Here’s an update on a few of the issues AMA Victoria is working on for members, including:
SafeScript changes: proposed requirement to contact other prescribers
Conversion practices review: AMA Victoria submission.
SafeScript changes: proposed requirement to contact other prescribers
As noted last week, the Department of Health is reviewing the Drugs, Poisons and Controlled Substances Regulations ahead of their remake in 2027. The Department is proposing that, after checking SafeScript, prescribers would be required to take reasonable steps to contact other prescribers identified in SafeScript where it shows recent prescribing of the same or similar monitored poison, and to document those steps if they proceed to prescribe.
Thank you to members who have already provided feedback. That input is informing AMA Victoria’s submission.
Feedback to date has centred on this proposal. Members consider that a requirement to take steps to contact other prescribers identified in SafeScript, and to document those efforts, is unlikely to be workable in routine care, particularly in post operative, emergency and after hours settings. There is concern this would operate as a compliance task rather than a clinically meaningful safeguard.
Members have also pointed to ongoing issues with SafeScript itself, including limited clinical context, gaps in information, and access and integration problems. There is a consistent view that any expansion of obligations should follow improvements in system performance and usability.
The review also covers tighter controls on supply of monitored medicines, including medicinal cannabis, expanded permissions for other practitioner groups to possess and administer medicines, and changes to storage and record keeping requirements.
We are continuing to develop our submission and welcome further feedback, particularly on how the SafeScript proposal would operate in practice.
Please send comments/feedback to [email protected] by Sunday 5 April.
Conversion practices review: AMA Victoria submission
AMA Victoria has provided a submission to the Victorian Law Reform Commission’s focused review of the Change or Suppression (Conversion) Practices Prohibition Act 2021.
AMA Victoria supports the objective of the Act. Conversion practices are harmful and have no place in healthcare. The issue is how the Act operates in practice, particularly in psychiatric care.
A central issue is the boundary between prohibited conduct and legitimate therapy. Psychiatric care commonly involves exploring and challenging a patient’s thoughts and feelings, including distress, identity and conflicting views. That is ordinary therapeutic work. The concern is that the current drafting does not clearly distinguish this from prohibited conduct.
Our submission identifies section 5(2)(b) as the key issue. The exclusion for conduct that is “necessary” to provide a health service creates uncertainty. There can be significant discussion about whether a treatment is necessary and by whom. This may restrict what can be discussed in a consultation. We have proposed that “necessary” be amended to “when clinically appropriate” to better align with how care is provided in practice.
The review also considers awareness and understanding of the Act. There is evidence of low awareness among health practitioners and limited understanding of what constitutes a change or suppression practice. Clearer articulation of the boundary, supported by practical guidance, would assist.
The Act includes significant criminal penalties. Our submission notes the concern with penalties of that kind where the boundaries of permitted clinical practice are not clear.
AMA Victoria’s position is that the objective of the Act is sound. The issue is clarity in clinical settings. The submission supports refinement, including clearer drafting of section 5(2)(b) and guidance that distinguishes prohibited practices from ordinary psychiatric assessment, treatment and exploratory therapy.
Members can contact [email protected] with any further views.