FIFTH COMMUNITY PHARMACY AGREEMENT CONSULTATION FIFTH COMMUNITY PHARMACY AGREEMENT: OVERVIEW OF STAKEHOLDER CONSULTATION ACTIVITIES TO 30 JUNE 2014 5CPA component Consultation activity With whom Timeframe Action taken in response 5CPA programmes Consumer views on the services and advice provided by pharmacies to consumers; The location of pharmacies; Issues relevant to competition between pharmacies; and Increased accountability of pharmacy owners for the professional pharmacy services provided to consumers. CHF December 2009 – December 2010 Advice provided informed policy options and negotiations for 5CPA. Advice sought on patient eligibility for the MedsCheck and Diabetes MedsCheck pilots PRG December 2010 – June 2012 Inclusion of ‘improved adherence’ to the aims of the programme. Use of broad patient eligibility criteria initially for the pilot that could be refined to inform the national roll-out. Added ‘significant medical event and complexity/type of administration’ as an additional indicator to number of drugs included. The interim evaluation report was provided to the PRG on 1 February 2012 for comment. Further consultation may be undertaken following finalisation of the evaluation in April 2012. Medication Use Reviews (MedsCheck) and Diabetes Medication Management Service (Diabetes MedsCheck) Two stage testing functionality of the Assessment Tool PSA AACP Guild Practising Community Pharmacists June 2011 and July 2011 Feedback incorporated into Assessment Tool. Consultation on community pharmacy software requirements MSIA Finalised mid 2012 Developing vendor resource documents to inform possible open source software solutions linking dispense and claiming functions of the planned system. Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Home Medicines Review (HMR) Development of new direct referral pathway to HMR PSA Guild AACP Other stakeholder consultations under 4CPA HMR research project December 2008 – October 2011 December 2008 – Ongoing PRG Guild AACP State and Territory health departments RACP APHA ACSQHC SHPA AGPN Public consultation HMR (and other MMR programmes) changes PRG April 2013- ongoing Provide advice to inform options to restructure the HMR (and other MMR Programmes fee structure) to support programme sustainability and integrity. HMR research project to collate and assess evidence in order to recommend better targeting of HMR patient eligibility criteria SHPA PSA Guild PRG March 2013 – ongoing Joint involvement in development of RFT Ongoing input into project outcomes. Development of requirement for RMMR services to be collaborative (referred by a general practitioner) PSA Guild Other stakeholder consultations under 4CPA RMMR research project May 2010 – October 2011 The change to require all reviews to be collaborative was implemented on 1 October 2011. Home Medicines Review (HMR) Residential Medication Management Review (RMMR) Development a hospital referral pathway for HMRs. HMR hospital referral pathway stakeholder consultation workshop 29 June 2012 2 Implementation of a new direct referral pathway to HMR from 1 October 2011. Update of existing professional practice guidelines to incorporate the new referral pathway by PSA. A consultation paper was released on 9 December 2011 and submissions closed on 20 January 2012. This paper was developed with input from PRG, and 75 submissions were received. Summary of the consultation responses provided to PRG for information on 19 April 2012. Further stakeholder consultations will be undertaken prior to finalisation of a HMR Hospital Referral Pathway. . Two hospitals selected (in Hobart and Melbourne) with the Department ready to commence, pending agreement on a commencement date with the Guild. A staggered national implementation is planned, which will be informed by data from the two initial sites. Current as at 30 June 2014 5CPA component Rural Pharmacy Workforce Rural Pharmacy Maintenance Allowance Consultation activity With whom Timeframe Action taken in response Development of policy changes to separate RMMR services from Quality Use of Medicines services. May 2010 – October 2011 PSA Guild Other stakeholder consultations under 4CPA RMMR research project Splitting payments for RMMR and QUM services from 1 October 2011. Update of the existing professional practice guidelines to incorporate changes to the RMMR programme. Provide feedback as it arises. Consultation with AHREN, PSA and PRG undertaken. Changes resulting from update to PhARIA classification implemented in July 2012. Exceptional circumstance criteria under development by Guild for 1) Rural and Remote Continuing Education Allowance 2) Rural Intern Training Allowance 3) Intern Incentive Allowance for Rural Pharmacies. 4) Rural Student Placement Allowance. August 2012 PRG members asked to seek views from their members/organisations regarding unforeseen impacts from 1 October 2011 changes to RMMR programme PRG Eligibility changes to a number of elements of RPWP resulting from PhARIA update and restrictions to PhARIA 2-6 ARHEN PSA Guild Pharmacy academics from various universities 2011 – Ongoing Advice on programme implementation, transitional arrangements and exceptions for the Rural Pharmacy Continuing Professional Education Allowance and the Rural Pharmacy Student Placement Allowance PRG December 2011 – January 2012 Development of an updated model, in the context of a changing rural index Guild DHS University of Adelaide 3 Late 2010 – July 2012 Consultation undertaken over mid 2011 January 2012. Advice provided to PRG on 19 April 2012 regarding changes to RPWP. Implementation complete and pharmacy owners advised where RPMA eligibility has not continued. An exceptional circumstance process is being managed by the Guild. Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Section 100 Support Allowances to Remote Area Aboriginal Health Services (AHS) Consultation on potential changes to programme arrangements PRG Guild Other stakeholder consultations under 4CPA evaluation of Indigenous pharmacy programmes Over 250 attendees at the Indigenous Joint Forum 2010-11 – Ongoing QUM Framework to support rural and urban Aboriginal Health Services Indigenous Joint Forum held in Melbourne on 26/27 March 2012 provided opportunities for further consultation with all delegates (over 250 delegates attended). Joint Forum outcomes have been collated, consolidated and considered by QUMAX Reference Group and the 5CPA PRG. No final decisions regarding programme changes have been made. Consultation on the recommendations from the Senate inquiry into the supply arrangements of PBS medicines to remote area AHSs (which included consideration of support arrangements) PRG November 2011 ongoing Government is in the process of finalising its response to the Senate inquiry recommendations. Consultation on potential changes to programme arrangements PRG Guild Other stakeholder consultations under 4CPA evaluation of QUMAX programme Over 250 attendees at the Indigenous Joint Forum 2010-11 – Ongoing Updated programme arrangements have been implemented. Indigenous Joint Forum held in Melbourne on 26/27 March 2012 provided opportunities for further consultation with all delegates (over 250 delegates attended). Joint Forum outcomes have been collated, consolidated and considered by QUMAX Reference Group and the 5CPA PRG. Taking into account the findings from the 4CPA evaluation of QUMAX, consultation on changes to the QUMAX programme QUMAX Programme Reference Group, made up of: DoHA Guild NACCHO PSA Ongoing 4 The new QUMAX programme model has been developed in the context of input from all stakeholders and implemented. QRG met on 14 February 2012 and 8 March 2012 to discuss QUMSP and NACCHO State Affiliate support arrangements post 30 June 2012. QRG met on 22 June 2012 – QUMSP and NACCHO State Affiliate support arrangements extended to 31 December 2012. From 1 Jan 2013, online education and training resources are being implemented to assist participating Aboriginal Health Services with their application, workplan and reporting requirements. Further assistance will also be available through Guild and NACCHO telephone hotlines. Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Pharmacy Practice Incentive (PPI) and Accreditation PPI: Clinical Interventions by Pharmacists Consultation regarding priorities for programme funding under 5CPA Broad stakeholder input through PPSAC 4CPA Research & Development Steering Committee and 4CPA Research & Development project (PROMISe). October 2008 – May 2010 Inclusion of Clinical Interventions as a priority programme area in 5CPA. Activities to support the roll-out of the PPI Programme under 5CPA PSA, with Expert Reference Group involvement, including Guild, SHPA, APESMA, ACP, APC, AACP, PDL, CHF, RACGP, AGPN, AMA, NPS, Carers Aust, ASMI September 2010 2011 Development of Professional Standards and Guidelines and online educational resources by PSA. PPI: Support for the Provision of Dose Administration Aids Consultation about the evaluation of the 4CPA DAA/PMP Programme Broad stakeholder input under 4CPA DAA/PMP evaluation. September 2007 – June 2009 Inclusion of a DAA component in the 5CPA. PPI: Staged supply support allowance Consultation about the 4CPA review of Staged Supply regarding implications for community pharmacies in the administration of Staged Supply of PBS medicines. AMA CHF State and territory health departments SHPA ANCD diverse range of other stakeholders February 2010 – 2011 Inclusion of Staged Supply component in 5CPA. Consultation on activities to support the roll-out of the PPI Programme under 5CPA PSA with Expert Reference Group involvement. September 2010 – 2011 Development of professional Standards