The King Review discussion paper has been released, incorporating 140 wide-ranging questions which include the need for Community Pharmacy Agreements, and whether S2 and S3 medicines should be restricted to pharmacy.
The Pharmacy Remuneration and Regulation Review is presented as a discussion of how community pharmacy currently operated, dotted with questions for consideration, rather than recommendations.
“Some stakeholders will see parts of this Paper as contentious and provocative,” the panel wrote.
“That is deliberate. In order to properly analyse the current system of pharmacy remuneration and regulation, existing approaches must be critically examined.
“While many parts of the system will stand up to such close scrutiny, other parts may be revealed as inadequate and in need of reform.”
The panel say that while they have heard about “the excellence of parts of the current system of community pharmacy,” they have also heard from those who are dissatisfied with it, and thus the review is a platform for improvement and, where needed, transformation within the sector.
“While the sustainability and viability of an effective community pharmacy sector is a key consideration of this Review, this is primarily a consumer-focused review that aims to identify which services and programs consumers value from community pharmacy,” they say.
“In developing our recommendations, the Panel will seek to ensure that future arrangements will support reliable and affordable access to medicines by the Australian community and will promote the quality use of medicines.
“The Panel will also consider any future arrangements in the context of the long-term sustainability and equitable distribution of the PBS as a government funded ‘community resource’.”
The Review highlights the unusual nature of the Community Pharmacy Agreements between the Pharmacy Guild and the Government, and queries whether it is consistent with the National Medicines Policy, with the sustainability and affordability of the PBS, and good government practice in terms of value for money, clarity, transparency and sustainability.
It asks whether, if the CPA process is not the best way to organise medicine distribution and remuneration, then what would be a preferable approach?
Community pharmacy programs within the CPA include some professional services that could be delivered by non-dispensing pharmacists, it says.
“Should the CPA be limited to dispensing and professional programs provided by community pharmacy only?” it asks.
It also asks whether it is appropriate for the Government to negotiate formal remuneration agreement agreements with the Guild on behalf of or excluding other stakeholders.
Question Nine asks, “Should the Government move away from a partnership agreement?”
And the Review also asks to what degree it is appropriate that community pharmacies be protected at all from the normal operations of consumer choice and protected in their business operations.
The Review discussion paper examines the way in which pharmacy is remunerated for dispensing – highlighting that some dispensing interactions may not involve a great deal of contact between the pharmacist and consumer, while others require a considerable amount of consultation.
It asks whether dispensing fee remuneration should more closely reflect the level of effort involved – for example, should initial and repeat scripts be remunerated the same?
Issues around high-cost medicines such as the recently PBS listed Hepatitis C drugs are discussed, as are whether there should be limitations on some of the retail products that community pharmacies are allowed to sell. Professional services remuneration is also queried.
“More generally, is there a need for new business models in pharmacy?” it asks.
An examination of the Location Rules is a key part of the discussion paper.
“There are differing views across the sector and in the community on the appropriateness of the current pharmacy location rules,” the panellists wrote.
“Those that support maintenance of the existing pharmacy location rules, argue that they provide pharmacy businesses with the certainty and capacity to allow continued investment in providing a range of high quality pharmacy and related services to the community.
“Others who favour a removal of the pharmacy location rules, argue that they prevent competition in the sector and stifle innovation and consumer choice.
“They note that there are fewer community pharmacies in Australia today than there were in 1988, despite the considerable growth in population since that time.”
The Review queries whether the removal of the location rules with the retention of the current state ownership rules for pharmacies would increase or decrease accessibility and affordability for consumers.
Location Rule 124 – short distance relocation – is examined, with attention to the way it may inadvertently lock pharmacies into specific shopping centres and “transferring effective ownership of the pharmacy approval number to the shopping centre”.
And the S2 and S3 schedules are examined – the Panel heard that requiring consumers to purchase S2 and S3s from pharmacies may limit access to these medicines, though broader access could create some risk.
“Are the current restrictions on the sale of schedule 2 and schedule 3 medicines an appropriate balance between access and health and safety for consumers? If not, how could this balance be improved?”
The Review Panel is now asking for submissions, which can be lodged formally at email@example.com, or forwarded to Pharmacy Review (MDP 900) Department of Health, GPO Box 9848, Canberra ACT 2601.
All submissions will be treated as public and published on the Review website, in the interest of transparency.
A short online questionnaire will also be available (to both consumers and pharmacists) from the Review Website, open until 18 September 2016.
The Review will provide a report to the Minister for Health by 1 March 2017.
Read the full paper here.