Schedule 8 Medicines Prescribing Code Pharmaceutical Services Branch Version: C20121121AG-3 Citation Department of Health, (2014), Schedule 8 Medicines Prescribing Code, Pharmaceutical Services Branch, Public Health and Clinical Services Division, Department of Health, Perth, Western Australia ___________________________________________________________________________________ Contents Forward ....................................................................................................................................... 1 Access ........................................................................................................................................ 1 Definitions .................................................................................................................................. 2 1. Requirements for the prescribing of Schedule 8 medicines .............................................. 4 Diagnosis.................................................................................................................................. 4 Authorisation for the prescribing of Schedule 8 medicines ....................................................... 4 1.1 High risk criteria ......................................................................................................... 4 1.2 Low risk criteria .......................................................................................................... 5 1.3 Application for authorisation to prescribe Schedule 8 medicines ............................... 5 2. Consultant support ................................................................................................................ 6 2.1 Initial support .............................................................................................................. 6 2.2 Support on renewal .................................................................................................... 6 2.3 Hospital discharge ...................................................................................................... 6 3. Consultant status ................................................................................................................... 7 3.1 Pain................................................................................................................................. 7 3.2 Addiction medicine specialists ........................................................................................ 7 3.3 Prescribing flunitrazepam ............................................................................................... 7 3.4 Prescribing alprazolam ................................................................................................... 8 4. Terminal illness ...................................................................................................................... 8 5. Opioid contracts and limited dispensing ............................................................................. 8 6. Prescribing Schedule 8 benzodiapines ............................................................................... 8 6.1 Prescribing flunitrazepam .............................................................................................. 8 6.2 Prescribing alprazolam (effective 1 February 2014)....................................................... 9 7. General regulatory matters ................................................................................................... 9 8. Resources............................................................................................................................. 10 9. Contacts................................................................................................................................ 11 10. Sending applications ......................................................................................................... 11 Appendix 1: Schedule 8 Quick reference guide to low and high risk criteria ..................... 12 Forward Schedule 8 medicines (drugs of addiction) are regulated by the Poisons Act 1964 and the Poisons Regulations 1965 (state legislation). The information in this document relates to the Western Australian (WA) legislation. Schedule 8 (S8) medicines are defined by the Poisons Act 1964 as: “Substances which should be available for use but require restriction of manufacture, supply, distribution, possession and use to reduce abuse, misuse and physical or psychological dependence”. In Western Australia, S8 medicines include: opioids stimulants (methylphenidate and dexamphetamine) benzodiazepines (flunitrazepam and alprazolam). The prescribing, storage and dispensing of S8 medicines are subject to a greater level of control than that of Schedule 4 medicines. The Poisons Act 1964 and the Poisons Regulations 1965 stipulate the legal requirements for the prescribing of S8 medicines. This Code does not apply to: off label use unregistered products stimulant medicines (please refer to the Stimulant Prescribing Code) buprenorphine or methadone prescribed as part of the Community Program for Opioid Pharmacotherapy (CPOP). The Stimulant Prescribing Code and further information on the CPOP may be found at the Pharmaceutical Services Branch website at www.health.wa.gov.au/pharmacy Access This document can be made available in alternative formats on request for a person with a disability. 