Status report on action in response to the evaluation of pbs medicine supply arrangements

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Status Report on action in response to the Evaluation of PBS Medicine Supply Arrangements for

Remote Area Aboriginal Health Services under Section 100 of the National Health Act 1953 A living document to be updated as progress continues

Last updated 9 October 2007 Key

Colour Meaning Actions, at the Australian Government level, are

Completed or No Action Required. Action, at the Australian Government level, relating to the

recommendation is currently Ongoing. NB – some recommendations are flagged as Ongoing (MoU), where action is required in the context of the re-negotiation of the MoUs with states and the NT.

ATSIHS Aboriginal and Torres Strait Island Health Service also referred to as Aboriginal Health Services (AHS)

HIC HIC is now Medicare Australia

Recommendation Action Status

Access to Medicines

1 S100 has met its aim of improving access to PBS medicines to clients of remote area ATSIHSs and should be continued.

All sources of data suggest a significant increase in medicine utilisation.

No action required.

No Action Required

2 Bulk supply has increased medicine utilisation however it would be enhanced by further attention to QUM.

A number of case study sites suggested that the shift to bulk supply was a key factor in overcoming

The Government is committed to bulk supply and the Quality Use of Medicines. For example, through the development of guidelines and training modules (refer to recommendations 13, 16.3, 22 and 23).

Completed

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geographic boundaries and improving access in their ATSIHS. However some smaller clinics had difficulty managing bulk supply.

3 S100 should encompass flexible options to enable the implementation of S100 in sites where bulk supply can not be adequately supported.

S100 could not be fully implemented in a few areas because of barriers to the implementation of bulk supply. Incorporating flexible options would enhance the ability of the program to improve access to medicines. These options should address methods for enabling individual supply in the context of S100 whilst ensuring appropriate reimbursement and without reintroducing the financial barriers to access.

Workforce or legislative issues that may prevent a small number of remote area ATSIHSs from taking full advantage of these alternative PBS supply arrangements should be addressed in the context of workforce and legislative reforms. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MOU)

4 DoHA should expand the range of medicines covered by S100 to include non-PBS medicines commonly used in Aboriginal and Torres Strait Islander communities (e.g. topical antifungals).

S100 does not cover non-PBS medicines. This creates additional costs for ATSIHSs and creates perverse incentives to use PBS medicines when a non-PBS option is more appropriate.

As announced in the 2004-05 Budget, the Australian Government has improved the capacity of the Pharmaceutical Benefits Scheme to meet particular needs in Indigenous health. Benefits of this measure are not restricted to remote areas. The mechanism to enable these medicines to be listed on the PBS has been established.

Completed

4.1 DoHA should review access to Schedule 8 medicines in remote areas.

Schedule 8 medicines are not covered under S100 because these medicines are subject to stringent controls because of their addictive potential. A number of sites suggested that difficulties of accessing such medicines in remote areas had negative health impacts, particularly for palliative care clients.

Regulatory control over the prescribing, storage and supply of drugs of addiction rests with the States. Consideration of options for appropriate access to these medicines for clients of participating remote area ATSIHS is most appropriate through the National Coordinating Committee on Therapeutic Goods.

Ongoing

3


5 Geographic restrictions in eligibility for S100 have caused difficulties in accessing and implementing the program and these should be reviewed.

For example, Gurrinny Yealamucka Health Services, Yarrabah falls just outside of the remote zone and so is not eligible for S100 despite being located 35km from the nearest pharmacy. In Geraldton, the catchment area of the ATSIHS includes an eligible and ineligible area which creates difficulties when clients use different services in the area. In some areas there is large seasonal migration in some cases to sites that would not otherwise be approved for S100 (e.g. Birdsville, Darwin).

The Rural, Remote and Metropolitan Areas (RRMA) classification scale is an appropriate basis for determining ‘remoteness’ in this context. However, there remain some interface issues, including those outlined in the evaluation report which will be addressed on a case-by-case basis.

Ongoing

6 DoHA should retain “clients of approved ATSIHS” as the criterion for individuals to benefit from the program.

There are areas where this criterion is ambiguous which has led to people inappropriately accessing medicines through S100 with an adverse impact on community pharmacists. In many cases strategies to address these issues have been introduced by ATSIHSs. The alternative would be to base eligibility on whether a person was Aboriginal and Torres Strait Islander or not. This would either require documentation potentially creating a barrier to access or Aboriginal and Torres Strait Islander status would have to be determined by ATSIHS staff which would basically be equivalent to the current system.

There is no specific action required in response to this recommendation. Any ambiguity over eligibility will be addressed on a case by case basis. No Action Required

7 DoHA should ensure that all MOU indicate that a high priority for reallocating funds resulting from S100 is to ensure that ATSIHSs have sufficient staff and resources to effectively implement the

This recommendation is relevant to participating remote area health services operated by the States and Territories. The various state Aboriginal and Torres Strait Islander Health Forums have an active role in determining priorities for the reallocation of funds resulting from state

Ongoing (MoU)

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program.

In many cases savings were spent on increasing capacity in relation to S100. In other cases funds remained unspent despite the health service being stretched to capacity. In some cases this was due to delays in the consultation process in others it was due to difficulty finding staff.

government participation in these arrangements. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

8 DoHA should ensure that funding for Doctors at S100 approved ATSIHSs is maintained and further facilitated.

ATSIHSs with a Doctor were more likely to report an increase in the amount of medicines prescribed and supplied as a result of S100. Maintaining and improving the involvement of doctors in the program is likely to have benefits in terms of the implementation of S100 as well as overall quality of care.

The Government supports increased medical workforce engagement in ATSIHs through a number of initiatives, including s19(2) exemptions provided under the Health Insurance Act 1973 and funding for primary health care services.

Ongoing

9 DoHA should clarify the program in relation to whether prescriptions made at another facility can be filled at S100 approved sites, repeat prescriptions and the ability of visiting physicians to supply medicines using S100.

Clarification has been provided on this issue, namely that a prescription made at an approved ATSIHS can be filled at a second approved ATSIHS as long as the requirements, in particular record-keeping requirements, of the S100 Remote Program are met and compliance with the relevant state or territory legislation is maintained. In practice it seems this can be complicated to achieve and is most easily overcome by the patient formally visiting the AHS when medicines are required. Also, visiting physicians are able to supply medicines using S100 if they are suitably qualified under the state or territory legislation to prescribe medication. The Department will disseminate these clarifications to stakeholders.

Ongoing

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10 Information about the performance of S100 would be improved if the following changes were made:

No Action Required

10.1 HIC should provide medicine utilisation data to ATSIHSs to enable them to keep track of their own performance.

Originally HIC was to provide clinics with data on their medicine utilisation however this has not occurred to date.

Discussions with Medicare Australia have been initiated to explore ways to improve availability of expenditure and medicine utilisation. Ongoing

10.2 A system to assess the quantum of medication that expires in ATSIHS should be considered to enable further evaluations.

This would be useful for ATSIHSs to judge the effectiveness of their inventory management. If such data could be collected in a consistent way it would also assist further evaluation by making it possible to show that increases in medicine utilisation were not due to waste.

This matter has been referred to the National Return of Unwanted Medicines (NATRUM) for consideration. Ongoing

10.3 DoHA should update records of ATSIHS client numbers to ensure that any comparisons between centres are accurate.

In order to assess trends in medicine utilisation among different ATSIHSs the size of the client population need to be taken into account.

The Department is undertaking a process to update ATSIHS client numbers. Ongoing

Compliance with State and Territory Legislation and Regulations

S100 has in many cases improved compliance with laws and regulations. However, due to an underestimation of the level of organisational change required to implement the program significant gaps still persist between policy and practice. Addressing issues requires a multi-pronged approach improving ATSHISs’ ability to address compliance by improving communication and improving access to resources and funds

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11 DOHA should examine mechanisms for providing more extensive support to ensure that S100 is implemented in a way that is compliant with State and Territory legislation and regulations. Best practice may require review and amendment of existing legislation in some cases. These additional support mechanisms should take into account that ATSIHS are at different stages of their implementation of S100 and have different needs.

The Department is considering ways to ensure that staff at participating health services are apprised of their responsibilities in the context of the supply and management of medicines. The collaborative development of a compliance self-assessment tool (see recommendation 12) or regular newsletters would be beneficial to improve the clarity of roles, regulation and recognition of Aboriginal and Torres Strait Islander Health Workers. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

12 A self assessment tool addressing legislative compliance issues should be made available to ATSIHSs to complete with their supporting pharmacists. The self assessment tool could be designed in collaboration with the DoHA, the Guild, NACCHO and State and Territory government. This assessment could be used both as a way of reflecting on progress at ATSIHSs but also a way of informing decision makers of new and persisting issues in compliance with State and Territory legislation and regulations.

While many ATSIHSs had made significant progress towards improving legislative compliance there was a sense of frustration by many of the staff that their ability to address legislative compliance issues on their site was limited and that there was no clear pathway to addressing these barriers. A regular process of self assessment that was also used to inform decision makers could be a useful tool in improving communication between different levels of program operation and enabling limitations to be addressed.

The Department will assist in the production of a self assessment tool or newsletter to help clarify information about achieving compliance and identifying persisting issues with compliance. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

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13 DoHA should develop a central resource for S100 to enable sharing of information and learnings.

A number of ATSIHSs and pharmacists felt that access to resources developed by others would have helped their implementation and would have saved labour associated with repeating work conducted by others. The importance of sharing information across Community-Controlled and State and Territory-operated ATSIHS was also stressed by some key informants.

In consultation with stakeholders, the Department will explore a number of communication channels, such as a regular newsletter, to enable sharing of information and experiences. These measures can also be linked with efforts to clarify legislative requirements and other aspects of the program. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

14 DoHA in conjunction with State and Territory Governments, the Guild and NACCHO should develop a resource that clearly states how the law and regulations should be applied to remote ATSIHSs. This process should also be used to identify legislative barriers to the implementation of S100.

The laws and regulations for most jurisdictions are quite complex and there is not one resource that brings together all relevant regulations and laws and discusses their application.

See responses to recommendations 11 -13. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

15 DoHA should work with State and Territory Governments, the Guild and NACCHO to identify ways of facilitating the operation of S100 approved services in jurisdictions where there are legal and regulatory barriers to program implementation (see rec 14).

This would include Poisons Licence issues in WA and repackaging rules in QLD. It should be noted that State and Territory governments are in some cases working independently to resolve these issues.

The Government will continue to work with the States and Territories to address identified barriers. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

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16 DoHA with State and Territory Governments, the Guild and NACCHO should examine ways of supporting systemic changes in ATSIHSs that would lead to improvements in legislative compliance and QUM. Specific examples of possible areas for improvement include:

No Action Required

16.1 IT funding and support is needed to address gaps in record keeping and legislative compliance problems arising from gaps in record keeping.

A number of ATSIHSs suggested that compliance would be assisted by development of computer programs to streamline ordering, dispensing and supply. These could be linked with labelling systems and claiming systems.

As part of its commitment to improving IT infrastructure in Aboriginal Community Controlled Health Services (ACCHSs), the Australian Government announced in 2004 measures to support the uptake of broadband technology in ACCHSs, to assist with improvements in administration and clinical practice. In addition, a comprehensive audit to establish specific gaps in IT capabilities at ACCHSs, with a specific focus of medication management, is proposed. The Department will engage with Medicare Australia to explore ways to improve availability of ordering and claiming systems.

Ongoing

16.2 Funding for support to assist with dispensary organisation.

The case study check list indicated that the organisation of dispensaries was an area for improvement particularly in terms of areas like shelf labelling.

The funding mechanism to cover such activities has been established as part of the Community Pharmacy Agreement – in particular the s100 Pharmacist Support Allowance. Support is ongoing.

Completed

16.3 A set of standards for delivery of pharmacy services should be developed.

A set of guidelines for the delivery of pharmacy services would assist Pharmacists in supporting ATSIHSs.

