Will paperless scripts impact the services pharmacies offer to residential care facilities? Anthony Tassone says changes are needed if pharmacy is to avoid legal and financial issues
The middle of the calendar year brings with it the Federal budget, and the 2018 Federal budget brought with it several announcements relevant to community pharmacy, including the commitment of $28 million over five years to upgrade the e-prescribing software system.
Whilst on face value this looks to be an encouraging and positive step, the Guild is seeking more information on this and other measures from the Budget.
The Budget papers say this measure is intended to create an electronic prescribing framework that will provide an option for prescribers, pharmacists and their patients to have a fully electronic PBS prescription as an alternative to paper-based prescriptions.
This “paperless” prescription regime is scheduled to be in place from a very specific date – 10 October 2019.
According to the Budget papers: “It will enable prescribers to use clinical prescribing software to issue an electronic PBS prescription as a legal form of prescription. Currently all prescriptions are paper based. This measure gives prescribers and consumers the option of a full digital experience. Their prescription will be able to be electronically transmitted from the prescriber to the pharmacy, reducing the reliance on paper and manual processing.”
The Guild will work to ensure that any e-scripts regime maintains the crucial role of community pharmacy in delivering quality use of medicines for patients, and does not undermine patient choice through prescription channelling.
The issue of paperless prescriptions has relevance across the community sector, including in the provision of medication supply services to residential aged care facilities (RACFs). Guild members have raised concerns regarding the challenges they face in obtaining prescriptions from prescribing doctors to supply Schedule 4 and 8 medications to RACF patients.
The Guild has also received reports from pharmacies being expected and, in some cases, even demanded from RACF staff to supply a prescription only or controlled medicine in the absence of a prescription or an oral order from the prescriber.
Whilst RACF staff may be in an awkward position themselves wanting to ensure continuity of supply and navigating challenges of prescribers who have provided a valid order, this still places the pharmacy in a very invidious position. Namely legally if they do not have a valid order from the prescriber, professionally in not wanting to disrupt the continuity of care, and financially in the case of medicines that attract a PBS subsidy.
Looking into obligations
Unfortunately, there has been a lack of progress in this area, and the Guild is approaching this matter as a priority to have a sensible and pragmatic solution that ensures community pharmacies abide by their legal obligations, that continuity of patient care is assured, and pharmacies are appropriately remunerated for the services being provided.
Recently the Victorian Branch of the Guild convened a meeting of Guild members with extensive knowledge and experience in serving RACFs to advise on the best course of action in the going forward to ensure that the Guild’s advocacy work is aligned with the best possible outcomes for members and their patients.
During the meeting, there was unanimous agreement that the current situation is untenable with unreasonable expectations for community pharmacies to maintain continuity of care, particularly when there is not a valid prescription or order
The Guild has received reports from members who have come under scrutiny by both State and National regulators regarding the validity of an order for supply of prescription only or controlled medicines to a resident of a RACF who would have otherwise risked consequences in management of their chronic condition or potentially hospitalisation.
Community pharmacy cannot continue to carry the can financially, professionally and legally in servicing RACFs. Changes must happen and are overdue.
The National Residential Medication Chart (NRMC), a paper-based medication chart that was developed by the Australian Commission on Safety and Quality in Health Care was aimed to ‘improve the safety of medication management in Australian residential care facilities through standardised medication charting and improved medication management practice.’
The NRMC also enables the supply and claiming of most PBS/RPBS prescriptions directly from a resident’s medication chart, not requiring a separate, hard copy of a PBS prescription.
The use of NRMC is not mandatory and has generally had a poor uptake as it’s perceived as burdensome by RACFs and prescribers. In addition, the exclusion of Schedule 8 medicines and pharmaceutical benefits requiring an authority has meant that even when the NRMC is implemented by a facility, the anticipated benefits are not fully realised.
The Guild’s objectives
As part of the Guild’s advocacy, we are calling on aged care providers and the state and federal governments to improve the functionality of the NRMC (including use of suitable electronic versions) and support its adoption and implementation to provide maximum patient benefit and safety including;
- safer medication delivery with reduced errors;
- a consistent approach to medicine prescription, administration and supply;
- a reduction in form duplication and administration costs.
Representations have been made to the Federal Minister for Health, Greg Hunt regarding the poor uptake of the NRMC and the exceptions that limit its use. His office has responded that:
“Although the use of fully electronic NRMC systems for PBS prescribing is not yet an option in Australia under existing legislation, it will be facilitated through the implementation of a broader electronic prescribing initiative. Electronic prescribing will enable the prescribing, dispensing and claiming of PBS medicines in a seamless electronic manner, including within the aged care setting.”
The response from the Minister’s office goes on to say;
“The National Digital Health Strategy anticipates there will be digitally enabled paper-free options for all medication management in Australia by 2022. My Department is currently considering the PBS regulatory and technical frameworks that would enable the safe and secure use of an electronic prescription as an alternative to a paper prescription or medication chart (including the NRMC).”
Which makes the Guild’s interest in electronic prescribing very topical and relevant in the delivery of services to RACFs. Whilst such innovation and advancements are encouraging, the timeline for digitally enabled paper-free options by 2022 is not immediate enough to resolve the very real issues confronting pharmacies right now in servicing RACFs.
The promise of a paperless prescribing future has the potential to bring great benefits for patients and all the health professional team, but we must understand how and when this will be implemented to ensure it resolves the challenges currently being faced in practice.