1 Definitions The following terms are defined for the purposes of this Code: “Application” means an “Application for authorisation to prescribe a Schedule 8 medicine” form. “CEO” means the Chief Executive Officer of the Department of Health or the delegate of the Chief Executive Officer of the Department of Health. “the Code” means the Schedule 8 Medicines Prescribing Code “Consultant” means a medical practitioner registered with the Australian Health Practitioner Regulation Agency (AHPRA) with specialty qualifications and recognised as a consultant by the Department of Health for the purpose of this Code. “CPOP” means the Community Program for Opioid Pharmacotherapy administered by the Department of Health. “Diagnosis” means a medical condition, which has been determined by a practitioner as the cause for the signs and symptoms presented. “Doctor-shopper” means a patient who has obtained prescriptions for S8 medicines from three or more doctors from different practices over a three-month period. “the Department” means the Department of Health, Western Australia. “ICD-10” means the International Statistical Classification of Diseases and Related Health Problems 10th Revision. “Immediate release (IR)” means the formulation is rapidly absorbed and quickly effective but requires repeated doses. “Morphine equivalents (MEqD)” means the equianalgesic morphine dose in mg per day. “Off-label use” means an indication not approved by the Australian Register of Therapeutic Goods (ARTG) “Opioid” refers to both natural and synthetic drugs whose effects are mediated by specific receptors in the central and peripheral nervous system commonly used for pain. “Parenteral” means delivery of medicines by the intravenous, intramuscular, subcutaneous, or intrathecal route. “Practitioner” refers to a medical practitioner or nurse practitioner registered with the Australian Health Practitioner Regulation Agency. “Prior written authorisation” means that the practitioner must obtain written authorisation from the CEO to prescribe before he/she is permitted to prescribe this medicine to the patient. 2 “PRN” (Pro re nata) means when necessary. “Registered drug addict (RDA)” means a person who has been notified and registered in accordance with the Drugs of Addiction Notification Regulations 1980. “Schedule 8 (S8) medicine” as specified by the Standard for the Uniform Scheduling of Medicines and Poisons (SUSMP), including: alprazolam codeine (when not combined with any other medicine) buprenorphine fentanyl flunitrazepam hydromorphone methadone morphine oxycodone pethidine tapentadol or salts of any of these substances and any preparation or admixture containing any of these substances, or the salts of any of these substances. “Substance misuse” History of substance abuse including: o substance abuse within the previous five years o being a registered drug addict o being a current participant in the CPOP. History of the diversion of S8 medicines within the previous five years. “Sustained release (SR)” means the drug is released over several hours to maintain a constant plasma concentration of the drug. “Terminal illness” means an illness giving rise to a life expectancy of 12 months or less. 3 1. Requirements for the prescribing of Schedule 8 medicines Diagnosis Before prescribing S8 medicines in the treatment of pain, a relevant diagnosis is to be made. A useful aid is the ICD -10. The diagnosis must be included on the application. Authorisation for the prescribing of Schedule 8 medicines Prior written authorisation from the CEO is required for practitioners to prescribe a S8 medicine in accordance with the Poisons Regulations 1965 for: a patient whose details correspond with a registered drug addict a period longer than 60 days (or for more than 60 days in any 12-month period) or flunitrazepam. When practitioners intend to prescribe a S8 medicine in these circumstances, an application to the CEO must be made for authorisation. 1.1 High risk criteria Authorisation requires consultant support (refer to section 2) where: a patient is less than 18 years of age a patient whose details correspond to those of a RDA a patient is identified as a doctor shopper a patient has a history of substance misuse the total combined daily dose of S8 medicines is greater than 90 MEqD (excluding terminal illness) the treatment is with immediate release (IR) preparations at a total combined daily dose greater than 45 MEqD (excluding terminal illness) the treatment is with a combined immediate release/sustained release (IR/SR) regimen where the IR form constitutes more than 50% of the total combined daily dose (excluding terminal illness) the treatment is with a parenteral form of S8 medicine (excluding terminal illness) or as requested by the CEO. The Department reserves the right to request a second opinion or review by a multidisciplinary pain service at its discretion to assist in determining an appropriate treatment management plan. 4 1.2 Low risk criteria Streamlined S8 authorisations will be provided (without the requirement for consultant support) where: the patient is aged 18 years or over the patient is not a RDA the patient is not identified as a doctor shopper the patient has no history of substance misuse the form of medication is not parenteral (excluding terminal illness) the total combined daily dose of S8 medicines is less than or equal to 90 MEqD (excluding terminal illness) no more than 50% of the total combined daily dose of up to 90 MEqD is in the form of an immediate release (IR) preparation (excluding terminal illness) or the total combined daily dose of IR preparations prescribed alone is less than or equal to 45 MEqD (excluding terminal illness). 