to roll out, has cost the ta payer billions of dollars and is nowhere near being universally used. There needs to be an enquiry on who should be held accountable for this current disaster which is urgently needed.

OPTION 2-9: ELECTRONIC PRESCRIPTIONS – CONSUMER CHOICE

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Ticked Agree
Disagree
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eRx already exists and allows consumer choice. Just find a way to get rid of the piece of paper that is now needed to access the electronic prescription portal. Should be quite simple

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

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Ticked Agree
Disagree
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The current hospital discharge system is a danger to our society. I have personally visited a post-discharge patient. She had been discharged at 7pm on a Friday night. She was elderly, frail and home alone. She was discharged on warfarin which she had not been on previously. There was no dose in any of the paperwork. The dose written was "Dose according to INR result" Thankfully I was there to ring the hospital and track down a doctor who had to find the paperwork to give me an indication of the dose. The next day I made an appointment for this patient with her GP. Without Pharmacist intervention this patient may have at worst died, or at best been re-admitted to hospital costing the tax payer thousands of dollars. The needs to be Pharmacist funding for post-hospital medication management plan in the patients home. This would prevent many of the re-hospitalisations that are occurring daily

Chapter 3: The Role of Community Pharmacy in Medicine Supply

OPTION 3-1: COMMUNITY PHARMACIES – MINIMUM SERVICES

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Ticked Agree
Disagree

OPTION 3-2: COMPLEMENTARY MEDICINES – SUPPLY FROM PHARMACIES

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Agree
Ticked Disagree
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Many consumers are turning to complementary medicines as either and adjunct or alternative to managing their health. Many consumers are using them for preventative health which is to be encouraged as it will save our health system billions in the future Pharmacy's are the best possible place to sell complementary medicines as Pharmacists have the knowledge on not only the complementary medicine but also how it may interact with any GP prescribed medications they may be on. However it is not the role of Pharmacy to be a regulatory arm of the TGA. If the TGA deems these complementary medicines can be sold to the Australian public then the sole responsibility of the Pharmacist is in advising if they would be suitable for a particular condition and any reasons why a patient shouldn't be taking them. It is then up to the consumer to make an informed decision as opposed to buying these same complementary medicines from supermarkets where there is no such advice available. There can be no precedent to impose a regulation on Pharmacy if the same regulation is not imposed on supermarkets selling the same products

OPTION 3-4: SALE OF HOMEOPATHIC PRODUCTS

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Agree
Ticked Disagree
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Completely disagree and I think completely beyond the scope and expertise of the review panel to comment on whether complementary medications should or should not be stored in any particular area o the Pharmacy.
Homeopathic products are a consumer choice and again I believe beyond the scope of the review panel to make recommendations that limit consumer choice.

Chapter 4: Community Pharmacy Remuneration by Government

OPTION 4-1: ACCOUNTING INFORMATION

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Agree
Ticked Disagree
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The Pharmacy Guild has ample data for the construction of the dispensing fee. Also the Review panel shows little understanding or chooses to ignore the that the most critical part of the dispensing process is the Patient/Pharmacist interaction and the counselling and advice provided to the patient. How can you "determine a set of accounting principles" that determine the price of all the information that is given to the patient in the counselling process. This is a professional service and the professional service fee, although inadequate, is built into the dispensing fee. This is the human face of Pharmacy that the Review Panel does not put a value on and cannot be determined by a set of accounting principles

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

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Agree
Ticked Disagree
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Option 4-2 is ludicrous and again assumes the dispensing process is just the putting together of the medication. As above, this option completely shows no understanding of the complete dispensing process and puts no value on the counselling aspect of dispensing, and the importance of the Pharmacist interaction with the patient.
The most efficient process would be to have medications available from vending machines. If this is what the Review Panel would like dispensing to look like then we better start building bigger hospitals.

OPTION 4-3: BENCHMARK FOR AN EFFICIENT DISPENSE

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Agree
Ticked Disagree
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How can the panel suggest a dollar value based on "best practice dispense". What is the citeria for this? Who sets the criteria? What value has been put in this number for the Pharmacist/Patient interaction?
Option 4-3 clearly states "given the data limitations" yet still has the audacity to suggest a figure for "best practice dispensing". This option needs to be deleted as it is basically a figure plucked out of the air with no basis.

OPTION 4-4: REMUNERATION FOR DISPENSING – FORMULA

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Agree
Ticked Disagree
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The Review Panel shows no understanding of dispensing being a professional service . This Option needs to be deleted

OPTION 4-5: REMUNERATION LIMITS

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Agree
Ticked Disagree
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There is no evidence that this option will present better value to the tax payer that the current system which has factored in billions of savings over many years

OPTION 4-6: REMUNERATION FOR OTHER SERVICES

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Agree
Ticked Disagree
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To make this recommendation without specific examples again shows the Panel has a lack of evidence that some of the recommendations that it is making are better options for the Australian Taxpayer

Chapter 5: The Regulation of Pharmacy for Medicine Supply

OPTION 5-1: LOCATION RULES – REMOVAL AND REPLACEMENT

Please select one item
Agree
Ticked Disagree
Make a comment
The current location rules have served the country well. Pharmacies are more accessible than GP's or supermarkets

OPTION 5-4: LOCATION RULES – POLICY OBJECTIVE

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Agree
Ticked Disagree
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The only modification that needs to be made is the shopping centre rule which is effectively making the Pharmacist a hostage to the Landlord

