PSA and NPSA release review submissions


The PSA team: (L-R) Chris Freeman, Joe Demarte, Michelle Lynch

PSA advocates for early-career pharmacists while NPSA calls for new funding mechanism to support pharmaceutical wholesalers

Each organisation put in its submission at the eleventh hour, outlining their recommendations to the Review of Pharmacy Remuneration and Regulation panel. AJP summarises the key points below:

Pharmaceutical Society of Australia (PSA)

In submitting to the King Review, PSA National President Joe Demarte says the organisation is “committed to ensuring a viable and robust community pharmacy network.” 

“For these objectives to be realised, Australia needs a community pharmacy network and workforce that is sustainable into the future.

“As a learning profession committed to evidence-based models of care, there are many opportunities to consider innovative ways for pharmacists to enhance service delivery through quality use of medicines.

“That’s why we’re confident that through this Review, the Government will be aware of the full scope of practice and evidence for pharmacists’ expertise and recognise that as a workforce, Australian pharmacists are underutilised.”

Demarte also highlights that up to 60% of Australia’s pharmacists are early-career pharmacists (ECP), representing the highest proportion of community pharmacy employees and the lowest proportion of pharmacy owners.

“Regardless of their roles, ECPs are the group who stand to be impacted most by any reforms and their long-term future is vital to the profession,” Demarte says.

Some of PSA’s key recommendations and positions include:

  • Discretionary discounting by pharmacies, whether independently or through the Government’s $1 discount measure, undermines the universality of the Pharmaceutical Benefits Scheme (PBS) and actively works against the objectives of the NMP.
  • Cost or social circumstances should not be a barrier for consumers to access health services provided by pharmacists. PSA believes that evidence-based, cost-effective community pharmacy services which meet consumer needs should be appropriately supported by the Government.
  • Pharmacist services remunerated by Government should allow for flexibility in terms of service setting to most appropriately meet consumers’ needs.
  • A more appropriate payment model for pharmacist services is one that recognises and remunerates pharmacists based on the complexity of the presenting consumer’s situation and/or services provided.
  • All community pharmacies should aim to meet the heath care needs of their local community through the provision of quality services and advice. PSA does not believe a “one size fits all” approach is appropriate to determine appropriate service provision or pharmacy trading hours.
  • PSA urges the Panel to carefully consider international evidence on the unintended effects of loosening community pharmacy regulations (including location rules, ownership and the State and Territory legislative restrictions on the co-location of pharmacies and supermarkets).

National Pharmaceutical Services Association (NPSA)

Mark Hooper
Mark Hooper, NPSA Chairman

In filing the organisation’s formal submission, NPSA Chairman Mark Hooper says, “The significance of this review for pharmaceutical wholesalers and all those who rely on us for medicines supply across the nation cannot be understated.

“As wholesalers we supply approximately 6,200 different PBS items to over 5,500 community pharmacies and through them to millions of consumers throughout Australia, generally within 24 hours.”

The NPSA says the current model of mark-up and the CSO Funding Pool needs to be updated to reflect current market realities.

“Our submission contains thorough and independent economic analysis of the pharmacy supply chain,” says Hooper.

In brief, the NPSA’s submission positions are as follows:

  • Full line wholesalers play a vital role in the delivery of the National Medicines Policy.
  • The changing regulatory environment has jeopardised the long-term sustainability of full-line pharmaceutical wholesaling.
  • A sustainable funding model is required. NPSA’s independent economic analysis conducted by L.E.K. Consulting demonstrates that there is adequate funding for wholesalers contained in the budget for 6th Community Pharmacy Agreement (6CPA). However, the NPSA’s forecasts of projected PBS expenditure and wholesaler remuneration fall below the government’s budgeted numbers, resulting in a forecast funding gap of $0.4bn to $0.5bn over the life of the 6CPA. Without a change in the funding mechanism, this will result in a substantial shortfall to wholesalers, jeopardising long-term sustainability.
  • NPSA is recommending that the $2.775bn billion in government wholesale and CSO funding should be retained:
  1. The wholesale margin of 7.52% be retained;
  2. A product mark-up floor price of $8.00 – $9.25 be introduced (i.e. a wholesale mark-up of $0.60 -$0.70 per unit);
  3. The CSO Funding Pool be retained at its current level; and
  4. Indexation of the CSO reinstated.

“A change in the mark-up, coupled with a continued and indexed CSO Funding Pool will go part of the way to providing greater stability: sustainable levels of remuneration and an environment into the future in which investment can occur,” concludes Hooper.

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