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

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 No action required.
medicines to clients of remote area ATSIHSs and
No Action Required
should be continued.
All sources of data suggest a significant increase in
medicine utilisation.
2 Bulk supply has increased medicine utilisation The Government is committed to bulk supply and
however it would be enhanced by further attention the Quality Use of Medicines. For example, through Completed
to QUM. the development of guidelines and training modules
A number of case study sites suggested that the shift (refer to recommendations 13, 16.3, 22 and 23).
to bulk supply was a key factor in overcoming

1

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 Workforce or legislative issues that may prevent a small
the implementation of S100 in sites where bulk number of remote area ATSIHSs from taking full
Ongoing
supply can not be adequately supported. advantage of these alternative PBS supply arrangements
should be addressed in the context of workforce and (MOU)
S100 could not be fully implemented in a few areas
because of barriers to the implementation of bulk legislative reforms.
supply. Incorporating flexible options would enhance
the ability of the program to improve access to This issue will also be explored in the context of
medicines. These options should address methods renegotiating the bilateral MoUs that underpin these
for enabling individual supply in the context of S100 arrangements in State/Territory operated services.
whilst ensuring appropriate reimbursement and
without reintroducing the financial barriers to access.
4 DoHA should expand the range of medicines As announced in the 2004-05 Budget, the Australian
covered by S100 to include non-PBS medicines Government has improved the capacity of the
Completed
commonly used in Aboriginal and Torres Strait Pharmaceutical Benefits Scheme to meet particular needs
Islander communities (e.g. topical antifungals). in Indigenous health. Benefits of this measure are not
S100 does not cover non-PBS medicines. This creates restricted to remote areas. The mechanism to enable these
additional costs for ATSIHSs and creates perverse medicines to be listed on the PBS has been established.
incentives to use PBS medicines when a non-PBS
option is more appropriate.
4.1 DoHA should review access to Schedule 8 Regulatory control over the prescribing, storage and
medicines in remote areas. supply of drugs of addiction rests with the States.
Ongoing
Schedule 8 medicines are not covered under S100 Consideration of options for appropriate access to these
because these medicines are subject to stringent medicines for clients of participating remote area ATSIHS
controls because of their addictive potential. A is most appropriate through the National Coordinating
number of sites suggested that difficulties of accessing Committee on Therapeutic Goods.
such medicines in remote areas had negative health
impacts, particularly for palliative care clients.

2

5 Geographic restrictions in eligibility for S100 have The Rural, Remote and Metropolitan Areas (RRMA)
caused difficulties in accessing and implementing classification scale is an appropriate basis for determining
Ongoing
the program and these should be reviewed. ‘remoteness’ in this context. However, there remain some
For example, Gurrinny Yealamucka Health Services, interface issues, including those outlined in the evaluation
Yarrabah falls just outside of the remote zone and so report which will be addressed on a case-by-case basis.
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).
6 DoHA should retain “clients of approved There is no specific action required in response to this
ATSIHS” as the criterion for individuals to benefit recommendation. Any ambiguity over eligibility will be
No Action Required
from the program. addressed on a case by case basis.
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.
7 DoHA should ensure that all MOU indicate that a This recommendation is relevant to participating remote
high priority for reallocating funds resulting from area health services operated by the States and Territories. Ongoing
S100 is to ensure that ATSIHSs have sufficient The various state Aboriginal and Torres Strait Islander
staff and resources to effectively implement the Health Forums have an active role in determining (MoU)
priorities for the reallocation of funds resulting from state

