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Well,
the CoAG Committee (and the working group to that committee) have
now published their commentary, and the final report is accessible
through the following link: (http://www.health.gov.au/haf/pharmrev
).
However there is no universal national Pharmacy Act model in sight.
I
have long considered that the restrictions imposed by the various
Pharmacy Acts were not in Pharmacy's best interest, and much of
what is in the final report makes good reading.
At
the national level, we have had a model system of a Poison's Schedule
that has been in place for many years. While the states maintain
control of the sale of poisons within their own precincts, state
legislation (with some minor differences) mirrors the national
model.
Are we to have a national Pharmacy Act?
It would make a lot of sense now that there is a basis to establish
one, and it would be a shame if all that governmental effort was
wasted, and dissipated back into the long established parochial
state models.
However,
with the limited enquiry that I have been able to make to date,
it would seem that the states and territories are going to continue
on their independent way, and are producing versions that do not
go anywhere near the scale of recommendations made.
It is also apparently being done in relative secrecy, which seems
to be leading up to a "done deal", with input from a
select group of people only.
Given all the publicity surrounding the original Wilkinson Review,
why the deafening silence now?
The
final CoAG report has a recommendation for a corporate pharmacy
model, which is excellent.
However, the recommendation is tempered by the elimination of
minority shareholders.
This is one of the recommendations that I find difficulty in understanding
.
Only "near relatives" need apply.
My concern is that we have a large group of people with Pharmacy's
interest at heart viz. pharmacy assistants, pharmacy technicians
and pre-registration pharmacists.
All of these people are employees and I find it difficult to exclude
them from having a financial interest in the business in which
they are working.
The concept of employee shares (which have to be divested if you
no longer work in the business) is not new, and needs to be considered.
Considering that this important line of people (excluding preregistration
students) is going to become more qualified through various certificate
and diploma courses, (hopefully with credits attached should they
wish to proceed to a pharmacy degree), why discourage them from
holding a financial interest?
The simple concept of having pharmacies incorporated as "exempt"
companies is straightforward to me. Other writers to this publication
have illustrated an exempt company means legally, a public company
cannot have direct, or indirect interest in such a company.
Surely this approach would remove the conflict predicted in the
final report regarding minority shareholders?
It would certainly remove the tension of a pharmacy wholesaler
structured as a minority shareholder.
This simply could not occur, if the pharmacy corporation had exempt
status.
But why eliminate all minority shareholders?
Are we about to shoot ourselves in the foot again?
It
is reliably reported that most of the states and territories are
going to tinker around the edges and not develop legislation that
might just be exhilarating in allowing full market and business
freedoms, while carefully protecting the profession, and simultaneously
allow only majority pharmacist effective control.
For
example, it seems that NSW might allow the total number of pharmacies
a pharmacist can own, to a maximum of six.
Why not unlimited ownership?
Why not take the plunge across the board and go to the full extent
for everything that the CoAG committee recommended?
Against
this backdrop there was also a whisper that one state may legislate
for pharmacist prescribing.
Now this is an interesting turn of events, and shows some progressive
thought.
In
the UK, pharmacists can become eligible prescribers at two levels
viz as a dependent prescriber or an independent prescriber.
Dependent prescribers are those pharmacists who have accreditation
similar to our consultant pharmacists here in Australia, and practice
in close association with a GP (usually in the same building).
These pharmacists serve a two year "apprenticeship"
by prescribing under a strict protocol, with prescriptions being
signed off by the GP. Independent prescribing comes post "apprenticeship"
and allows for pharmacist initiated prescriptions, again under
agreed protocols.
Clinical
nurse practitioners in most western countries (including Australia)
already have limited prescribing rights. Through the type of training
pharmacists receive, it ought to be a natural progression for
a pharmacist to move into a prescribing stream.
In
Australia, because of the way consultant pharmacy is constructed,
such a move could produce a degree of tension if the consultant
pharmacist/prescriber was the active owner of a pharmacy.
A conflict of interest could definitely emerge, and it is here
that Pharmacy Acts assume importance.
It
is this type of process that should be commented on by the profession
at large, in an open and creative fashion. And what emerges ought
to be able to be incorporated into a national Pharmacy Act model,
for adoption by all states and territories.
When
the Wilkinson Review was undertaken, cognitive services in pharmacy
had not developed to any extent. The Review encouraged their development,
but could not plot many recommendations, because of a lack of
knowledge as to scale and direction.
With the various Pharmacy Acts coming up for review, does this
not highlight a need for a more ongoing process to keep pace with
pharmacy professional development?
The Wilkinson Review also suggested that Pharmacy Boards scale
back their intervention into the business activities of pharmacists
and concentrate only on professional aspects.
This I agree with, because it frees up pharmacists to form a range
of alliances, now necessary for business survival.
For example, I recently read a report where the Priceline chain
of variety stores was going to open its first pharmacy in Victoria.
Obviously this report is a bit exagerated, because Priceline is
a corporation which does not appear to have all of its shareholders
as pharmacists.
Certainly there is a distinct pharmacy "flavour" in
the Priceline presentation, and there may even be some pharmacist
investors involved, but it is my guess that one or more Australian
pharmacists have formed an alliance with Priceline to either lease
space, or take on a Priceline franchise.
The mechanics do not really matter.
I only use the example to illustrate one method of survival, where
the commercial aspects of a pharmacy are delegated or controlled
by an entity with appropriate skills, leaving pharmacists to do
what they do best. It is a useful alliance and a good fit. It
should produce a successful pharmacy model.
Legislation in a number of states would have prevented this from
occurring, so obviously there are some "insiders" who
are aware of impending changes and are gearing up to take full
advantage.
And why not?
My only regret is that the process has not been open and available
to all.
This
article is not meant to be an expert critique on the various Pharmacy
Acts.
It is an expression of frustration that after all this time and
investigation, it may still be some time before we have a national
Pharmacy Act model, a single registering authority, and no shackles
to impede business development.
As a profession, we certainly need to go through a simplification
process, for much of the complexity and frustration of carrying
on the business of a pharmacist, is self inflicted.
Personally, I am anxious to see what impediments may have been
put in place for cognitive services.
Consultant pharmacists need to be given independence, and freedom
to develop opportunity in their own right (not necessarily tied
to a community pharmacy).
We can only wait and see.
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