and Guidelines and online educational resources by PSA. 5 Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Development of a Community Pharmacy Service Charter December 2010 – June 2011 PPI: Funding to support the Accreditation System and roll-out of Additional Programmes to Support Patient Services ACSA AHPA APESMA AACP AGPN AHPRA AHRC AMA ANF ASMI Carers Australia CHF Council of the Ageing NACCHO NAPSA NEDA NPS NRHA PSA PBA SHPA ACSQHC Guild 6 Convened a workshop in December 2010 to discuss how to tailor the Australian Charter of Healthcare Rights to be suitable for a community pharmacy setting. Draft concepts for the Community Pharmacy Charter were developed and distributed for wider consultation and comment. The Community Pharmacy Service Charter was finalised and implemented in June 2011. Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Research and Development Workshop to inform 5CPA research priorities and identify a list of potential projects for research focus under the 5CPA Approximately 175 participants attended a workshop representing a wide range of stakeholders that included: professional and industry organisations, government, peak bodies and consumers. The Advisory Panels comprise representatives from the following organisations: PSA CHF ASMI SHPA AACP AMA RACGP Illuminate Health Consulting NRHA Health Consumers of Rural & Remote Australia PBA The George Institute for Global Health NMHCCF March 2010 and April 2011 A number of research priority areas were recommended, including six that were subsequently funded under the 5CPA programme: Mental Health Professional Integration (Collaboration) Rural Health Literacy Consumer Needs Chronic Illness The Rural project has subsequently been discontinued. Inclusion of a further Research and Development project on HMR Patient Eligibility Guild March 2013 October 2013 Commencement in October 2013 of HMR Patient Eligibility project. Review of the Existing Supply Arrangements of PBS Medicines in Residential Aged Care Facilities and Private Hospitals under 4CPA Aged care sector Private hospitals Medical practitioners Nurses Pharmacists Residents and patients September 2009 Inclusion of ‘Medication Charts’ initiative in 5CPA. Informing policy parameters of initiative. Initiative Development Meetings Guild DHS OACQC ACSQHC August 2010 – October 2012 Supply and PBS claiming from a medication chart in Residential Aged Care Facilities Establishment of Advisory Panels to oversee the research projects. Advisory panels select tenders and provide advice and guidance on the individual research projects. 7 Development of a public consultation paper. Identification and resolution of policy issues in relation to programme design and implementation. Agreement on elements of the programme that required broader consultation. Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Supply and PBS claiming from a medication chart in Residential Aged Care Facilities Draft content of consultation paper for comment PRG AMA November – December 2010 Changes were made to the draft public consultation papers as a result of PRG advice including: increased emphasis on the reduced administrative burden for the pharmacist; ensured consistent use of the term “prescriber”, as opposed to medical practitioner or doctor; included further information on the link with QUM policy and the Authority medicines process. Call for responses on parameters of the initiative through the release of a consultation paper PRG Targeted aged care stakeholders Broad range of pharmacy and prescribing industry stakeholders State and territory health authorities The general public March 2011 – April 2011 Aged care facilities Public and private hospitals Community pharmacies Medication packaging companies November 2010 – June 2011 Inform legislative amendments to the National Health Act 1953, identify policy issues and potential change management issues. AMA November 2010, June 2011, January 2012 and April 2012 Resolved the issue about how ‘repeat’ medication orders will be dealt with on the chart Informed communication requirements for prescribers. February, August, November, December 2011 and March 2012. Site visits to inform policy and implementation issues Discussions with the AMA to identify issues for prescribers Meetings with representatives from state and territory departments of health All jurisdictions Consultation on community pharmacy software requirements May 2011 to December 2012 MSIA ACIVA 8 Responses informed legislative amendments currently before parliament. Highlighted the importance of safety and quality use of medicines requirements which have resulted in the Department engaging the ACSQHC to develop the National Residential Medication chart. Informed issues to be address in relation to implementation and change management activities. Identified and incorporated key issues into the development and implementation of the initiative, including informing legislative amendments. Provided information in relation to Commonwealth legislative and regulatory changes. Identified requirements for software vendors to support the transition to new arrangements. Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Supply and PBS claiming from a medication chart in Residential Aged Care Facilities National Residential Medication Chart Reference Group – established by the ACSQHC October 2011 – ongoing Aged Care Facility representation DoHA Medicare Consumer Guild AMA ACAA RACGP PSA DVA Providing advice and guidance to the ACSQHC on the development and implementation of the National Residential Medication Chart project. Department of Veterans Affairs DVA November 2011 Identified issues that impacted on ensuring RPBS access is maintained and inform of legislative amendments to the National Health Act 1953. Consultation regarding exemptions required from NSW Ministry of Health NSW Ministry of Health ACSQHC July 2012 - ongoing Provided advice to NSW Ministry of Health on specific elements of the chart to support the granting of the exemptions to allow the phased implementation to commence. Continued Dispensing of PBS Medicines in defined circumstances Management of programme implementation ACSQHC, state governments, residential aged care peak bodies, DSS. October 2011 – ongoing Managed the implementation of the National Residential Medication Chart project. Initiative Development Meetings Guild DHS PSA August 2010 – October 2012 Policy issues in relation to programme design, Medicare system and implementation identified and resolved. Agreement on elements of the programme that required broader consultation Development of practice guidelines. 9 Current as at 30 June 2014 5CPA component Continued Dispensing of PBS Medicines in defined circumstances Consultation activity With whom Timeframe Action taken in response Draft content of consultation paper for comment PRG AMA November December 2010 Changes to the consult papers were made to papers as a result of PRG advice including: changing name of the initiative from Medication Continuance to Continued Dispensing of PBS Medicines in defined circumstances. communication from pharmacists to prescribers when a continued dispensing even has occurred built in as a mandatory step. indemnity issues being explored including if the indemnity lies with the original prescriber or the pharmacist. the development of pharmacist education and professional protocols. Call for responses on parameters of the initiative through the release of a consultation paper PRG targeted aged care, pharmacy and prescribing industry stakeholders State and territory health authorities The general public March – April 2011 Meetings with representatives from state and territory departments of health All jurisdictions February, August, November, December 2011 and March 2012. Sought advice from PDL with regard to pharmacy indemnity issues Consultation on community pharmacy software requirements PSA – Expert Advisory Group – industry consultation seeking comment on professional guidelines PDL August 2011 MSIA AMA AACP NPS APC PDL CHF Tasmanian Department of Health May 2011 – December 2012 October – November 2011 10 Responses informed legislative amendments currently before parliament. The Department engaged the PSA to develop professional protocols and guidelines for pharmacists undertaking a continued dispensing supply. Prior clinical review is mandatory prior to a continued dispensing supply. Informed issues to be addressed in relation to implementation and change management activities. Released FACT SHEET at APP conference in March 2012. Identified and incorporated key issues into the development and implementation of the initiative, including informing legislative amendments. Provided information in relation to Commonwealth legislative and regulatory changes. Advice provided will support ongoing implementation. Identify requirements for software vendors to support the transition to new arrangements. Feedback received from stakeholders has been incorporated into the development of the professional guidelines. Current as at 30 June 2014 5CPA component Electronic recording and reporting of controlled drugs Electronic recording and reporting of controlled drugs Consultation activity Initiative development meetings With whom Guild Medicare PRG AMA Timeframe August 2010 – October 2010 November December 2010 Meeting with the Office of the Australian Information Commissioner January 2011 Call for responses on parameters of the initiative through the release of a public consultation paper Office of the Australian Information Commissioner PRG Targeted health sector stakeholders including health professionals and software vendors State and territory health