from manufacturer to community pharmacy, including consideration of: regulatory requirements, standards and quality control to provide assurance of timely and reliable access and delivery; the and cost drivers associated with timely supply consistent with the NMP, wholesaling, logistics and delivery; the adequacy of funding to promote investment in supply chain infrastructure to meet future PBS supply and security needs; and the relationships between manufacturer, wholesaler, distributor, delivery partner, pharmacy and government and how these impact consumer and community need. Accountability and Regulation What regulatory arrangements are necessary to promote high standards of delivery and accountability amongst pharmacies, wholesalers, manufacturers and other entities receiving funding under the PBS, and the data required to monitor and assess these standards of delivery and community outcomes. Consumer Experience The consumer experience, including: consumer attitudes to the services expected from community pharmacy; consumer expectations regarding access to and affordability of medicines; and consumer priorities regarding access to and quality use of medicines.
If it is desirable for the ratio of community pharmacies to population to increase or decrease in some areas, what in your opinion is the best way to encourage this? Distribution Arrangements the National Health Act 1953 Most medicines on the PBS are available under section 85 (s85) of the National Health Act 1953 (the Act). In addition to this, some medicines are distributed under alternative arrangements where these are considered more appropriate, which are provided for under section 100 (s100) of the Act. Several programs exist for the provision of medicines as pharmaceutical benefits in this way, including the Highly Specialised Drugs Program and the Efficient Funding of Chemotherapy (EFC) Program, both available in private and public hospitals. Due to the increase in expensive new PBS medicines provided under the s100 program, expenditure has increased greatly on s100 relative to s85 over the last ten years, as noted in Table 2. Table 2 – s100 and s85 Benefits Benefits by Program 2005-06 2014-15 Section 100 $208,067,908 $2,106,800,000 Section 85 $5,826,451,884 $7,119,087,606 Most of the expenditure on s100 programs occurs in public hospitals (Figure 3), a reversal of ten ago when most occurred in community pharmacy. However, this growth could be attributed to the introduction of chemotherapy and other highly specialised drugs into s100. Figure 3 – Proportion of Expenditure on s100 Benefits by Pharmacy Type However, s85 medicines are predominantly distributed in community pharmacy and this has not changed, as illustrated in Figure 4. Figure 4 – Proportion of Expenditure on s85 Benefits by Alternate Supply Setting Pharmacy Industry The business for the pharmacy sector in Australia is both retail and health care. Selected data from the April 2016 IBISWorld report on the pharmacy sector in Australia illustrates the proportion of income pharmacy received from prescriptions as opposed to non-prescription business (Figure 5). Note that it is not possible to distinguish PBS versus private prescriptions from this data. It has been put to the Panel that the ratio of revenue from ’front of shop’ and prescription medicines varies greatly across pharmacy business models. Figure 5 – Products and Services Segmentation In your opinion, should there be a maximum ratio of retail space to professional area within pharmacies to maintain the atmosphere of a health care setting for community pharmacies receiving remuneration for dispensing PBS medicines? Trial
Is the ability for the consumer to choose their pharmacist, and change pharmacists if they are dissatisfied, the appropriate or best mechanism to provide feedback? Are appropriate standards for the dispensing of medicines and delivery of services by community pharmacy? If so, are these standards being upheld? If not, how could the current standards be improved?
C – The Review acknowledges the assistance of the following organisations and individuals, who provided valuable insights and information during bilateral discussions held with the Review Panel from December 2015 to March 2016. Alfred Hospital Clinical Pharmacy Alzheimer’s Australia Arthritis Australia Australian Federation of AIDS Organisations Australian Injecting and Illicit Drug Users League Australian Medical Association Australian Pharmaceutical Industries Australian Private Hospitals Association Australian Self Medication Industry Ltd Baxter Healthcare Boehringer Ingelheim Canadian Pharmacists Association Cancer Voices Australia Catholic Health Australia Charnwood Capital Chemist Chemist Warehouse Chronic Illness Alliance Cincotta Chemist Mascot Cominos Pharmacy Services Commonwealth Department of Health stakeholders Consumers Health Forum of Australia Davidsons Chemist Mascot DHL Supply Australia Diabetes Australia Epic Pharmacy Fordgate Pharmacy Friendlies Pharmacy High Wycombe Friendly Society Medical Association (National Pharmacies) Generic and Biosimilar Medicines Association GuildLink Health Care Consumers’ Association Hepatitis Australia Jayson Atkins Pharmacy Leukaemia Foundation Lymphoma Australia McCarthy’s Pharmacy Medici Capital Medicines Australia Melanoma Patients Australia Mr Mouhamad Zoghbi Mt Hawthorn Community Pharmacy National Aboriginal Community Controlled Health Organisation National Pharmaceutical Services Association National Pharmacy Association (UK) National Seniors Australia NPS MedicineWise NSW Users and AIDS Association Pfizer Australia Pharmaceutical Services Negotiating Committee (UK) Pharmaceutical Society of Australia Pharmacy Guild of Australia Pharmacy Guild of New Zealand Pitcher Pharmacy Professional Pharmacists Australia Ramsay Health Care Samford Chemmart Pharmacy Pharmaceuticals Limited Slade Pharmacy Society of Hospital Pharmacists of Australia Symbion EBOS White Group 777 Pharmacy Nollamara D – Listed below are relevant documents referred to throughout the Discussion Paper. This is intended to provide the reader with additional information or context should they wish to understand the issues further. National Medicines Policy Last accessed: Sixth Community Pharmacy Agreement Last accessed: Sixth Community Pharmacy Agreement Programs Last accessed: National Health Act 1953 Last accessed: