#336 Use of digital images of paper prescriptions and emergency supply arrangement by pharmacists
24 August 2021
Victorian Department of Health consultation - Image based prescribing
The Federal Department of Health has issued updated fact sheets advising that image based prescribing arrangements will cease from late September 2021. Latest fact sheets are available for prescribers and pharmacists.
To lawfully enable transmission and supply of medicines utilising image-based prescribing (digital images of paper prescriptions) in Victoria, the Secretary to the Victorian Department of Health has issued a public health emergency order (PHEO#4) enabling use of digital images of paper prescriptions. PHEO#4 is due to expire on 27 September 2021.
To lawfully enable the National Health (Continued Dispensing – Emergency Measures) Determination in Victoria, the Secretary issued a public health emergency order (PHEO#2) to facilitate emergency supply of medicines by pharmacists, subject to specified circumstances. PHEO#2 is also due to expire on 27 September 2021.
The National Health (Continued Dispensing – Emergency Measures) Determination remains in force. The latest version is available here.
In the Victorian Department of Health’s telling, previous consultation has indicated that is it important that the State and Commonwealth are aligned in the authorisations to minimise uncertainty and confusion by patients, prescribers and pharmacists. This is required to ensure that the funding of medicines and authorisations to prescribe and supply are aligned.
- Consistent with the federal funding arrangements, the Victorian Department of Health is proposing to not renew PHEO#4 on 28 September 2021. This means use of image-based prescribing (also known as digital image of paper prescriptions) would no longer be lawful from 28 September 2021.
- Consistent with the federal funding arrangements, the Victorian Department of Health is proposing to renew PHEO#2 on 28 September 2021. This means the expanded arrangement for emergency supply of medicines by pharmacists would continue from 28 September 2021.
Alternatives to support telehealth
Use of electronic prescriptions has been in place in Victoria for over 12 months, with the first electronic prescriptions being transmitted in May 2020. The majority of prescribing and dispensing software programs now enable electronic prescriptions. Implementation of electronic prescribing has been led by the Australian Digital Health Agency.
Member feedback requested
The Victorian Department of Health has asked AMA Victoria to advise if we support the proposal to cease PHEO#4 on 27 September 2021 and extend PHEO#2 on 28 September 2021. We are after the views of members in constructing our response.
Our early thinking, contrary to the Department’s proposal, is to request an extension of image-based prescribing for a further six months (until electronic prescriptions arrangements are better established), and to argue for emergency supply arrangements to expire on 27 September (as we have funded telehealth for GPs and a further extension of such arrangements plays into pharmacy scope creep and deferred care).
The Department has further requested that if we do not support its proposal, that we advise how we envisage arrangements would work where there is an inconsistency between the PBS funding of medicines and state authorisations to prescribe and supply. It has also requested that we advise on what options would be available to minimise confusion by patients and health practitioners to address an inconsistency.
Suffice to say, our view is that image-based prescribing has worked well to date and what we are requesting is merely an extension of what patients, GPs and pharmacists alike have been used to throughout the pandemic. For patients (and GPs), we cannot see that this is an issue at all, provided patients get the medication prescribed by their GP. The question of how the Victorian Department of Health reconciles this with its federal counterpart is squarely within its own domain.
If you would like to contribute towards AMA Victoria’s response, please send your feedback through to Senior Policy Adviser, Lewis Horton, at LewisH@amavic.com.au by Monday 30 August 2021.