OPTION 5-5: LOCATION RULES – OWNERSHIP & LOCATION

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Agree
Ticked Disagree
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There is strong and healthy competition in the Australian Pharmacy market. There has never been more consumer choice or more price competition. There is no evidence that in changing the location rules will provide more choice or a more efficient medicine distribution service

OPTION 5-6: INFORMATION ON PHARMACY OPENING HOURS

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Ticked Agree
Disagree
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The Pharmacy Guild already has this service which just needs to be enhanced , not re-built. The Australian public need to be made more aware of this

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

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Agree
Ticked Disagree
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What good is information given over the internet at 2am in the morning if there is no-where open to purchase that medicine?
Again this option shows a lack of understanding of patient outcomes.
A far better option is for government funding to be made available to encourage more 24 hour Pharmacies in Urban and Regional centres. This will never cover the whole population ae remote regions won't be able to access these Pharmacies easily but an internet solution is no good unless a patient has access to the medications

OPTION 5-8: RURAL PHARMACY MAINTENANCE ALLOWANCE

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Ticked Agree
Disagree

OPTION 5-9: HARMONISING PHARMACY LEGISLATION

Make a comment
Neither agree nor disagree with this as there are benefits with both systems. Again evidence needs to be provided that changing the system will provide better outcomes

OPTION 5-10: TRANSPARENCY

Please select one item
Agree
Ticked Disagree
Make a comment
The only lack of transparency is the lack of data being collected by government to evaluate the success.
Is there an evaluation of how much the PBS saves the hospital system?

OPTION 5-11: EVALUATION MECHANISMS

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Agree
Ticked Disagree
Make a comment
Public polls consistently show Pharmacists as in the top 3 of trusted professionals. The undermining of Pharmacy is not by the community, it's by the regulators and bureaucrats that want to change a system that is one of the best in the world with no evidence that what they are proposing will enhance the health of Australians at a better price.

Chapter 6: The Distribution of Medicines to Community Pharmacy

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

Please select one item
Agree
Ticked Disagree
Make a comment
The CSO provides certainty that the wholesalers will deliver PBS medications subject to specified criteria
However Point C is valid as the High Cost Low Margin drugs are playing havoc with Pharmacy cashflow

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

Please select one item
Ticked Agree
Disagree

OPTION 6.1: CSO REMOVAL, RETENTION OR REPLACEMENT ALTERNATIVE 3

Please select one item
Agree
Ticked Disagree
Make a comment
The current CSO is working well

OPTION 6-2: SUPPLY OF HIGH COST MEDICINES

Please select one item
Ticked Agree
Disagree

Chapter 7: Future Community Pharmacy Agreements

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

Please select one item
Ticked Agree
Disagree

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

Please select one item
Agree
Ticked Disagree
Make a comment
Not sure what benefit this option would provide as the PBS is about the delivery of medicines to the Australian public and the supply chain is a critical part of this

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

Please select one item
Agree
Ticked Disagree

OPTION 7-4: COMMUNITY PHARMACY AGREEMENTS – PARTICIPANTS

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Agree
Ticked Disagree
Make a comment
The Pharmacy Guild is the representative body of the majority of Pharmacies in Australia. It has a greater role in maintaining the viability of the Pharmacy network throughout the country so they can continue to deliver PBS medications to the Australian public.
The other groups have more self-interested reasons for being part of the negotiations and hence should not be included.

Chapter 8: Health Programs Offered by Community Pharmacy

OPTION 8-1: DOSE ADMINISTRATION AIDS – STANDARDS

Please select one item
Ticked Agree
Disagree

OPTION 8-2: COMMUNITY PHARMACY PROGRAM – KEY PRINCIPLES

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Agree
Ticked Disagree
Make a comment
These programmes need to be funded from within the PBS as they add value to the distribution of medications. Agree that they need evaluation and a set of principles.
These programmes need to be accessible to the whole of the Australian public so tendering or negotiating with s certain Pharmacies will not achieve this. They should form part of CPA's and rolled out as part of the total PBS service.

Chapter 9: Indigenous Medicine Access

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

Please select one item
Ticked Agree
Disagree

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

Please select one item
Agree
Ticked Disagree
Make a comment
There has to be enough evidence that an AHS can provide a better service than an existing Pharmacy otherwise there is a duplication of services and an added cost to the taxpayer.
If there is no Pharmacy servicing an area then rather than create another government agency for service provision, a better outcome would be to provide financial incentives for the existing pharmacy to improve it's reach of service

Chapter 10: Specific Issues

OPTION 10-1: s100 HIGHLY SPECIALISED MEDICINES

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Ticked Agree
Disagree

OPTION 10-2: CHEMOTHERAPY COMPOUNDING – PAYMENTS

Make a comment
Once again there needs to be evidence that shows the outcome to the patient before any decision to change is made

OPTION 10-5: GENERIC MEDICINE - LISTING ARRANGEMENTS

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Agree
Ticked Disagree
Make a comment
This option would be a disaster for the Australian public. Limiting the number of generics sounds good in theory but when out of stocks occur then there are no alternatives with disastrous consequences.
Price disclosure has done enough to get generics at the least cost to the PBS. Further cost cutting or tendering for a generic is disastrous when out of stocks occur .

OPTION 10-6: MACHINE DISPENSING

Please select one item
Agree
Ticked Disagree
Make a comment
The value in the dispensing process is the Pharmacist/patient interaction and there is no evidence dispensing machines allow this to happen.