3

program. government participation in these arrangements.
In many cases savings were spent on increasing
capacity in relation to S100. In other cases funds This issue will also be explored in the context of
remained unspent despite the health service being renegotiating the bilateral MoUs that underpin these
stretched to capacity. In some cases this was due to arrangements in State/Territory operated services.
delays in the consultation process in others it was due
to difficulty finding staff.
8 DoHA should ensure that funding for Doctors at The Government supports increased medical workforce
S100 approved ATSIHSs is maintained and further engagement in ATSIHs through a number of initiatives,
Ongoing
facilitated. including s19(2) exemptions provided under the Health
ATSIHSs with a Doctor were more likely to report an Insurance Act 1973 and funding for primary health care
increase in the amount of medicines prescribed and services.
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.
9 DoHA should clarify the program in relation to Clarification has been provided on this issue, namely that a
whether prescriptions made at another facility can prescription made at an approved ATSIHS can be filled at
Ongoing
be filled at S100 approved sites, repeat a second approved ATSIHS as long as the requirements,
prescriptions and the ability of visiting physicians in particular record-keeping requirements, of the S100
to supply medicines using 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.

4

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 Discussions with Medicare Australia have been initiated to
ATSIHSs to enable them to keep track of their explore ways to improve availability of expenditure and
Ongoing
own performance. medicine utilisation.
Originally HIC was to provide clinics with data on
their medicine utilisation however this has not
occurred to date.
10.2 A system to assess the quantum of medication This matter has been referred to the National Return of
that expires in ATSIHS should be considered to Unwanted Medicines (NATRUM) for consideration.
Ongoing
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.
10.3 DoHA should update records of ATSIHS client The Department is undertaking a process to update
numbers to ensure that any comparisons between ATSIHS client numbers.
Ongoing
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.

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

5

11 DOHA should examine mechanisms for The Department is considering ways to ensure that staff at
providing more extensive support to ensure that participating health services are apprised of their
Ongoing
S100 is implemented in a way that is compliant responsibilities in the context of the supply and
with State and Territory legislation and management of medicines. The collaborative (MoU)
regulations. Best practice may require review and development of a compliance self-assessment tool (see
amendment of existing legislation in some cases. recommendation 12) or regular newsletters would be
These additional support mechanisms should beneficial to improve the clarity of roles, regulation and
take into account that ATSIHS are at different recognition of Aboriginal and Torres Strait Islander
stages of their implementation of S100 and have Health Workers.
different needs. This issue will also be explored in the context of
renegotiating the bilateral MoUs that underpin these
arrangements in State/Territory operated services.
12 A self assessment tool addressing legislative The Department will assist in the production of a self
compliance issues should be made available to assessment tool or newsletter to help clarify information
Ongoing
ATSIHSs to complete with their supporting about achieving compliance and identifying persisting
pharmacists. The self assessment tool could be issues with compliance. (MoU)
designed in collaboration with the DoHA, the
Guild, NACCHO and State and Territory This issue will also be explored in the context of
government. This assessment could be used both renegotiating the bilateral MoUs that underpin these
as a way of reflecting on progress at ATSIHSs but arrangements in State/Territory operated services.
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.

6

13 DoHA should develop a central resource for S100 In consultation with stakeholders, the Department will
to enable sharing of information and learnings. explore a number of communication channels, such as a
Ongoing
A number of ATSIHSs and pharmacists felt that regular newsletter, to enable sharing of information and
experiences. These measures can also be linked with (MoU)
access to resources developed by others would have
helped their implementation and would have saved efforts to clarify legislative requirements and other aspects
labour associated with repeating work conducted by of the program.
others. The importance of sharing information across
Community-Controlled and State and Territory- This issue will also be explored in the context of
operated ATSIHS was also stressed by some key renegotiating the bilateral MoUs that underpin these
informants. arrangements in State/Territory operated services.
14 DoHA in conjunction with State and Territory See responses to recommendations 11 -13.
Governments, the Guild and NACCHO should This issue will also be explored in the context of Ongoing
develop a resource that clearly states how the law renegotiating the bilateral MoUs that underpin these
and regulations should be applied to remote (MoU)
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.
15 DoHA should work with State and Territory The Government will continue to work with the States
Governments, the Guild and NACCHO to identify and Territories to address identified barriers.
Ongoing
ways of facilitating the operation of S100 approved
services in jurisdictions where there are legal and (MoU)
This issue will also be explored in the context of
regulatory barriers to program implementation renegotiating the bilateral MoUs that underpin these
(see rec 14). arrangements in State/Territory operated services.
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.

