Tgk1946's Blog

From:
Sent: Tuesday, 2 June 2009 2:37 PM
To: Trevor Kerr
Subject: Re: Notifications

Hello Trevor

A good set of questions there. I can give you the position on each, although it might not be just what you want to hear.

1. Recent changes to the Act.

The changes only relate to a doctor’s requirement for a permit, or more particularly, circumstances where they are authorised to prescribe without one. Pharmacists are entitled to dispense a legal script without verifying that a permit is in place.

My apologies if this bit sounds pedantic, but the situation with Notifications takes a sentence or two to explain. Section 33 of the Act requires medical practitioners to notify the department if they have reason to believe a person is drug dependent. The recent amendments basically didn’t change this requirement (although the circumstances where it is necessary were narrowed). What did happen though is that removing the need for a permit in some circumstances didn’t remove the need to notify, in effect “uncovering” something that has always been there. The department has never been too active in chasing compliance with notifications, so it is likely that they weren’t done a lot of the time. By referring to s33 notifications in the recent communications about the changes it looked like they were something new that had suddenly appeared, but they didn’t.

2. Pharmacist notifications.

Pharmacists don’t have to make s33 notifications. Under s36 though they have to notify when they are called on to supply excessive quantities of S8s. It is common for our records to have s33 and s36 notifications for the same patient over time.

3. Medication review or monitoring at point of dispensing

There is no system in Australia that routinely records medication histories in a way that can be reviewed by either a prescriber at the consultation or by a pharmacist at the time of dispensing. Pharmacy computers are not networked beyond the internal network of a single pharmacy, so there is no capacity to determine if a person presenting a script for, say, tramadol, has received it from anywhere else, or if there is a history of notifications (strictly speaking, in Victoria there is no register of drug dependency, only a record of notifications). If a pharmacist were to call the permits unit here and ask, we would tell them about any permits or notifications, but the information can’t be accessed externally. Since tramadol, anti-depressants and most benzodiazepines are not S8s they don’t require permits so only notification histories would be held by the department.

4. Cross checking OST scripts with other scripts

This effectively doesn’t happen through any routine, automated system. Although methadone and buprenorphine are paid for through the PBS, the reimbursement is done through a mechanism that doesn’t identify the patient. Scripts for other PBS items will be recorded by Medicare for all concession holders, but private scripts are not centralised. Neither the state government or Medicare have any information about the level of supply of private scripts that don’t require permits.

5. Alprazolam

Non-concession, non-PBS Authority scripts won’t be reported back to Medicare so there is no current system to monitor use. Alprazolam lies outside the permit system as well.The pharmaceutical industry has access to wholesaler data and can track these sales down to postcode level, but governments and professional bodies generally don’t have access to these data.

Trevor, the question of how to monitor and minimise the potential for many problematic prescription drugs is one that regulators are very concerned with. But the fact is that until we get a universal system of real-time, on-line medication monitoring it is not possible to achieve the ideal level of control through the existing PBS and permit systems. All states and Territories have, however, joined together to accelerate the development of e-Health systems that should get us to that point. Victoria is taking a lead role in these initiatives, but there are many hoops to jump through before we will be working in the informed environment that you are asking about.

If you want to talk about this a bit more you can call me on the number below.

Cheers

Hi

I do pharmacotherapy prescribing, but I wonder how the changes to the Act affect pharmacists.
Say a person has been notified elsewhere, then turns up later at another pharmacy with a script for tramadol or seroquel.
Does the pharmacist have on-line access to the register at the point of presentation of the script? Or does the pharmacist have to dispense and then notify on the “reason to believe etc”?
I guess the supplementary question is whether those kinds of prescriptions for people on the OST program would be detected by cross-checking on the other register for drug dependency?
Finally, is anyone looking at ways of finding out how much alprazolam is being moved through off-line prescriptions?