authorities General public Representatives of the departments of health in all eight jurisdictions Representatives of the department of health in all eight jurisdictions Draft consultation paper sent to PRG for comment Meetings with state and territory health departments State and Territory ERRCD Steering Group Discussions with the AMA to identify issues for prescribers Meetings with the Pharmacy Guild AMA Guild Consultation on community pharmacy and prescriber software requirements Discussions with NeHTA regarding messaging and content standards MSIA NeHTA 11 March 2011 – April 2011 Action taken in response Determined the direction of the initiative and drafted the public consultation paper. Acknowledged that the PRG was broadly supportive of the initiative and the proposed parameters. A Privacy Impact Assessment of the initiative was conducted. February 2011 – August 2012 August 2012 ongoing February and April 2012 February 2012 ongoing February 2012 ongoing September 2012 – ongoing Acknowledged that the initiative was broadly supportive and key advice was considered and incorporated into the development of the next stages of the initiative, including within the High Level requirements for the system released as a part of the Department’s Request for Expression of Interest 371/1011. Released FACT SHEET on 5CPA website on 26 April 2012. Input from the jurisdictions was used to inform the system development and policy parameters and implementation options for the initiative. Input is being used to ensure that the objectives of the initiative are achieved, risks are identified and the initiative is implemented and operated consistent with applicable legal and policy obligations. Considered options for the ‘interface’ with practice management software. Considered implementation options for the development of the electronic Controlled Drugs Register. Identify requirements for software vendors to support the transition to new arrangements. Continue to liaise with NeHTA to ensure the ERRCD system aligns with eHealth standards. Current as at 30 June 2014 5CPA component Pharmacy Location Rules Pharmacy Location Rules Consultation activity Independent review conducted by Urbis Pty Ltd, including: - Stakeholder interviews - Online survey to review the effectiveness and efficiency of the Rules Stakeholder workshop hosted by Department and the Guild Meetings with the Guild Meet with the Consumers Health Forum staff to broadly outline the proposed amendments to the Rules. With whom Guild DHS RACGP AMA PSA ACPA APESMA SPHA PBA CHF NRHA Primary Health Care Four individual brokers who regularly act on behalf of applicants Online survey received from 15 of the 23 previous applicants. DHS ACPA Timeframe January 2010 June 2010 Action taken in response Responses informed the development of the determination introduced into parliament. Decision that further consultations were needed with ACPA and DHS. October 2010 – October 2011 Ongoing consultation with DHS regarding administrative processes relevant to the Pharmacy Location Rules DHS Mid 2011 – ongoing Meetings with the Guild to discuss proposed minor amendments to the Pharmacy Location Rules to address anomalies within the Rules. Guild Late 2012 – mid 2013 Pharmacy Location Rules Issues and Opportunities Workshop; and Pharmacy Location Rules Process Discovery and Improvement Workshop Health (PAB and LSB) DHS ACPA Chair 12 April / May 2013 Development of the new location rules. Following the registration of the determination, stakeholders were advised of the changes via letters to community pharmacies, agents who act on behalf of applicants and other stakeholders. Frequently Asked Questions and a revised handbook to assist potential applicants are available on the Department’s website. Articles were distributed to pharmacy journals for potential inclusion in online and printed publications. Proposed minor amendments to address anomalies in the Rules have been agreed. Drafting of a new determination has commenced. Considering areas where application and administrative processes could be streamlined and possible improvements to the section 90 application process. Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Electronic Prescriptions Payment processes for EPF claiming system by DHS. Guild MSIA DHS PES vendors June 2012 – ongoing DHS extends the EPF payment process to implement an EPF payment process direct to PES vendors and to maintain the 15 cents EPF payment to pharmacy. Consultations to manage Prescription Exchange Service interoperability and pharmacy participation in ETP eRx and Medisecure Guild (later) DHS (later) April 2012 – ongoing PES Interim Interoperability Initiative. Consultation about the parameters and definitions to apply to the Guild proposal to pay pharmacy 15cents for each electronic prescription dispensed Guild DHS Early 2010 – ongoing 15 cents Electronic Prescription Fee (EPF) included in the Fifth Agreement signed on 3 May 2010. Agreement to pay PES vendors 85 cents EPF from 1 July 2012 to 31 Dec 2012 and 35 cents EPS from 1 Jan 2013 to 30 June 2013. CSO consultation workshops CSO Funding Pool Collection of under co-payment data Fifth Community Pharmacy Agreement Evaluation Framework Development and implementation of the under co-payment data collection measure, including: development of changes to Medicare processes, development of changes to pharmacy dispensing software; development of a communications strategy for pharmacy; letters providing information to hospitals and other stakeholders; updating of information on the DHS and DoHA websites; and consideration of postimplementation issues. Ongoing stakeholder engagement to update the Evaluation Framework annually or as required during the Fifth Agreement. Pharmaceutical wholesalers CSO Administration Agency TGA Guild June 2010 – October 2010 MSIA Pharmacy software vendors Guild DHS DVA Peak stakeholder bodies (CHF, PSA, SHPA, AFSPA, APHA, RACP, RACGP, AMA) January 2010 – May 2012 The Evaluation Framework is available on the Department’s website and the Department invites public comment from interested stakeholders Ongoing 13 Changes to the CSO Service Standards and changes to the Deeds of Agreement with CSO Distributors. The revised Code of Good Wholesaling Practice is being used within the CSO framework002E. Technical issues discussed and progressed; Vendor resource document finalised; Monitoring of collection of data submissions from 1 April 2012. Amended legislative instruments regarding the collection of under co-payment data. The Evaluation Framework and Department website have been updated are based on comments received to date. Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Combined Review of the Medication Management Review Programmes under the Fifth Agreement. PRG Consumers Community Pharmacist Accredited Pharmacists Hospital Pharmacists General Practitioners RACF residential and nursing staff Other Health Professionals July 2013 Dec 2014 PRG Pharmacy Guild of Australia; Pharmacy owners; Pharmacist workforce (including Community pharmacists); Accredited pharmacists and relevant hospital practitioners; Pharmaceutical Society of Australia; Australian Association of Consultant Pharmacists; Society of Hospital Pharmacists of Australia; and Professional Pharmacists Australia (formerly known as APESMA). Consumers; Consumers Health Forum of Australia; Council on the Ageing; Carers Australia; National Aboriginal Community Controlled Health Organisation; Mental Health Council of Australia; Aug 2014 – March 2015 Combined Thematic Review of Access, Consumer Experience and Quality Use of Medicines under the Fifth Agreement. 14 Advice, opinions, information and data sought from participating stakeholders to enable response to evaluations Stakeholder consultation undertaken through focus groups, interviews and surveys Advice, opinions, information and data sought from participating stakeholders to enable response to evaluations Stakeholder consultation undertaken through focus groups, interviews, workshops and research analysis Current as at 30 June 2014 5CPA component Consultation activity With whom Review of Governance Structures established under the Fifth Agreement. Timeframe Action taken in response Aug 2013 January 2015 National Rural Health Alliance; National Aged Care Health Alliance; National Prescribing Service; Medicines Australia; Australian Medical Association; Medicare Locals Network; and Royal Australian College of General Practitioners. ACC PRG Pharmacy Guild of Australia Pharmaceutical Society of Australia; Australian Association of Consultant Pharmacists; Society of Hospital Pharmacists of Australia; and Professional Pharmacists Australia (formerly known as APESMA). Consumers; Consumers Health Forum of Australia; Council on the Ageing; Carers Australia; National Aboriginal Community Controlled Health Organisation; Mental Health Council of Australia; National Rural Health Alliance; National Aged Care Health Alliance; National Prescribing 15 Advice, opinions, information and data sought from participating stakeholders to enable response to evaluations Stakeholder consultation undertaken through interviews, surveys and workshops Current as at 30 June 2014 5CPA component Consultation activity With whom Timeframe Action taken in response Service; Medicines Australia; Australian Medical Association; Medicare Locals Network; and Royal Australian College of General Practitioners. Generic Medicines Industry Association National Australian Pharmacy Students' Association (NAPSA) Department of Health Department of Human Services(Medicare) Department of Veteran Affairs State and Territory Health Departments 16 Current as at 30 June 2014