Guild submission to Pharmacy Review

Date: 30 September 2016

The Pharmacy Guild of Australia has made a series of recommendations to the Review of Pharmacy Remuneration and Regulation that would deliver improved patient outcomes and sustain local community pharmacies into the 2020s and beyond.

The Pharmacy Review is being conducted by a three-member panel appointed by the Federal Government under the terms of the Sixth Community Pharmacy Agreement (6CPA). The Guild submission is in response to the Discussion Paper issued by the Review Panel in July.

Community pharmacies enjoy very high levels of public trust and support. Time and again, qualitative and quantitative research has confirmed that community pharmacies consistently meet the needs and expectations of consumers. 

The Guild strongly supports the tried and tested community pharmacy model, which is underpinned by Location Rules that ensure that Australians have high levels of accessibility to medicines through a well-distributed network of community pharmacies that are owned by pharmacists who have a professional obligation to deliver quality health outcomes for their patients.

However, there is always room for improvement.  The sensible approach is to maintain and build upon a system that works well, so that it works even better in the future.  Accordingly, the Guild sees the Review as an opportunity to demonstrate and build on the benefits of the existing community pharmacy model, which is one of the most successful and sustainable parts of our health system.

Some of the recommendations made by the Guild are:

  • Retention of the five-year community pharmacy agreements negotiated between the Federal Government, which represents the interests of taxpayers and consumers, and the Pharmacy Guild which represents the owners of the community pharmacies who finance the privately capitalised infrastructure required to deliver the PBS, the RPBS and related medicine services to the public.
  • The Federal Government should fund an ongoing campaign to raise public awareness of the role of community pharmacy as a trusted health destination, and the availability of pharmacy services.
  • The Federal Government should use the Primary Health Networks (PHNs) to provide incentives for local community pharmacies to coordinate emergency after-hours patient access to PBS medicines and other critical community pharmacy services.
  • In the interest of PBS universality, the community pharmacy-funded optional $1 discount should be abolished.
  • There should be a thorough review of all PBS Patient Co-payments and Safety Net Threshold levels to ensure that PBS medicines are affordable for consumers.
  • Future community pharmacy agreements must reinvest a fair proportion of the savings from PBS reforms into ensuring that the core clinical role of dispensing remains viable and is remunerated at a level that reflects the cost pressures on community pharmacies.
  • The sustainability of the medicines supply chain must be ensured by fully expending the funding for wholesalers committed to in the 6CPA, through a wholesale mark-up floor and retention of the Community Service Obligation (CSO).
  • The Federal Government should fund a fee-for-service Opiate Dependence Treatment (ODT) program for eligible community-based patients delivered through community pharmacy to reduce patient barriers to access.
  • For greater efficiency and patient care, the National Diabetes Services Scheme (NDSS) supply and remuneration model should parallel the supply arrangements of the PBS.
  • The Federal Government should immediately take responsibility for the national implementation of a real-time recording system for Controlled Drugs (e.g. Electronic Recording and Reporting of Controlled Drugs – ERRCD).
  • In order to receive Federal Government funding, all pharmacist-delivered professional services must be uploaded to an e-Health record to ensure coordinated patient care.
  • The Federal Government should fund a fee-for-service minor ailments program in community pharmacy that uses a recordable pharmacist-only medicine schedule.
  • The Federal Government should allow community pharmacies to order a standard range of pathology tests and renew prescriptions in line with best practice for patients receiving ongoing therapy for stable conditions.
  • To provide equity, enhanced patient access, improve uptake and maximise herd immunity, community pharmacies should be funded to administer scheduled vaccines listed on the National Immunisation Program (NIP) Schedule (and should record vaccinations directly to the Australian Immunisation Registers) on a level playing field with other health professionals. 
  • The Continued Dispensing arrangements for urgent PBS medicine supply should be expanded to include other medicines used to treat chronic health conditions, with a requirement to inform the prescriber consistent with the current arrangements.
  • Community pharmacies should be funded to become local health hubs where there are health gaps due to demonstrated shortages of GPs and other health professionals.
  • To improve patient access, all PBS medicines should be available under the Closing the Gap (CTG) PBS Co-payment Measure and eligibility should be linked to the patient’s Medicare Card enabling Aboriginal and Torres Strait Islander patients to receive CTG prescriptions from all prescribers.

On the future of community pharmacy, the Guild submission makes clear that the predicted growth in the number of Australians living with complex, multiple morbidities, means that the clinical health role of community pharmacy in maximising medicine adherence and the quality use of medicines will be increasingly important.

As is occurring in other countries, more and more community pharmacies will specialise in providing medicines and broader health services, support and advice for patients with specific chronic health conditions, addressing the needs of their local communities.

The focus of community pharmacies on particular chronic health conditions will align with consumers’ increasing demand for holistic health solutions. Informed and empowered consumers will seek out health providers that are able to organise and deliver solutions that are likely to encompass a combination of prescriptions, pharmacy-only medicines, over-the-counter and complementary health products, medicine-related services, health and wellbeing support, and remote and in-pharmacy health monitoring.

As well as playing an enhanced role in chronic disease management and the delivery of broader health solutions, the community pharmacy of the future will increasingly become a preferred location for the treatment of minor ailments, vaccinations, preventive health, health checks and risk assessments, self-care and the tackling of health and lifestyle issues.

The submission is available at

Media enquiries: Peter Waterman 0419 260 827 Greg Turnbull 0412 910 261

Contact: [Squiz] Iain Simmons

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