Professional practice standards have been developed by the Pharmaceutical Society of Australia. Completed

16.4 A generic set of procedures and protocols should be developed that can be adapted for local use.

This should be located on a central website (see

See response to recommendation 13. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these

Ongoing (MoU)

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recommendation 14). This would prevent work being replicated at different ATSIHS.

arrangements in State/Territory operated services.

16.5 Designated staff should manage dispensaries where possible.

Legislative compliance was better in ATSIHSs when responsibility for managing the dispensary was limited to particular staff members.

The Government supports service-based decision making in the allocation of staff responsibilities. Note, that the Department is also developing tools to assist compliance (refer to recommendations 11 to 13).

Completed

16.6 Enhanced training should be provided to ensure medicines are supplied appropriately.

This training should be supported by systems in the ATSIHS. Provision of information and use of cautionary labels were identified as areas of weakness by all data sources.

See responses to recommendations 22 and 23.

Completed

16.7 Processes should be introduced to review errors in order to inform future training and quality management.

Mistakes are sometimes made in all environments where medicines are supplied. Improving service quality is dependent on ensuring that problems can be identified and addressed.

The Department is exploring ways to provide guidance material on error minimisation through good dispensing practice through the distribution of a newsletter. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

16.8 ATSIHSs and Pharmacists should develop communication strategies to ensure imprest lists are regularly reviewed and issues with stock at the pharmacy and transport to the ATSIHS are addressed.

Both Pharmacists and ATSIHSs indicated that availability of medicines still adversely affected access. Pharmacists tended to rate these problems as less common than ATSIHSs suggesting that Pharmacists may not always be aware of problems at the ATSIHS level.

The funding mechanism to cover these activities has been established as part of the Community Pharmacy Agreement – in particular the s100 Pharmacist Support Allowance. Support is ongoing.

Completed

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Administration

17 DoHA and HIC in consultation with State and Territory Governments, the Guild and NACCHO should develop an electronic means for ATSIHSs to order from pharmacists.

Agreement has been reached with stakeholders on options to be used by ATSIHSs to order PBS medicines through S100 arrangements, and has been disseminated to participating health services. For example in Western Australia a electronic template has been developed and is used by ATSIHSs to help decrease ordering time, and is then provided to the pharmacist in hard copy form. However these steps do not prevent further developments for more electronic ordering to pharmacists.

Ongoing

18 DoHA and HIC in consultation with stakeholders State and Territory Governments, the Guild and NACCHO should develop an electronic means for pharmacists to claim from HIC.

Discussions with Medicare Australia have been initiated to explore ways to improve PBS claiming facilities for pharmacists. Ongoing

19 DoHA and State and Territory Governments should develop a mechanism to provide greater support to alleviate increased workload at ATSIHSs.

Bulk supply moves work formerly done at a pharmacy to an ATSIHS. Some services have been able to use money reallocated from their pharmacy budget to fund extra staff to do this work but others have not had sufficient funds. A particular area of concern was that a number of ATSIHSs had equipment (e.g. for labelling) that was not being used. Better support of systems would alleviate these problems.

As outlined in the response to recommendation 7, in relation to remote area health services operated by the States and Territories, the Government supports capacity building as a high priority for reallocation of funds made available through participation by State/Territory Governments in these PBS supply arrangements. In the community controlled sector, the Government supports service-based decision making in the allocation of staff responsibilities. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

Impact on Pharmacists

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20 DoHA should increase the level of remuneration for pharmacists through S100.

Pharmacists felt that the current level of remuneration under S100 was insufficient given the level of service provided. It should be noted that the dispensing fee for S100 is considerably lower than the dispensing fee for S85. One area that is seen as particularly problematic is listed below.

This is being considered under the Fourth Community Pharmacy Agreement as part of the review of the S100 supply arrangements. The Fourth Community Pharmacy Agreement primarily contains the remuneration arrangements for dispensing of PBS medicines by community pharmacists.

Ongoing

20.1 An additional freight component should be added to the S100 handling fee where applicable.

A number of ATSIHSs and Pharmacists felt that the current rate either did not or did not sufficiently cover freight costs.

See response to recommendation 20.

