Decide what pharmacists can prescribe, then set training standards, the AMA says.
Implementing pharmacist prescriber training courses before national standards and guidelines are finalised raises public safety concerns, the AMA says.
The Australian Pharmacy Council set out two options in its consultation paper – leave the current standards as is and let the broader debate play out before revising them, or proceed with updating the accreditation standards now.
AMA President Dr Danielle McMullen said while their submission welcomed the council’s attempt to strengthen its standards, its consultation should pause until the Pharmacy Board of Australia’s (PBA) endorsement was resolved.
“We don’t yet know what the endorsement is going to include, so how on earth will we know what educational standards are required to meet that endorsement?”
It’s not the first time the AMA has raised concerns that pharmacy prescribing expansions have occurred without substantial evidence.
In its scathing June submission to the PBA, it declared pursuing autonomous non-medical prescribing “unacceptable and reckless”.
“We need to step back and make sure that these processes are being done properly and not just rushed through to match up with some state-based programme that’s already out in the wild,” Dr McMullen told The Medical Republic.
“Numerous trials and pilots have been implemented in quick succession before appropriate post-program evaluations could be undertaken,” the submission read.
Updates to the council’s draft standards, which limited enrolment to generally registered pharmacists, ensured qualified supervisors, and clarified that most international models reviewed in its consultation required a postgraduate qualification, were well received by the AMA.
Related
However, three other aspects of the draft also drew the AMA’s concern.
While the APC had undertaken a literature review, the AMA flagged that its analysis did not differentiate between collaborative, protocol-driven or independent models of pharmacist prescribing, or between community and hospital prescribing.
The AMA pointed to a recent Sax Institute rapid review, which TMR reported on last month, that determined while pharmacist-led prescribing could improve medication access, evidence of its clinical effectiveness and safety was weak.
The APC’s own review concluded evidence supporting pharmacist prescribing was strongest in interprofessional, collaborative models of care, as was evidence on safety outcomes – exactly what the AMA said they had advocated for.
“We should avoid cherry-picking approaches from other countries,” the AMA said – especially international models designed for collaborative general practice pharmacists rather than for community pharmacists.
The AMA’s submission referenced the Health Professionals Prescribing Pathway (HPP), which allows greater prescribing authority for non-doctors but requires that any expansion match the drug’s risk, align with the professional’s scope of training, and sit within a clear governance framework defining who’s responsible.
By contrast, the PBA’s proposed endorsement would broaden pharmacists’ prescribing authority to include Schedule 8 medicines – medicines associated with risk of misuse and dependence – but does not specify exactly what pharmacists are allowed to prescribe.
Instead, the PBA recommended pharmacist prescribers self-assess to determine their scope, an approach the APC has similarly adopted.
The council recommended future prescribing programs to help students define and document their scope of practice, yet the AMA says the training gap remains stark.
“Current pharmacist prescribing courses provide only 120‒150 hours of supervised clinical experience. In comparison, medical practitioners gain these critical skills through extensive medical training, which includes a minimum 5,000 hours of clinical experience,” its submission read.
“If the competencies outlined by the accreditation standards are intended to be ‘foundational’, the standards should outline the additional competencies required for pharmacists intending to practise at the higher end of the proposed scope, as well as the associated educational programs and assessment requirements.”
“The proposed one-size-fits-all approach is not sufficiently robust to protect patient safety.”
Thirdly, the AMA said the proposal created a “serious conflict of interest” by allowing pharmacists to both prescribe and dispense medicine, including for colleagues working on the same premises – complications that should have been included in the Learning Domain document and independently assessed.
It also failed to explain how professional practice competencies underpinning safe and effective prescribing, such as managing chronic conditions, clinical governance and continuity of care, would be delivered, monitored and assessed in prescriber programs, the AMA said.
And while the proposed standards addressed conflicts of interest in program design and delivery, they didn’t address the commercial conflicts facing pharmacists as autonomous prescribers, the AMA said.
The revised standards will replace the 2023 accreditation standards for Pharmacist Prescriber Education Programs.
Submissions for the public consultation closed on 3 August, with an interim consultation feedback report due for release shortly.
