‘April Fool’s day’ for pharmacists and patients as Continued Dispensing ends next week

The Easter long weekend is a notoriously busy time of year for pharmacists. But 2024 could be the busiest one yet, as a major policy change is set to occur.

Easter Sunday (31 March 2024) will be the last day of the National Health (Continued Dispensing – Emergency Measure) Determination 2023. 

That means the number of Pharmaceutical Benefits Scheme (PBS) medicines available via Continued Dispensing will be dramatically slashed from 755 to 150 during a public holiday – when reports have indicated a jump in Easter travel from 2023.

It’s ‘almost farcical’ for a change to Continued Dispensing to occur over any public holiday, let alone Easter, said Chris Campbell MPS, PSA General Manager Policy and Program Delivery.

‘We already know that pharmacies still remain open and GP access is reduced,’ he said. ‘A major change over that period of time is just not good policy.’

What will the impacts be?

While Continued Dispensing legislation is critical during a natural disaster, there are many scenarios where the policy supports continuity of care where people are separated from their medicines and prescriptions, including:

• personal circumstances such as incidences of domestic violence or personal trauma
• theft
• prescriber illness or leave
• localised flooding.

Aside from reducing access to medicines for patients during critical and unplanned circumstances there are also implications for the pharmacy profession.

‘For some pharmacies, this is the busiest time they’ll have in the calendar year,’ said Mr Campbell.

‘You’ve got a perfect storm of increased prescription requirements and requests ahead of the holidays, people who are travelling who may not have access to their regular GP, and pharmacies ramping up their immunisation programs.’

If a patient is ‘lucky enough’ to travel before the end of March, pharmacists will be able to provide continuation of their medication while they’re on holiday in most, but not all states.

‘From 1 April, April Fool’s Day, that same patient can come in and not be looked after,’ said Mr Campbell. ‘It’s the worst possible time for this policy to change.’

What’s changing and where?

When the temporary federal instrument National Health (Continued Dispensing – Emergency Measure) Determination 2023 ceases at the end of this month, the number of PBS medicines available via Continued Dispensing will reduce to 150 in the jurisdictions that adopted the legislation, including:

• Queensland
• Western Australia
• the ACT
• the Northern Territory.

However, there are some jurisdictions that the change won’t affect, including:

• New South Wales and South Australia, where it was never adopted
• Victoria, where Public Health Emergency Order 25 enabling expanded Continued Dispensing expired on 6 February 2024.

The only state to permanently enact full Continued Dispensing is Tasmania. However, the impending repeal of the Emergency Determination will still lead to barriers in continuity of care for Tasmanians.

‘Patients in Tasmania will continue to be able to access Continued Dispensing medicines that are not one of the ordained 150 medicines, however they will be forced to pay unnecessary out-of-pocket costs,’ said Mr Campbell.

This is because the other 605 molecules can only be supplied privately. 

Patients across Australia who have a certain medical condition that’s not covered by medicines on the list may be forced to seek care in emergency departments (EDs) during an access-to-care crisis.

‘The government is almost picking and choosing which conditions to support. ‘It’s unnecessary discrimination,’ he said.

‘We should be making sure people don’t unnecessarily attend places such as EDs, where there are other more pressing emergencies those areas should be supporting.’ 

Which medicines will still be eligible for Continued Dispensing?

Medicines listed in the National Health (Continued Dispensing) Determination 2022 will be available through Continued Dispensing ongoing.

More information about regulations in each state and territory regarding Continued Dispensing can be found in the PSA Regulation Hub.

Why have there been so many extensions to Continued Dispensing?

Continued Dispensing was first enacted in 2012 for HMG CoA reductase inhibitors (statins) and PBS oral hormonal contraceptives. The policy was reenacted in January 2020, expanding to include all PBS medicines, and has been extended a number of times since.

The expanded list was turned off in late 2022, only to be turned back on again on 22 December 2023, when a new Continued Dispensing Emergency Measure Determination was issued by the federal government to support Australians affected by natural disasters and other emergencies. 

Due to lapse on leap day (29 February 2024), the emergency measure was extended at the 11th hour until 31 March 2024.

‘Every time there is a disaster, the government extends or reinstates this measure,’ said PSA National President Associate Professor Fei Sim FPS.

Regulations should be in place to support the safe and effective use of medicines, not hinder it, said A/Prof Sim. 

‘It makes no sense these measures expire after each natural disaster passes,’ she said. 

Why should it become permanent?

There are a number of efficiencies that would come from a permanent Continued Dispensing measure, including:

• removal of red tape to facilitate emergency responses when natural disasters occur
• better support for individuals who may be going through a personal crisis.

The ongoing extensions are indicative of an effective, and necessary policy, said Mr Campbell.

‘When life is going as planned, patients shouldn’t need to access Continued Dispensing,’ he said. ‘But life doesn’t always go as planned. If the legislation is made permanent, then Australians will be able to use it when they most need it.’

What action is PSA taking?

The PSA continues to call for the Continued Dispensing legislation to become permanent, said Mr Campbell.

‘We are continuing to have conversations with regulators in all states and territories, as well as the federal government to extend the arrangements,’ he said.

‘It’s a combination of regulations in the states and territories to make Continued Dispensing available, and the federal government supporting a reduction to out-of-pocket costs.’

The PSA has also called for better Continued Dispensing legislation through the pre-budget submission process over many years.