Ongoing

21 The Guild, NACCHO and DoHA should review the requirements and provisions of the support allowance.

The presence of visiting Pharmacists was associated with greater increases in medicine utilisation suggesting that such visits may foster more complete implementation of S100. It was clear that many Pharmacists felt the administrative requirements of the support allowance were too demanding and the remuneration too poor to apply. In many cases support was provided anyway at either cost to the Pharmacist or cost to ATSIHS. If a process to enable retrospective applications could be developed this would alleviate some of the financial hardships experienced by Pharmacists and ATSIHSs. Recommendations about revisions to the support allowance are included in the Loller (2003) report.

Revised arrangements are in place for s100 allowance under the Fourth Community Pharmacy Agreement, including increased payment rates. The Professional Programs and Services Advisory Committee (PPSAC) is reviewing eligibility and administrative arrangements.

Ongoing

12


21.1 Review of the support allowance should take into account the stage ATSIHSs are at in terms of their capacity to manage and supply medicines.

ATSIHSs were at very different stages in terms of their capacity to implement S100 and all services reported that the initial stages of implementation were difficult.


Ongoing

21.2 Review of the support allowance should take into account the need to obtain pharmacy relief.

Lack of locum services were a barrier to Pharmacist’s providing support services to ATSIHSs.


Ongoing

Impact on S100 on Aboriginal and Torres Strait Health Service Staff

22 Further development of pharmacy modules for ATSIHWs is needed and this should be in the context of the national processes for development and review of AHW competencies overall.

The Government has worked with the States and Territories and other stakeholders to improve the clarity of roles, and recognition of Aboriginal and Torres Strait Islander Health Workers, through the development and review of units of competency such as Work With Medicines (HLTAHWM406A). These units of competency are contained in the Health Training Package (HLT07) as part of the new Aboriginal and Torres Strait Islander Health Worker Qualifications.

Completed

23 More in-service training should be made available for ATSIHWs to overcome the lack of formal pharmacy training at present.

Any additional training program would take time to implement. Additional training at ATSIHSs is required as soon as possible therefore short term in-service programs would be useful. These could be used as a basis for piloting modules for a more comprehensive program.

See response to 22. Short intensive training course may be quickly developed based on the units of competency contained in the Health Training Package (HLT07). On the successful completion of the training, Statements of Attainment for the competencies successfully attained is awarded.

Completed

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24 Training initiatives should be accompanied by measures such as provision to staff relief to minimise barriers to their uptake and reduce potential negative impacts on ATSIHS clients.

See response to recommendation 22. Completed

25 DoHA should fund the development of a Pharmacy Technician program for ATSIHSs based on an assessment of existing programs.

See response to recommendation 22. Any new program should aim to utilise the material in the Health Training Package (HLT07) and the associated assessment and learning resources.

Completed

Quality Use of Medicines

26 DOHA with other stakeholders should review legal and technical aspects of the use of dose administration aids in ATSIHSs.

Changed supply arrangements under S100 mean that an increasing number of clients with complex conditions are being managed at ATSIHS level. ATSIHSs vary in the extent to which they have expertise to deal with managing medication for these cases. Dose administration aids of some kind were used in most ATSIHSs. In general while most ATSIHSs felt that they had found the best solution available given the environment in which they were working there appeared to be serious limitations to most methods.

Evidence does not support universal acceptance of dose administration aids in remote communities. In addition, ‘legal aspects’ in this context relate to the statutory frameworks enacted by the States and Territories to safeguard public safety in the supply of scheduled poisons, including prescription-only medicines. Decisions about the appropriate use of dose administration aids should be made locally, in accordance with good medication management practice.

No Action Required

27 ATSIHSs and Pharmacists should review criteria for using dose administration aids.

QUM could be improved if criteria for the use of Dose Administration Aids in ATSIHSs were reviewed in the light of National Medicines Policy criteria or other published guidelines that are applicable in the ATSIHSs setting.

The Government supports local decision making on the use of appropriate dose administration aids, in accordance with relevant State/Territory legislation. No Action Required

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28 DOHA should in consultation with stakeholders fund the use of dose administration aids in ATSIHSs in the context of pharmacy remuneration and consistent with the outcomes of the review (see rec. 26 )

Refer to the response to recommendation 26. Also, existing s100 pharmacy support allowances made available under the Fourth Community Pharmacy Agreement may be used to support activities requested by ATSIHSs, including the repackaging of medicines in dose administration aids.

Completed

29 DoHA should fund the adaptation/development and distribution of information sheets on common and new medicines.

A number of ATSIHSs suggested that information sheets on common and newly emerging medicines. Information sheets would be a useful resource for Aboriginal health workers and health staff as well as clients. They would ensure that everyone kept up to date with the current medicine information. The National Prescribing Service and the Pharmacy Guild have already developed some resources. These in addition to information from consumer organisations could be assessed and adapted for ATSIHSs by NACCHO and other interested stakeholders.

The Government supports existing activities in this area coordinated through the National Prescribing Service and the National Aboriginal Community Controlled Health Organisation (NACCHO), as well as the development and promulgation of medication handbooks written for Aboriginal and Torres Strait Islander Health Workers (eg Medicines Book for Aboriginal Health Workers (first edition 2005), a project funded by the Australian Government under the Rural and Remote Pharmacy Infrastructure Grants Program (part of the Rural and Remote Pharmacy Workforce Development Program).

Completed

Performance under the MoUs

30 NT DHCS and QH need to extend their efforts to undertake steps to improve the QUM in all ATSIHSs as agreed in the MOU clause 5.1

NT DHCS has taken some steps to improve QUM and sought to minimise the impact of S100 on its services. However it is likely that additional support will be required to facilitate the smooth transition from Hospital to Community pharmacy. With the

This recommendation relates to participating ATSIHSs operated by the Governments of the Northern Territory and Queensland. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

15


exception of the Mount Isa district it is not clear that QH has undertaken steps to improve QUM despite a clear recognition by QH staff of the need to do so.

31 NT DHCS and QH, in consultation with the relevant Aboriginal and Torres Strait Islander Forums/Partnerships, should develop QUM indicators and put in place measures to monitor performance against these indicators in line with the MOU clause 5.1

This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services. Ongoing

(MoU)

32 DoHA should include regular reporting of performance against QUM indicators to Aboriginal and Torres Strait Islander Forums in the MOU.


(MoU)

33 NT, DHCS, in consultation with the Aboriginal Forum, should consider a tiered approach to S100 savings that would consider both Territory wide and local needs.

The centralised model for the distribution of savings adopted by NT DHCS is efficient administratively, directs monies into priorities that are likely to improve Indigenous health in a significant way and does enable ATSIHSs that might otherwise be disadvantaged to benefit. However, there is a sense that the local needs of ATSIHSs are not being adequately addressed. The NT DHCS is currently underspent particularly in relation to some of the monies targeted at QUM. Developing a mechanism for ATSIHSs to access some of these savings would provide an alternative way of developing QUM.

The Government supports consideration of a system wide approach to the quality use of medicines to enhance these supply arrangements, in consultation with Aboriginal Health Forum partners. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

34 NT DHCS should provide more comprehensive feedback about expenditure of S100 savings.

Many of the concerns about the NT DHCS were

This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

16


related to a sense by some ATSIHSs that they had never “seen the money”. More transparency in reporting may allay some of these concerns.

35 DoHA and SA DHS should simplify the reporting requirements of the South Australian MOU so that they are commensurate with the amount of money involved.

Technically the SA DHS did not meet its reporting requirements under the MOU. However this was not a major concern to either party because of the small amount of money involved. The reporting requirements of the SA MOU are very similar to the NT and QLD MOU even though a far larger sum of money involved. It is suggested that SA DHS should be considered to have met its requirements provided that there is evidence that savings have been paid to the two approved clinics.

Opportunities for simplifying the reporting requirements will be considered in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

36 QH should review and upgrade the training of ATSHIS staff to ensue that all approved ATSIHSs are able to comply with legal and regulatory requirements.

QH has undergone significant changes in relation to S100 and in relation to laws concerning supply of medicines at remote ATSIHSs. In some cases practice has not kept pace with these changes and steps need to be taken to assess and ensure compliance.

