by Brianna Porter
Knowledge Director
Sitting in my office in the south of Sydney it seems to be every week we are hearing about another compounding pharmacist being brought up on the accusation of closed loop arrangements. There is an emerging trend of all-in-one online clinics for all sorts of ailments or patient groups such as men’s health, personalised skincare or vitamins, where you take an online survey, this is assessed by a doctor and you receive your medication in the mail. Simple, right?! These are the traps that some pharmacists are falling into seeing the opportunities for increased prescription numbers but missing the intricacies of the regulations. Don’t get me wrong here, if this is managed in line with regulation and best practice for prescribing and dispensing then these are very convenient tools for the consumer (I know I’m loving telehealth!). But the digital world presents us with a lot of what-ifs.
Whether knowingly or otherwise, these pharmacies are entering into exclusive arrangements with prescribers which contravene the pharmacy board of Australia’s guidelines. The guidelines on compounding of medicines states that;
“pharmacists must not enter into arrangements for exclusive supply of prescriptions for compounded medications from a health practitioner/prescriber or other third party”
Collaboration with prescribers is very important in compounding but we need to set clear boundaries to ensure that those relationships don’t interfere with regulatory compliance and patient’s rights.
The Code of Conduct for Pharmacists states that part of providing good care, is recognising and respecting the rights of patients to make their own decisions. Decisions extend to where their prescriptions are being filled, for all types of medicines not just compounding. Clinics or prescribers are of course able to forward prescriptions onto pharmacies on behalf of their patients but they must receive consent from the patient to do so and the patient has to have knowledge of where their dispensing records are being kept. The patient is well within their rights to have their prescriptions filled elsewhere should they chose to do so.
Dispensing prescriptions that have been forwarded from prescribers is done so under the same conditions and requirements as any other prescription. The pharmacists’ part in the prescription medicine process is as the gate keeper. The compounding pharmacist needs to assess each prescription for risks associated not only with their premises, personnel and the product itself, but also in regards to other patient risk factors such as other medications and medical history. Then once compounded, the pharmacist is required to offer the patient specific guidance on their compounded product, such as why it has been compounded, how to use the product and adverse reactions to be on the lookout for. All these things are key in-patient safety when dispensing medicines. Recent horror stories in the pharmacy media have shown the importance of the pharmacist’s role and what happens when they don’t fulfil their professional obligations.
If you are working with clinics or looking to start, make sure you are setting clear boundaries and fulfilling your professional obligations. Risking your patient’s safety, your business and in some instances your ability to practice should not be a pre-requisite for prescriber collaboration or referral.