Real time prescription monitoring – what does it mean for health professionals?

Since at least 2012 there has been an increasing push by Coroners and peak industry bodies in Australia for the implementation of a national real-time prescription monitoring system that alerts doctors and pharmacists to people who are misusing prescription drugs. In excess of 20 Coronial Inquests in NSW, Victoria and Western Australia alone have recommended a real-time prescription monitoring system in an attempt to reduce the number of lives that are lost as a result of overdosing on prescription medications.

The question for health practitioners, and in particular allied health practitioners such as pharmacists, is to what extent it will impact on their professional responsibilities and obligations.

Current status of the system in Australia

In 2013, the Australian Government developed and funded an Electronic Recording and Reporting of Controlled Drugs system (“ERRCD”) and licensed the system to each State and Territory in Australia.  The EERCD aims to provide immediate access to data relating to dispensing by pharmacists of certain controlled drugs, and online access to authorised health professionals of up to date information relating to patient dispensing histories. It is believed that an effective nationwide EERCD will provide practitioners with a clinical tool to minimise the number of patients who are doctor and pharmacy shopping and help practitioners make informed clinical decisions, including early identification of patients who have, or are at risk of, addiction.

Several States and Territories have been actively trialling a system and are diverting increasing funds for its implementation. In April 2016 Victoria announced it was allocating approximately $30million over 4 years to implement its ERRCD system and anticipates it starting in 2018. Whilst the ERRCD system is currently restricted to Schedule 8 medications, such as oxycodone, Victoria is considering expanding the model to include certain other drugs such as diazepam and codeine. This will be particularly relevant given that the Australian Government announcement in December 2016 that certain codeine medication will be available on prescription only by 2018.

In January 2017 Western Australia implemented new regulations which, amongst other things, promote the safe dispensing of controlled drugs and establish the legal framework for the transfer of information about the prescribing and dispensing of controlled drugs through the ERRCD. The ERRCD will require changes to existing ways of practice and will be rolled out in stages. The WA transition to the system, including ongoing training and support to pharmacists and doctors, is expected to be completed by late 2018.

What will it mean for health and allied health practitioners?

In addition to the changes that will need to be made to a practitioner’s administrative and technological systems (for which further training and presumably funding will be provided), evidence of a practitioner’s knowledge and use of ERRCD is likely to have particular significance in coronial, civil and disciplinary proceedings.

A common feature in many of the recent coronial inquests in relation to deaths arising from overdoses of prescription medication, and the disciplinary cases for professional misconduct involving doctors and pharmacists, is the lack of education about the legal and clinical aspects of drugs of dependence and the regulations application in each State. There are often differences between each State and Territory as to the regulations applicable to prescribing (and consequently dispensing) drugs of dependence. Both health practitioners and pharmacists need to ensure they are well educated on the current regulations, and any changes to regulations and practice guidelines, that are made as the ERRCD is implemented in their State or Territory.

Prescribers will also no doubt be expected to have a system in place whereby regular checking of a patient’s dispensing history on the ERRCD is undertaken prior to writing a prescription for a drug of dependence and to turn their mind to whether the patient is addicted, or at risk of developing an addition to the medication. Many practitioners regularly have such a thought at the forefront of their minds, however once an ERRCD system is in place, one would anticipate that evidence of performing such a check will be expected of the practitioner in civil and disciplinary proceedings.

Pharmacists will need to be equally vigilant. As pharmacists must make an independent judgment as to whether a prescription presented is valid, the medication safe and appropriate for a patient, and whether it is consistent with the prescriber’s intention, pharmacists will need to ensure that personal dispensing guidelines are updated to include checking any ERRCD system, and recording and acting upon the results. That may require further enquiries with the prescriber or previous dispensers and/or refusing to dispense medications.

While the additional step in a health, and allied health, practitioner’s practise is adding to the workload of already busy professionals, most would welcome and support the additional tool. The potential benefits to the community in assisting professionals provide their patients the care they require far outweighs the inconvenience. As a whole the profession is actively embracing a nationwide ERRCD system.

However, as every good lawyer and insurer will say, just make sure you keep a record of your knowledge and use of it!

If you would like to keep up to date on  more “serious” issues and developments relevant to professionals follow Julie Somerville on LinkedIn.

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