This issue will be considered in the context of renegotiating the bilateral MoU with Queensland. Ongoing

(MoU)

37 QH should demonstrate that they have maintained expenditure on Indigenous Health by providing evidence that savings from S100 have been spent on Indigenous health in order to meet the requirements of their MOU.

To date, QH has only reported on anticipated

Efforts to ensure that more timely expenditure data are made available, as appropriate, to guide decision-making and reporting on initiatives arising from Queensland Health’s participation in these arrangements will be considered in the context of renegotiating the bilateral MoU with Queensland.

Ongoing (MoU)

17


expenditure not actual expenditure. The case studies suggested that expenditure had sometimes not occurred or when it had there were significant lack of clarity about how it had been spent.

38 QH and the Queensland office of DoHA should develop guidelines for the expenditure of savings.

A number of QH staff suggested that more guidance was required from DoHA about what savings should be spent on. Developing shared guidelines could be an effective compromise between the preference of the Queensland Health office of DoHA for a more directed approach to expenditure and QH desire to foster local decision making.

The development of shared guidelines for the expenditure of savings, with appropriate community consultation, and consistent with statewide health priorities will be considered in the context of renegotiating the bilateral MoUs with the relevant States and the Northern Territory.

Ongoing (MoU)

39 DoHA and QH should develop a streamlined system to reduce the administrative load associated with claiming in sites with primary care and inpatient facilities co-located.

In order to comply with the Australia Health Care Agreement, medicines supplied to inpatients must be removed from HIC claims. This adds to the complexity of the claim process.

Privatisation of PBS medicine supply through local community pharmacies (rather than through hospital pharmacies), is expected to minimise these issues. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

40 QH should revise management structures in relation to S100 so that ATSIHSs can receive better support and that better accountability can be achieved.

A number of issues with accountability, reporting and implementation appeared to relate to failures in communication Corporate Office and the Zones and Districts. All but one of the approved QH services are based in Northern zone so developing a more integrated management approach at the zonal level may improve both implementation and staff

The Government supports improved communications to management and staff of remote area health services participating in these PBS supply arrangements. This issue will also be explored in the context of renegotiating the bilateral MoUs that underpin these arrangements in State/Territory operated services.

Ongoing (MoU)

18


satisfaction.

41 Savings to the Torres Strait Island and Northern Peninsula Health Service District (TS and NPHSD) resulting from costs shifting to the PBS should be indexed against CPI in order to achieve parity with other QH Health Service Districts.


(MoU)

42 QH should take steps to resolve anomalies in the implementation of S100 in the Torres Strait Island and Northern Peninsula Health Service District.

At this stage QH has not provided any evidence to support the notion that TS&NP HSD should be treated as a special case by DoHA. However the implementation of S100 in this District raises a number of issues in relation to adherence to the MOU. QH specifically mentions Thursday Island Clinic in the MOU so assistance in implementation could have been provided from the outset. The evaluation team does recognise access issues associated with the co-payment and has recommended that this issue be addressed across the board.


(MoU)

43 QH should be required to move supply from Hospital to Community Pharmacists in future MOU.

Hospital Pharmacists currently supplying approved ATSIHS were extremely overstretched and felt that the level of support they could provide fell well short of what was actually required. The results of the evaluation in other jurisdictions suggest that shifting to Community Pharmacists was associated with better level of support than that provided by Hospital Pharmacists.


(MoU)

19


44 Future MOU should take into account reform of the Australian Health Care Agreement and its potential impact on clients of S100 approved ATSIHS.

In the past Public Hospitals have provided patients with a small amount of medicine (5 days) supply on discharge. Under new reforms to Australia Health Care Agreement some Public Hospitals in Queensland will be able to prescribe PBS medication to outpatients and patients upon discharge. This may impact on clients of S100 approved services attending Hospitals affected by this reform. Currently they would either have to pay for their medicines at the Hospital or visit the ATSIHS on their return home to get the supply of medicines re-authorised.


(MoU)

Status report on action in response to the evaluation of pbs medicine supply arrangements

Health & Medicine

context of medicines

pbs medicines government

bulk supply

nonpbs medicines

remote areas

stringent medicines

supply of drugs

individual supply