1.3 Application for authorisation to prescribe Schedule 8 medicines An application for authorisation is required to be completed when a practitioner wishes to prescribe a S8 medicine as set out in the Code. A new application will be required to be completed when: a patient’s treatment within the high risk criteria has changed the patient moves from ‘low risk’ into ‘high risk’ there is a change in drug there is a change in drug form there is a change in drug dose there is a change in the patient’s name details the previous authorisation has expired the authorised practitioner changes practice address or the patient moves to a different medical practice. 5 2. Consultant support Practitioners are required to provide consultant support for any patient who meets one or more of the criteria in the list of high risk criteria (refer to Appendix 1: S8 Quick reference guide to low and high risk criteria for the full list of criteria). Consultant support should provide details of the: patient’s diagnosis and need for ongoing treatment with S8 medicines drug, dose and frequency of administration of the S8 medicine(s) required length of time that a consultant will support an application. If no shorter length of time is specified, the Department will accept the most recent consultant’s support for a maximum of three years. Where a patient is a RDA, identified doctor shopper or has a history of substance misuse evidence must be provided to show these issues have been addressed. Authorisations will not be issued where patients fail to attend scheduled consultant appointments. It is the responsibility of the practitioner and the patient to ensure ongoing consultant review if required. 2.1 Initial support Consultant support is required before authorisation for all patients who fit the high risk criteria unless otherwise determined by the CEO. 2.2 Support on renewal Consultant support is required for renewal of authorisation for treatment with S8 medicines for all patients with high risk criteria and as determined by the CEO. 2.3 Hospital discharge A hospital discharge summary dated no more than three months prior to the application date, plus evidence of referral to a consultant will be considered with applications to prescribe for patients who satisfy any high risk criteria and who have recently been released from hospital. The discharge summary and evidence of referral must accompany the application form. 6 3. Consultant status 3.1 Pain The following specialists are recognised as being able to provide consultant support for high risk applications provided that the speciality is relevant to the diagnosis under treatment: anaesthetist endocrinologist gastroenterologist neurologist oncologist pain medicine specialist palliative care specialist physician rheumatologist surgeon other specialists as approved by the CEO. 3.2 Addiction medicine specialists Practitioners who are a Fellow of the Australasian Chapter of Addiction Medicine (FAChAM) will be recognised as consultants for the management of Schedule 8 treatment for pain for patients who are registered drug addicts and patients with a recent history of substance abuse, diversion or doctor shopping, provided: S8 treatment is prescribed for pain not for addiction the patient is reviewed within 12 months by a multidisciplinary pain clinic or a specialist appropriate for the pain diagnosis. All other applications will be treated in accordance with Departmental policy. 3.3 Prescribing flunitrazepam For the purposes of this policy the following specialties are recognised as being able to provide consultant support for the prescribing of flunitrazepam: psychiatrist sleep medicine physician neurologist. 7 3.4 Prescribing alprazolam For the purposes of this policy the following specialties are recognised as being able to provide consultant support for the prescribing of alprazolam: psychiatrist other specialists as approved by the CEO. 4. Terminal illness If a patient during the course of treatment becomes terminally ill (i.e. has a life expectancy of less than 12 months) then a practitioner is required to notify the Department accordingly by completing an application. A specific drug and dose will be authorised where indicated on the application. Where S8 medicines are being titrated, then the name of the drug together with ‘PRN’ should be indicated on the application to enable flexibility in treatment. Palliative care practitioners from the same practice or team can apply for a group authorisation to allow all prescribers in the group to prescribe for a patient who is terminally ill. Applications for terminal illness are considered low risk unless the patient: is less than 18 years of age is a RDA is identified as a doctor shopper or has a history of substance misuse. In these instances the patient will be considered in the high risk category and consultant support will be required. 