AMA Victoria continues to oppose the Community Pharmacist Program and its expansion. Our position has been consistent. Prescribing is a medical act. The CPP raises ongoing concerns about patient safety, clinical accountability, continuity of care and commercial conflicts of interest.
In that context, and noting developments at both levels of government, we have declined to participate in the Department of Health and Safer Care Victoria CPP Expert Advisory Committee. With the introduction of the Pharmacist Board’s prescribing standard at the federal level, and the state government’s active promotion of “Chemist Care Now”, we were concerned that formal participation could reasonably be construed as endorsement of the program itself.
At the same time, the government has been explicit that the CPP will proceed. It is an election commitment, with dedicated funding and budget allocation. Against that reality, AMA Victoria has taken the view that there is some value in providing limited, offline feedback on specific protocols where patient safety and continuity of care are clearly at risk.
Our recent feedback on the revised UTI protocol reflects this approach. While reiterating our opposition to the CPP, we raised concerns about the degree of clinical judgement expected of pharmacists in managing risk, weighing treatment options and identifying alternative diagnoses. These are decisions that, in general practice, rely on diagnostic training, clinical experience and access to longitudinal patient information.
At the same time, we again cautioned against the substitution of rigid flowcharts for clinician-led assessment. Protocols and decision trees cannot safely replicate diagnostic reasoning, particularly where patients present with undifferentiated symptoms or complex backgrounds. In practice, the CPP protocols oscillate between requiring pharmacists to exercise medical judgement on the one hand, while constraining that judgement through oversimplified flowcharts on the other. Neither approach provides a safe or accountable model of care.
This builds on our earlier feedback on CPP expansion protocols, which identified broader and recurring issues. These include pharmacists being required to assess undifferentiated presentations, unclear medico-legal accountability, inconsistent communication with general practice, unrealistic infrastructure expectations, and the transfer of unresourced follow-up burdens to GPs when patients re-present with complications or unresolved symptoms.
Our intent in providing protocol-level feedback is not to legitimise the program, but to press for safeguards that reduce harm where a program is proceeding regardless. This includes clearer exclusion criteria, mandatory referral pathways, and stronger, more reliable information sharing with general practice.
We recognise there is a balance to be struck. We remain open to member views on whether even this limited form of engagement is appropriate, and would revisit our approach if there is strong sentiment that AMA Victoria should not participate at all, even through protocol-level feedback. What has not changed is our opposition to the CPP itself, and our refusal to lend it legitimacy through formal advisory roles.
Members are encouraged to contact [email protected] with feedback or questions.