The end is here for digital image prescriptions, with the interim arrangement allowing pharmacists to supply and claim for prescriptions sent via fax, email or SMS concluding on 31 March 2022.
The initiative, which has been in place since March 2020, was extended several times to support telehealth consultations during COVID-19.
Having served this purpose, and with electronic prescriptions now widely available in GP clinics and pharmacies, there are concerns about the associated risk of fraudulent behaviour.
Here’s what you need to know to ensure minimal disruption to patients and workflow.
1. Prescriptions written before 31 March 2022 will still be valid
All paper prescriptions issued before 31 March under image-based prescribing can be supplied after this date. This means your file of faxed prescriptions received can be dispensed, including repeats.
Digital images of prescriptions, however, will not be eligible for Pharmaceutical Benefits Scheme (PBS) claims if the prescription is written after 31 March.
2. It is going to be a messy transition
The end of the initiative is likely to have gone under the radar for prescribers, patients and pharmacists, meaning the transition may catch many unaware.
PSA Senior Pharmacist Peter Guthrey MPS said it will be a difficult time for pharmacists, who will bear the burden of chasing prescribers for valid prescriptions.
‘There will be professional and financial risk to pharmacists in supplying medicines from a fax or email copy of a prescription if the original is not subsequently received,’ he said.
‘Pharmacists are in the unfortunate position of having to chase up original copies of prescriptions which may have been filed in their prescribers’ records.
‘However, the profession has told us that digital image prescribing has created significant patient safety, administrative and legal challenges to work through. Once we move beyond the transition, we will be in a better place.’
3. Previous fax/phone order regulations remain available
Digital image prescriptions were introduced to support telehealth consultations. However, it is still possible for prescribers to create paper prescriptions during these consultations after 31 March.
The practical impact is that faxed or emailed prescriptions for Schedule 4 medicines will revert to being supplied under ‘owing prescription’ arrangements.
A prescriber can phone or fax a paper prescription to a community pharmacy for urgent supply, subject to state and territory regulations. From 1 April 2022, the prescriber must ensure the pharmacy receives the hard copy of a PBS prescription within 7 days.
Some states require prescriptions to arrive at the pharmacy sooner. And in one state, faxed scripts are problematic: Victorian regulations do not recognise faxes as a legal order (but do recognise phone orders). The PSA’s COVID-19 microsite outlines the phone/fax requirements for each jurisdiction.
In Queensland, phone and fax order regulations were changed in the new Medicines and Poisons (Medicines) Regulation 2021. Queensland pharmacists must be familiar with new time limits for hard-copy prescriptions to arrive at the pharmacy (i.e. 7 days for Schedule 4 medicines or 5pm the next business day for Schedule 8 medicines).
4. Moving to electronic prescriptions is encouraged
Mr Guthrey said the end of digital image prescribing was an opportunity to discourage paper prescriptions transmitted by fax, phone and email and instead promote electronic prescriptions.
‘Across Australia, 98% of pharmacies and 89% of GPs have participated in electronic prescribing,’ he said. ‘This is very positive progress. Electronic prescribing will dramatically reduce many of the medicine safety problems that occur in prescribing and dispensing.
‘It may be helpful to provide updated fact sheets and details of electronic prescriptions when chasing up faxed prescriptions. This includes the option of emailing an electronic prescription token to patients and/or pharmacies.
‘I am hopeful the inconvenience of faxing and posting prescriptions to a pharmacy will see more prescribers issue more prescriptions as eScripts, which will in turn reduce the administrative burden of chasing original scripts on pharmacists’
5. In NSW or Victoria the transition may be trickier
Most states and territories have a legal framework that is directly linked to the PBS instrument, which will automatically reflect these changes. Therefore, digital image prescriptions written from 31 March will not be legally valid.
New South Wales and Victoria, however, have separate legal instruments with different expiry dates for digital image prescriptions.
New South Wales
In NSW, image-based prescriptions will remain legal for private prescriptions until 30 September 2022, but cannot be supplied as PBS prescriptions. According to NSW Health, ‘image-based prescriptions can only be issued and dispensed for Schedule 4 medicines, except those in Appendix D (S4D medicines). S4D medicines and Schedule 8 (S8) medicines are not included in the temporary arrangements due to risks associated with fraudulent prescription and supply.’
PSA’s NSW State Manager Simone Diamandis FPS said this will be challenging for pharmacists.
‘This is going to be a nightmare for pharmacists,’ she said. ‘Pharmacists will be in the unenviable position of needing hard-copy prescriptions to claim PBS reimbursement, while doctors will likely be unaware of this change.
‘PSA has written to the AMA and RACGP to ensure they have strong messaging to NSW prescribers to cease issuing digital image prescriptions from 31 March 2022.
‘Patients will be caught in the middle, and may get slugged with the full cost of their medicines if the original prescription is unable to be sent to the pharmacy.’
Victoria’s public health emergency order (PHEO) #4, which allowed digital image prescribing in the state, is due to expire on 30 June 2022.
The Victorian Department of Health will shortly revise PHEO #4 to end image-based prescribing outside of a hospital setting. This will align Victorian legal requirements for pharmacists and prescribers with the PBS funding arrangements. The PSA COVID-19 microsite will be updated when these changes occur.
6. The only exception are scripts written in hospitals and dispensed in hospitals
Digital image prescriptions for hospitals will be extended until 31 March 2023. These prescriptions may only be supplied by a hospital pharmacy. This includes both public and private hospitals.
Tips for breaking the news to prescribers
Lauren Haworth MPS, Pharmacist in Charge at TerryWhite Chemmart Maddingly in central Victoria said it’s crucial to ‘get on the front foot’ and explain the changes and options available to prescribers.
‘I went in prepared to troubleshoot with solutions to the questions that I thought they were going to ask me,’ she said. ‘They were very grateful for the call because none of them knew that this was happening.’
One local GP clinic, for example, has a high proportion of non-Medicare card holders, which makes it difficult to issue electronic prescriptions to these patients.
‘We ran through the ins and outs of what that would mean for them, and a way that we could get around [the issue],’ she said. ‘We discussed that they can use our email address for the patient, and those scripts can come directly to us.’
Prescribers also need to know the services that pharmacists are still able to provide, Ms Haworth said.
‘[For example] we pick up original scripts at least once a week, so that’s an option if the patient doesn’t need it immediately,’ she said.
Further details are expected on the PBS website in the coming days.