7

16 DoHA with State and Territory Governments, the
Guild and NACCHO should examine ways of
No Action Required
supporting systemic changes in ATSIHSs that
would lead to improvements in legislative
compliance and QUM. Specific examples of
possible areas for improvement include:
16.1 IT funding and support is needed to address gaps As part of its commitment to improving IT infrastructure
in record keeping and legislative compliance in Aboriginal Community Controlled Health Services
Ongoing
problems arising from gaps in record keeping. (ACCHSs), the Australian Government announced in
A number of ATSIHSs suggested that compliance 2004 measures to support the uptake of broadband
would be assisted by development of computer technology in ACCHSs, to assist with improvements in
programs to streamline ordering, dispensing and administration and clinical practice. In addition, a
supply. These could be linked with labelling systems comprehensive audit to establish specific gaps in IT
and claiming systems. 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.
16.2 Funding for support to assist with dispensary The funding mechanism to cover such activities has been
organisation. established as part of the Community Pharmacy
Completed
The case study check list indicated that the Agreement – in particular the s100 Pharmacist Support
organisation of dispensaries was an area for Allowance. Support is ongoing.
improvement particularly in terms of areas like shelf
labelling.
16.3 A set of standards for delivery of pharmacy Professional practice standards have been developed by
services should be developed. the Pharmaceutical Society of Australia.
Completed
A set of guidelines for the delivery of pharmacy
services would assist Pharmacists in supporting
ATSIHSs.
16.4 A generic set of procedures and protocols should See response to recommendation 13.
be developed that can be adapted for local use. This issue will also be explored in the context of Ongoing
This should be located on a central website (see renegotiating the bilateral MoUs that underpin these
(MoU)

8

recommendation 14). This would prevent work being arrangements in State/Territory operated services.
replicated at different ATSIHS.
16.5 Designated staff should manage dispensaries The Government supports service-based decision making
where possible. in the allocation of staff responsibilities. Note, that the
Completed
Legislative compliance was better in ATSIHSs when Department is also developing tools to assist compliance
responsibility for managing the dispensary was limited (refer to recommendations 11 to 13).
to particular staff members.
16.6 Enhanced training should be provided to ensure See responses to recommendations 22 and 23.
medicines are supplied appropriately.
Completed
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.
16.7 Processes should be introduced to review errors in The Department is exploring ways to provide guidance
order to inform future training and quality material on error minimisation through good dispensing
Ongoing
management. practice through the distribution of a newsletter.
(MoU)
Mistakes are sometimes made in all environments
where medicines are supplied. Improving service This issue will also be explored in the context of
quality is dependent on ensuring that problems can be renegotiating the bilateral MoUs that underpin these
identified and addressed. arrangements in State/Territory operated services.

16.8 ATSIHSs and Pharmacists should develop The funding mechanism to cover these activities has been
communication strategies to ensure imprest lists established as part of the Community Pharmacy
Completed
are regularly reviewed and issues with stock at the Agreement – in particular the s100 Pharmacist Support
pharmacy and transport to the ATSIHS are Allowance. Support is ongoing.
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.

9


Administration

17 DoHA and HIC in consultation with State and Agreement has been reached with stakeholders on options
Territory Governments, the Guild and NACCHO to be used by ATSIHSs to order PBS medicines through
Ongoing
should develop an electronic means for ATSIHSs S100 arrangements, and has been disseminated to
to order from pharmacists. 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.
18 DoHA and HIC in consultation with stakeholders Discussions with Medicare Australia have been initiated to
State and Territory Governments, the Guild and explore ways to improve PBS claiming facilities for
Ongoing
NACCHO should develop an electronic means for pharmacists.
pharmacists to claim from HIC.
19 DoHA and State and Territory Governments As outlined in the response to recommendation 7, in
should develop a mechanism to provide greater relation to remote area health services operated by the
Ongoing
support to alleviate increased workload at States and Territories, the Government supports capacity
ATSIHSs. building as a high priority for reallocation of funds made (MoU)
Bulk supply moves work formerly done at a pharmacy available through participation by State/Territory
to an ATSIHS. Some services have been able to use Governments in these PBS supply arrangements. In the
money reallocated from their pharmacy budget to community controlled sector, the Government supports
fund extra staff to do this work but others have not service-based decision making in the allocation of staff
had sufficient funds. A particular area of concern was responsibilities.
that a number of ATSIHSs had equipment (e.g. for
labelling) that was not being used. Better support of This issue will also be explored in the context of
systems would alleviate these problems. renegotiating the bilateral MoUs that underpin these

Impact on Pharmacists

10

20 DoHA should increase the level of remuneration This is being considered under the Fourth Community
for pharmacists through S100. Pharmacy Agreement as part of the review of the S100
Ongoing
Pharmacists felt that the current level of remuneration supply arrangements. The Fourth Community Pharmacy
under S100 was insufficient given the level of service Agreement primarily contains the remuneration
provided. It should be noted that the dispensing fee arrangements for dispensing of PBS medicines by
for S100 is considerably lower than the dispensing fee community pharmacists.
for S85. One area that is seen as particularly
problematic is listed below.
20.1 An additional freight component should be added See response to recommendation 20.
to the S100 handling fee where applicable.
Ongoing
A number of ATSIHSs and Pharmacists felt that the
current rate either did not or did not sufficiently cover
freight costs.
21 The Guild, NACCHO and DoHA should review Revised arrangements are in place for s100 allowance
the requirements and provisions of the support under the Fourth Community Pharmacy Agreement,
Ongoing
allowance. including increased payment rates. The Professional
The presence of visiting Pharmacists was associated Programs and Services Advisory Committee (PPSAC) is
with greater increases in medicine utilisation reviewing eligibility and administrative arrangements.
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.

11

21.1 Review of the support allowance should take into See response to recommendation 21.
account the stage ATSIHSs are at in terms of their
Ongoing
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.
21.2 Review of the support allowance should take into See response to recommendation 21.
account the need to obtain pharmacy relief.
Ongoing
Lack of locum services were a barrier to Pharmacist’s
providing support services to ATSIHSs.

Impact on S100 on Aboriginal and Torres Strait Health Service Staff

22 Further development of pharmacy modules for The Government has worked with the States and
ATSIHWs is needed and this should be in the Territories and other stakeholders to improve the clarity
Completed
context of the national processes for development of roles, and recognition of Aboriginal and Torres Strait
and review of AHW competencies overall. 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.
23 More in-service training should be made available See response to 22.
for ATSIHWs to overcome the lack of formal Short intensive training course may be quickly developed Completed
pharmacy training at present. based on the units of competency contained in the Health
Any additional training program would take time to Training Package (HLT07). On the successful completion
implement. Additional training at ATSIHSs is required of the training, Statements of Attainment for the
as soon as possible therefore short term in-service competencies successfully attained is awarded.
programs would be useful. These could be used as a
basis for piloting modules for a more comprehensive
program.

12

24 Training initiatives should be accompanied by See response to recommendation 22.
measures such as provision to staff relief to
Completed
minimise barriers to their uptake and reduce
potential negative impacts on ATSIHS clients.

25 DoHA should fund the development of a See response to recommendation 22.
Pharmacy Technician program for ATSIHSs Any new program should aim to utilise the material in the Completed
based on an assessment of existing programs. Health Training Package (HLT07) and the associated
assessment and learning resources.

Quality Use of Medicines

26 DOHA with other stakeholders should review Evidence does not support universal acceptance of dose
legal and technical aspects of the use of dose administration aids in remote communities. In addition,
No Action Required
administration aids in ATSIHSs. ‘legal aspects’ in this context relate to the statutory
Changed supply arrangements under S100 mean that frameworks enacted by the States and Territories to
an increasing number of clients with complex safeguard public safety in the supply of scheduled poisons,
conditions are being managed at ATSIHS level. including prescription-only medicines. Decisions about
ATSIHSs vary in the extent to which they have the appropriate use of dose administration aids should be
expertise to deal with managing medication for these made locally, in accordance with good medication
cases. Dose administration aids of some kind were management practice.
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.
27 ATSIHSs and Pharmacists should review criteria The Government supports local decision making on the
for using dose administration aids. use of appropriate dose administration aids, in accordance
No Action Required
QUM could be improved if criteria for the use of with relevant State/Territory legislation.
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.

13

28 DOHA should in consultation with stakeholders Refer to the response to recommendation 26. Also,
fund the use of dose administration aids in existing s100 pharmacy support allowances made available
Completed
ATSIHSs in the context of pharmacy under the Fourth Community Pharmacy Agreement may
remuneration and consistent with the outcomes of be used to support activities requested by ATSIHSs,
the review (see rec. 26 ) including the repackaging of medicines in dose
administration aids.

29 DoHA should fund the adaptation/development The Government supports existing activities in this area
and distribution of information sheets on coordinated through the National Prescribing Service and
Completed
common and new medicines. the National Aboriginal Community Controlled Health
A number of ATSIHSs suggested that information Organisation (NACCHO), as well as the development and
sheets on common and newly emerging medicines. promulgation of medication handbooks written for
Information sheets would be a useful resource for Aboriginal and Torres Strait Islander Health Workers (eg
Aboriginal health workers and health staff as well as Medicines Book for Aboriginal Health Workers (first edition
clients. They would ensure that everyone kept up to 2005), a project funded by the Australian Government
date with the current medicine information. The under the Rural and Remote Pharmacy Infrastructure
National Prescribing Service and the Pharmacy Guild Grants Program (part of the Rural and Remote Pharmacy
have already developed some resources. These in Workforce Development Program).
addition to information from consumer organisations
could be assessed and adapted for ATSIHSs by
NACCHO and other interested stakeholders.

Performance under the MoUs

30 NT DHCS and QH need to extend their efforts to This recommendation relates to participating ATSIHSs
undertake steps to improve the QUM in all operated by the Governments of the Northern Territory
Ongoing
ATSIHSs as agreed in the MOU clause 5.1 and Queensland. This issue will also be explored in the
context of renegotiating the bilateral MoUs that underpin (MoU)
NT DHCS has taken some steps to improve QUM
and sought to minimise the impact of S100 on its these arrangements in State/Territory operated services.
services. However it is likely that additional support
will be required to facilitate the smooth transition
from Hospital to Community pharmacy. With the

14

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 This issue will also be explored in the context of
relevant Aboriginal and Torres Strait Islander renegotiating the bilateral MoUs that underpin these
Ongoing
Forums/Partnerships, should develop QUM arrangements in State/Territory operated services.
indicators and put in place measures to monitor (MoU)
performance against these indicators in line with
the MOU clause 5.1
32 DoHA should include regular reporting of This issue will also be explored in the context of
performance against QUM indicators to renegotiating the bilateral MoUs that underpin these
Ongoing
Aboriginal and Torres Strait Islander Forums in arrangements in State/Territory operated services.
the MOU. (MoU)
33 NT, DHCS, in consultation with the Aboriginal The Government supports consideration of a system wide
Forum, should consider a tiered approach to S100 approach to the quality use of medicines to enhance these
Ongoing
savings that would consider both Territory wide supply arrangements, in consultation with Aboriginal
and local needs. Health Forum partners. (MoU)
The centralised model for the distribution of savings
adopted by NT DHCS is efficient administratively, This issue will also be explored in the context of
directs monies into priorities that are likely to improve renegotiating the bilateral MoUs that underpin these
Indigenous health in a significant way and does enable arrangements in State/Territory operated services.
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.
34 NT DHCS should provide more comprehensive This issue will also be explored in the context of
Ongoing
feedback about expenditure of S100 savings. renegotiating the bilateral MoUs that underpin these
arrangements in State/Territory operated services. (MoU)
Many of the concerns about the NT DHCS were

