Focus on vaccine premise requirements

The Victorian Pharmacy Authority has updated its guidelines on facilities for vaccination services, saying this is a timely reminder on workload and supervision

The latest update on the guidelines on facilities for vaccination services has a focus on premises requirements specific to pharmacies preparing vaccines from multi-dose vials… such as COVID-19 vaccines.

“The vaccine preparation area (in which vaccines from multi-dose vials are drawn up, labelled and prepared for administration) must be away from direct patient contact, distraction and separate from areas that provide other pharmacy services at the same time,” says the VPA in its latest circular.

“This is to ensure that proper attention is given to the activity and to reduce the risk of error.

“Contamination risks associated with the use of multi-dose vials can be mitigated by having a dedicated vaccination preparation area that is clean, hygienic, and uncluttered and by implementing an appropriate cleaning and disinfection schedule.

“VPA inspectors will be inspecting to the updated guidelines on facilities for vaccination services and good pharmacy practice to support compliance.”

David McConville, Chair of the VPA, says that pharmacies are essential to increasing access to vaccination services, which has been “highlighted in the rollout of the COVID-19 vaccination program in approved participating pharmacies”.

“Pharmacists have demonstrated their ability to provide vaccination services to a high standard and it is important that this is maintained with the COVID-19 vaccination program,” he wrote.

“I wish to remind all licensees of their responsibility to make themselves sufficiently aware of the manner in which their pharmacy is being conducted, including the provision of vaccination services, to ensure that it is being carried on in accordance with the law and good pharmacy practice.

“This communiqué also serves as a timely reminder regarding workload and supervision in the context of vaccination services and highlights important considerations when administering different COVID-19 vaccine brands.”

The VPA says that licensees and pharmacists in charge should “regularly assess the impact of vaccination demand on pharmacy workload and implement measures to mitigate the risk of burnout and errors”.

“This is critical with the anticipated surge of COVID-19 vaccines and with that the demand for vaccination in pharmacies.”

Examples of mitigating measures it lists include:

  • Using a booking system and limiting the number of bookings and walk-ins.
  • Employing additional pharmacists and other dispensary staff.
  • Designating specific days of the week to vaccinating when there is an adequate number of trained and qualified staff on duty.
  • Training and delegating staff to manage queries of a non-clinical nature.  

The VPA also asks licensees and pharmacists in charge to consider whether the pharmacy is adequately supervised.

“Consideration should be given to the workload, workflow, and foot traffic of the pharmacy, staffing level and whether adequate procedures are in place to ensure the pharmacy can be adequately supervised whilst vaccination services are being provided, which may be especially challenging in the case of a sole pharmacist operated pharmacy.”

Certain measures may need to be implemented, such as:

  • Rostering or employing additional pharmacist(s) so that there is a sufficient number of pharmacists on duty on designated vaccination days.
  • Using a booking system so that vaccinations occur on days or at times where the pharmacy is not busy or outside of opening hours.
  • Having adequate procedures in place e.g., on how to manage schedule 3 medication requests while the pharmacist is vaccinating.


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  1. Paul Sapardanis

    It is great that the VPA has acknowledged the additional workload that is placed on pharmacists but has failed to put a number on this. I have heard stories of already busy pharmacies undertaking vaccination services without hiring additional pharmacists. This needs to be addressed

    • Maxwell Segal

      I agree. They must put numbers on number of jabs per hour per pharmacist, number of scripts a single pharmacist can do per hour. It’s crazy that some pharmacists are doing 300 and upwards scripts per day without help. It’s a disaster waiting to happen.

  2. Michael Ortiz

    Interesting discussion

    Are GPs and Government clinics required to meet the same criteria?

    I recently completed the Vaccination on line training and there are lots of changes and updates to look out for. Training is comprehensive and practical.

    The booking system in NSW is a shambles. No appointments available for weeks and there are around 20% to 30% no shows.

    I wonder whether it is costing pharmacist money to vaccinate their customers. The pyment is embarrassingly low – some GPs may be milking the system by requiring a Pfizer pre vaccination consultation. The Government pays Pharmacists $16.00 per dose and the booking system schedules 15 minute appointments. If you do the maths payment is $64.00 per hour and the costs of compliance with all the vaccination requirements make it almost impossible for Pharmacists to recover their costs particularly with the Astrazeneca vaccine. GPs were paid $38.00 for an AZ consultation, while Pharmacists were required to provide the same information to patients for free.

    Where is the Guild’s costing study ?

    Did the Guild’s Health Economics Committee sign off on the fee? or did they just fall for the Health Department’s tried and true strategy for the last 30 years of: this is our offer – take it or leave it?

    The Federal Government has a minimum pricing policy for all pharmaceuticals. It pays to the lowest cost and the patient pays the difference. This policy has not been applied to the COVID vaccinations.

    The Guild needs to put together a submission to MSAC setting out an MBS fee for pharmacist vaccination which is cost minimised against the same service provided by GPs. That is, ask for the same payment as GPs for doing the same task. Vaccinations are also routinely given by practice nurses.
    would hope that after the Panademic is over that the Guild will follow up on this issue.

    Based on current advertising , the NSW mass vaccination centres pay $25.00 per hour for admin staff and use nurses award wages (@$35 per hour) to vaccinate and Pharmacists to fill syringes @ $35.00 per hour.

    If you add up all the costs including on costs as well as the time taken to follow procedures, then vaccinations have become a loss leader for community pharmacies.

    As to employing additional staff, it is hard to justify as 3,500 community pharmacies only delivered 100,000 vaccinations a week for the last 4 weeks due to a lack of demand for the AZ vaccine.

    Despite the protestations from the AMA, the sky hasn’t fallen in yet.

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