Pharmacist prescribing: what the stakeholders said

The Pharmacy Board has now published the individual submissions it received on pharmacist prescribing… revealing doctor and specialist opposition

In its latest communique, the Board says that it encourages all interested pharmacists, stakeholders and members of the public to review the submissions, here. Any further comments can be provided by email to

The Royal Australian and New Zealand College of Ophthalmologists submitted that “in many cases pharmacists do not have the equipment or skill to be able to determine the appropriateness of prescription medications used in ophthalmology”.

“The Pharmacy Board of Australia’s discussion paper refers to education and training considerations however, RANZCO does not support pharmacist prescribing for ophthalmic medications as medical training cannot be condensed into a pharmacy education program or scheduled endorsement,” wrote CEO David Andrews.

As previously reported in AJP, the Royal Australian College of General Practitioners wrote that it strongly opposes all three models of pharmacist prescribing proposed by the Pharmacy Board.

“The RACGP does not support the expansion of pharmacists’ scope of practice beyond their core function of medicine advice and dispensing, into prescribing,” it said.

“The provision of medical services by health professionals lacking the necessary medical training or registration is an inappropriate and unsustainable solution to address the health needs of Australians.”

It said there was a risk that the business needs of a pharmacy could be prioritised over patients’ needs.

Meanwhile the Australian Medical Association said the Pharmacy Board had made “gravely worrying” assumptions, including “the proposal to bypass the nationally agreed process for applications to prescribe; the denial that the proposals represent a significant expansion of pharmacists’ scope of practice; and a lack of acknowledgement that its proposals will impact on the broader health workforce”.

But there was also significant support for the Board’s proposals.

Alfred Health submitted that “there is evidence internationally and locally which indicate that prescribing models for pharmacists must be adopted in Australia to ensure that prescribing is safe, patient-centered, timely, effective, efficient and equitable”.

“We have shown [with evidence included in the submission] that patient care can be improved by having pharmacists, working within the healthcare team, and alongside doctors, taking responsibility for prescribing within their scope of practice.

“These models, implemented and evaluated within Victoria (described as partnered charting) provide the evidence required to support prescribing by pharmacists.”

The Centre for Medicine Use and Safety, Monash University said it preferred the collaborative prescribing model.

“Pharmacists should be allowed to prescribe within their scope of practice to increase patient choice, improve access to medicines, improve continuity of care, and assist in addressing issues confronting the health-care system.

“However, clear governance arrangements are needed covering roles and responsibilities to avoid fragmentation of care.

“A Cochrane systematic review of Australian and international literature suggests pharmacists prescribe as safely and effectively as medical prescribers in both primary and secondary care settings.

“No published evidence suggests that pharmacists as ‘non-medical’ prescribers are not safe.

“Pharmacists should meet the competencies designated for all prescribers. The level of training required for pharmacist prescribers will likely depend upon the scope of practice, the degree of specialisation and consultation skills required and the autonomy in decision making.

“It is likely that a basic level of prescribing training is required even for a limited level of pharmacist protocol prescribing with training broadening out to a post graduate certificate for collaborative and autonomous prescribing that incorporates a period of supervised practice.”

And the Grattan Institute recommended a mixed model.

Pharmacists are “key members of the health teams in hospitals. Improving the ability of the sector to deliver efficient, high-quality care to all is crucial to making Australia’s health system more sustainable,” it submitted.

“Using pharmacists’ skills better – by allowing suitably prepared pharmacists to prescribe – will improve people’s access to health care, facilitate better medication management, reduce costs, and ease the burden on general practice.

“We recommend that pharmacists be allowed to prescribe under all three models proposed in the Pharmacy Board discussion paper: autonomous prescribing, prescribing under supervision, and prescribing under a structured prescribing arrangement.

“Autonomous prescribing should be restricted to pharmacists employed in large hospitals, and prescribing under supervision should be restricted to hospitals and selected larger practices.”

The Board published its discussion paper on pharmacist prescribing, which posed several questions about this potential role, in March 2019.

“The discussion paper was intended to facilitate the profession, stakeholders and the public to explore opportunities for pharmacist prescribing, through one or more of the models of non-medical prescribing outlined in the Health Professionals Prescribing Pathway 2013,” it says.

“The Board is currently reviewing the feedback and will publish a report to inform all interested parties about the views articulated in the broad range of submissions. A publication date for the report has not yet been set and further updates will be provided by the Board in due course.”

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NOTICE: It can sometimes take awhile for comment submissions to go through, please be patient.