15

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 Opportunities for simplifying the reporting requirements
requirements of the South Australian MOU so will be considered in the context of renegotiating the
Ongoing
that they are commensurate with the amount of bilateral MoUs that underpin these arrangements in
money involved. State/Territory operated services. (MoU)
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.
36 QH should review and upgrade the training of This issue will be considered in the context of
ATSHIS staff to ensue that all approved ATSIHSs renegotiating the bilateral MoU with Queensland.
Ongoing
are able to comply with legal and regulatory
requirements. (MoU)
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.
37 QH should demonstrate that they have Efforts to ensure that more timely expenditure data are
maintained expenditure on Indigenous Health by made available, as appropriate, to guide decision-making
Ongoing
providing evidence that savings from S100 have and reporting on initiatives arising from Queensland
been spent on Indigenous health in order to meet Health’s participation in these arrangements will be (MoU)
the requirements of their MOU. considered in the context of renegotiating the bilateral
To date, QH has only reported on anticipated MoU with Queensland.

16

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 The development of shared guidelines for the expenditure
develop guidelines for the expenditure of savings. of savings, with appropriate community consultation, and
Ongoing
A number of QH staff suggested that more guidance consistent with statewide health priorities will be
considered in the context of renegotiating the bilateral (MoU)
was required from DoHA about what savings should
be spent on. Developing shared guidelines could be an MoUs with the relevant States and the Northern Territory.
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.
39 DoHA and QH should develop a streamlined Privatisation of PBS medicine supply through local
system to reduce the administrative load community pharmacies (rather than through hospital
Ongoing
associated with claiming in sites with primary pharmacies), is expected to minimise these issues.
care and inpatient facilities co-located. (MoU)
In order to comply with the Australia Health Care This issue will also be explored in the context of
Agreement, medicines supplied to inpatients must be renegotiating the bilateral MoUs that underpin these
removed from HIC claims. This adds to the arrangements in State/Territory operated services.
complexity of the claim process.
40 QH should revise management structures in The Government supports improved communications to
relation to S100 so that ATSIHSs can receive management and staff of remote area health services
Ongoing
better support and that better accountability can participating in these PBS supply arrangements.
be achieved. (MoU)
A number of issues with accountability, reporting and This issue will also be explored in the context of
implementation appeared to relate to failures in renegotiating the bilateral MoUs that underpin these
communication Corporate Office and the Zones and arrangements in State/Territory operated services.
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

17

satisfaction.
41 Savings to the Torres Strait Island and Northern This issue will be considered in the context of
Peninsula Health Service District (TS and renegotiating the bilateral MoU with Queensland.
Ongoing
NPHSD) resulting from costs shifting to the PBS
should be indexed against CPI in order to achieve (MoU)
parity with other QH Health Service Districts.
42 QH should take steps to resolve anomalies in the This issue will be considered in the context of
implementation of S100 in the Torres Strait Island renegotiating the bilateral MoU with Queensland.
Ongoing
and Northern Peninsula Health Service District.
(MoU)
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.
43 QH should be required to move supply from This issue will be considered in the context of
Hospital to Community Pharmacists in future renegotiating the bilateral MoU with Queensland.
Ongoing
MOU.
(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.

18

44 Future MOU should take into account reform of This issue will also be explored in the context of
the Australian Health Care Agreement and its renegotiating the bilateral MoUs that underpin these
Ongoing
potential impact on clients of S100 approved arrangements in State/Territory operated services.
ATSIHS. (MoU)
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.

19

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