5. Opioid contracts and limited dispensing An opioid contract should be used in all cases where an S8 is prescribed. Written opioid contracts between patient and prescriber are used routinely by specialist pain clinics and represent best practice, as the contract clearly sets out the patient’s and prescriber’s responsibilities. They also serve to document informed consent. In certain circumstances, patients may be required to have a limited amount of their medication dispensed at a time and this may be conditioned as a requirement of the authorisation. This is to assist in reducing the likelihood of a patient requesting additional prescriptions due to medication being used up ahead of time before the next prescription is due. 6. Prescribing Schedule 8 benzodiazepines 6.1 Prescribing flunitrazepam In accordance with the Poisons Regulations 1965, prior written authorisation from the CEO is required by practitioners wishing to prescribe flunitrazepam for each individual patient. This 8 unique authorisation number must be hand written by the prescriber on the prescription prior to presentation at a pharmacy. If there is no authorisation number the pharmacist must refuse to dispense and will be required to contact the practitioner. An authorisation will only be issued if the application is accompanied by written support from an appropriate consultant i.e. psychiatrist, sleep medicine physician or neurologist (see section 3.3). 6.2 Prescribing alprazolam (effective 1 February 2014) Written authorisation from the CEO is required by practitioners wishing to prescribe alprazolam for each individual patient for a period greater than 60 days. This authorisation number does not need to appear on the prescription. Consultant support is not required for applications if prescribing is for approved indications and in dosages within the normal therapeutic range. Practitioners wishing to prescribe alprazolam for a RDA for any period of time will require prior authorisation and appropriate consultant support (see section 3.4). 7. General regulatory matters The CEO may revoke or cancel an authorisation issued to a practitioner. A practitioner who has completed an application or who has received a written authorisation from the CEO may request in writing that their application or authorisation be cancelled. Practitioners should notify the CEO in writing if replacement prescriptions are required for lost, stolen or otherwise inaccessible medication. Pharmacists are required to be familiar with the practitioner’s handwriting or must verify with the practitioner that the prescription is valid. Repeat prescriptions must be retained at the pharmacy. Practitioners are required to specify intervals between prescription repeats when writing prescriptions for S8 medicines including directions for use. Prescriptions are valid for six months from the date that they are written. To prescribe S8 medicines for clinical research, an application will require submission of a copy of the research proposal with approval from an Ethics Committee constituted in accordance with the Guidelines issued by the National Health and Medical Research Council (NHMRC) An application to prescribe a S8 medicine when high risk criteria are met must be forwarded to the CEO by the practitioner for further consideration. The application must be accompanied by any relevant consultant reports available or as requested. 9 8. Resources The following resources are available from www.health.wa.gov.au/S8 Application to prescribe a schedule 8 medicine Treatment contract for the use of an opioid medicine Morphine equivalent dose conversion calculator Notification of addiction to drugs S8 Quick reference guide to low and high risk criteria The Poisons Act 1964, Poisons Regulations 1965 and Drugs of Addiction Notification Regulations 1980 are available from the State Law Publisher at www.slp.wa.gov.au The ICD-10 is available at www.who.int/classifications/icd/en/ 10 9. Contacts Pharmaceutical Services Branch PO Box 8172 Perth Business Centre WA 6849 Tel: (08) 9222 4424 (Monday – Friday 8.30am to 4.30pm) Fax: (08) 9222 2463 10. Sending applications Applications may be submitted by: Mail: Pharmaceutical Services Branch PO Box 8172 Perth Business Centre WA 6849 Facsimile: (08) 9222 2463 11 Appendix 1: S8 Quick reference guide to low and high risk criteria If any high risk criteria are ticked, consultant support must accompany an, “Application for authorisation to prescribe a Schedule 8 medicine” form. Criterion Low risk criteria High risk criteria (no consultant support required) (consultant support required) Patient age 18 years or over Less than 18 years Patient is an RDA1 No Yes Dose* Total combined daily dose less than or equal to 90 MEqD2 Total combined daily dose greater than 90 MEqD2 Form of medication* Not parenteral Parenteral IR3 formulations only* Total daily dose less than or equal to 45 MEqD2 Total daily dose greater than 45 MEqD2 Combined SR4 and IR3 formulations* Total combined daily dose Total combined daily dose 3 where the IR form constitutes where the IR3 form is greater up to 50% of a IR3/SR4 regimen than 50% of a IR3/SR4 regimen Patient identified doctor-shopper5 No Yes History of substance abuse No Yes History of diversion or misuse of Schedule 8 medicines No Yes *excluding terminal illness 1RDA: Registered drug addict 2MEqD: 3IR: Equianalgesic morphine dose per day Immediate release formulation 4SR: Sustained release formulation 5Doctor-shopper: A patient who has obtained Schedule 8 prescriptions from three or more doctors from different practices over a three month period. 12