By Suzanne Greenwood, Executive Director
Patients, community pharmacies and prescribers across the country today are faced with the ever-changing complexity of the PBS with more specialised and high-cost medicines being listed with complex restrictions determining subsidisation. Prescribers and pharmacists are having to adapt work practices and operations to ensure patients continue to receive the subsidised medicines they need while avoiding any unintended non-compliance.
Forgive me a moment as I step up onto my soapbox about this...
Outright, intentional fraud should rightly be frowned upon and the Department of Health is justified in taking the necessary actions needed to address such fraud and reclaim monies. However, recent PBS compliance activities by the Department have focused on unintentional administrative anomalies which is traumatic to the pharmacist and staff involved and can affect patient care.
And this is compounded by the COVID-19 pandemic which has proved to be an enormous challenge for the entire health sector. But throughout the pandemic, community pharmacies have gone to great lengths to stay open and support the primary healthcare of the Australian public.
They have served – and continue to serve - the needs of their community as prescribers transitioned to telehealth arrangements and working remotely.
So, when we combine changes within the PBS with the myriad external factors brought about by the pandemic, we see an often confusing and rapidly evolving situation for both prescribers and pharmacists which occasionally can result in unintended non-compliance.
It is also notable that while the Government’s Provider Compliance Strategy has provider education and support as the foundation, the focus for PBS compliance appears to only target pharmacies. It is the pharmacists who are being penalised for administrative errors that were often due to prescribers unfamiliar with their PBS obligations. In many cases, the issue may be minor but the potential impact on the patient can be huge.
The prescription received by the pharmacy may meet State and Territory requirements, but the failure to educate all health professionals on their responsibilities under PBS law can see an error being made which results in it falling foul of Commonwealth compliance regulations. The options for the patient are to contact the prescriber for a PBS compliant prescription, if that is possible, or pay the non-PBS costs which may be prohibitive, especially for vulnerable or disadvantaged patients. Delays in having a compliant PBS prescription supplied can interrupt a patient’s treatment with potential detrimental health consequences.
And if the pharmacy dispenses according to the intent of the prescriber, then they may get caught up in one of the Department of Health’s compliance activities. This can be a costly error for a pharmacy if the medicine costs thousands of dollars. We know this is happening and it is affecting the businesses of some pharmacies, and also the ability of patients to access medicines. And adding to the frustration is that an inadvertent prescriber error can affect a patient who has otherwise been having prescriptions dispensed successfully for some time.
And pharmacists are not infallible. They too may overlook some requirement and make an unsubstantiated PBS claim. Pharmacists need to continually review their dispensing and claiming processes and make sure staff are aware of their obligations and actioning any alerts provided through PBS Online. However, the bigger issue is making sure that compliant PBS prescriptions are issued in the first place.
The Department needs to act on this and return to the basics of its own Compliance Strategy. As a first step, it must prioritise an education and awareness campaign for the providers – prescribers must understand PBS requirements to ensure that prescriptions are properly written at the outset and pharmacists must understand their responsibilities in assessing and managing any compliance issues at the time of dispensing.
In addition, the Health Department and Services Australia must urgently review and update the PBS Online alerts with input from the sector. Pharmacists have told us how easy it is to overlook a warning, whereas claim rejections prompt urgent attention by dispensary staff.
There are a range of PBS compliance activities undertaken by the Department to determine if there has have been any example of PBS non-compliance. However, such activities should largely be unnecessary if the Commonwealth has provided the promised education and awareness campaign. If providers are educated and the systems work properly, there will be less time spent on administration and more on clinical care.
A potential consequence of the current compliance activities is that if prescribers continue to issue non-compliant PBS prescriptions but pharmacists are more alert and responsive, patients won’t be able to have the prescription dispensed as a pharmaceutical benefit. What could this mean for the patient?
On its website the PBS is described as providing “timely, reliable and affordable access to necessary medicines for Australians”.
To ensure this access is maintained and strengthened the Commonwealth needs to work with the whole sector including prescribers, pharmacists, and medical and dispensing software providers to not only educate and raise awareness of PBS requirements but to ensure that support systems such as prescribing and dispensing software are better enabled to prevent any inadvertent administrative non-compliance.
