Just when you thought that ol’ scope of practice thing was licked…
If the regulator is going to allow non-doctors to prescribe, the AMA says, then it has to either mandate collaborative care or risk “catastrophic events”.
AHPRA is currently updating the National Prescribing Competencies Framework, a task which previously fell under the remit of NPS MedicineWise before it was defunded in 2022.
In its public consultation paper, AHPRA described the proposed changes as “minor amendments to a small number of competencies”.
Examples of the proposed changes as laid out in the consultation paper include a new definition of scope of practice and a new paragraph on shared decision making.
Where the current framework describes scope of practice as “the areas and extent of practice for an individual health professional, after taking into consideration the health professional’s training, experience, expertise and demonstrated competency”, the new draft describes it as “influenced by the settings in which they practise, the health needs of people, the level of their individual competence and confidence and the policy requirements (authority/governance) of the service provider”.
The new paragraph on shared decision making defines it as “a consultation process in which a health professional and a person jointly participate in making a health decision, having discussed the options, and their benefits and harms, and having considered the person’s values, preferences and circumstances”.
In contrast, the AMA submission to AHPRA noted that the framework is up for “significant proposed changes” that show “insufficient regard to the potential for inappropriate models of prescribing to emerge, particularly models which fall outside a collaborative model where a medical practitioner has clinical leadership”.
The AMA’s concern related to what it called the “continued use of non-collaborative prescribing models” and its belief that policy should be directed at encouraging models which prioritise safety.
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Basically, the association felt that the proposed changes are a missed opportunity to tackle issues like pharmacist-led prescribing models, which it said were “bypassing established national processes”.
“The framework can be interpreted as a means of non-medical health professionals engaging in independent assessment for the purpose of making prescribing decisions,” the AMA wrote.
“Medical practitioners are currently the only health professionals trained to fully assess a person, initiate further investigations, make a diagnosis, and understand the full range of clinically appropriate treatments for a given condition, including when to prescribe and, importantly, when not to prescribe medicines.”
Association president Dr Danielle McMullen said prescribing models which don’t involve the patient’s usual doctor are the “thin end of the wedge” and could potentially lead to serious patient harm.
“We have concerns that the revised prescribing framework does not sufficiently emphasise collaborative prescribing models, where non-medical prescribers operate in a medically led team,” she said.
“Our position is 100% clear: non-medical prescribers must work in close collaboration with medical practitioners to ensure safe, effective, and evidence-based care.”
The guideline consultation paper also proposed a new competency related to off-label prescribing, which advises prescribers to consider the option “only when a registered medicine is unavailable or inappropriate, there is adequate information available to support use and the potential benefits and risks have been identified, evaluated and documented”.
In its response, the AMA noted that there were additional clinical, safety, ethical, medico-legal and financial factors related to off-label prescribing which must be considered.
Changes to the framework are expected to be finalised before the end of 2025.
