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27 October 2011

Changes to General Rules in the Pharmaceutical Schedule

PHARMAC is pleased to announce amendments to the General Rules of the Pharmaceutical Schedule from 1 November 2011. This proposal was the subject of a consultation letter dated 19 August 2011. In summary, the effect of the decision is that:  Pharmacists will be able to annotate a prescription with a Specialist endorsement where they have evidence that the patient has a Specialist recommendation and is eligible for subsidy, without requiring a counter signature or endorsement from the prescriber. Pharmacists will be able to amend the presentation of the pharmaceutical dispensed, without requiring a signature from the prescriber, but only when it is not practicable to dispense the presentation prescribed. Removal of Part II 2.2 in the General Rules. This would result in certain pharmaceuticals having restrictions on what uses they will not be subsidised for. These restrictions follow the current rules applied under Part II of the General Rules Removal of 4.8 of the General Rules, Amendment of Schedule

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Details of the decision Some minor amendments have been made to the Pharmaceutical Schedule General Rules to help reduce the administrative burden for both pharmacists and prescribers. The changes will come into effect from 1 November 2011. Pharmacists will be able to annotate a prescription where they have evidence that a patient is eligible for subsidy via Specialist recommendation, without requiring a counter signature or endorsement from the prescriber. Where the pharmacy has an electronic record of an endorsement from a previous prescription written by the same prescriber, i.e. Specialist recommendation, then the pharmacy may annotate the prescription accordingly. Where a Specialist recommendation has not been completed by the prescriber and the pharmacy has no record of a previous Specialist recommendation, pharmacists may obtain the name of the recommending Specialist verbally and annotate and initial the script with the requirements for subsidy i.e. Specialist name and date of recommendation along with a note that the prescriber has been contacted. Pharmacists will be able to amend the presentation of the pharmaceutical dispensed, without requiring a signature from the prescriber, even where it is an increased cost to DHBs. This can only occur when it is not practicable to dispense the presentation prescribed. Any annotation would not be able to override any other Schedule restriction. This rule change is intended to allow pharmacists to provide a funded product when an out-ofstock occurs for a particular presentation of the product without requiring the prescriber’s signature or notification from PHARMAC. Pharmacists will be required to annotate the prescription with the reason for the amendment for audit purposes. The intent of this change is to reduce the administrative burden for pharmacists and prescribers and its effects on the market are to be monitored.

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Part II 2.2 of the General Rules will be removed. This will result in certain pharmaceuticals having restrictions added on which uses they will not be subsidised for. These new subsidy restrictions follow the intent of the current rules that are applied under Part II of the General Rules. Please refer to pages 23-24 of the November 2011 Update for further information. Feedback received We appreciate all of the feedback that we received and acknowledge the time people took to respond. All consultation responses received by 9 September 2011 were considered in their entirety in making a decision on the proposed changes. Most responses were supportive of the proposal, and the following issues were raised in relation to specific aspects of the proposal:

Theme Concern over the electronic recording of the annotation under the patient notes section within pharmacy dispensing software Comment As the pharmacy software systems are not capable of recording the data at this time in an appropriate format, it would be appropriate that the current electronic recording of Specialist recommendations and date of recommendation be considered a sufficient electronic record. Pharmacists are required under the Health Practitioners Competency Assurances (HPCA) Act to work within their clinical capabilities and when they feel an action is outside of their competency to not proceed, hence this should be the basis of their clinical judgment. As this was not consulted upon, nor have the financial implications been assessed, not appropriate to implement at this time.

Pharmacists would appreciate clear guidelines around the boundaries of acceptable behaviour to facilitate clinical decision-making in regards to altering the presentation of the pharmaceutical dispensed Further suggestions for pharmaceuticals which could be annotated by pharmacists in case of missing endorsement

More information If you have any questions about this decision, you can call our toll free number (9 am to 5 pm, Monday to Friday) on 0800 66 00 50.

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