AMA submission on the NPS Prescribing Competencies Framework Project

20 Feb 2012

Dear Dr Weekes

I am writing in response to your invitation for submissions to the National Prescribing Service (NPS) Prescribing Competencies Project.

As requested, the AMA has provided track-changes to the NPS draft document supplied. In addition, we would also like to make some more general comments in response to the draft.

Prescriber Training

It is the AMA’s view that prescribers of medicines must be adequately trained in organic and inorganic chemistry, physiology, biochemistry, and anatomy. Only after completing an educational program that offers this level of core training, would a health practitioner meet the competency requirements to prescribe.

Currently, only medical practitioners receive this level of training.

Additionally, from our knowledge of education and training programs only medical practitioners would fully meet Performance Criteria 3.6.1 Synthesises information obtained from the comprehensive assessment, investigations and diagnostic tests and establishes a diagnosis.

Scope of Practice

The framework should place greater emphasis on:

  • practitioners prescribing within their scope of practice;
  • being competent in using knowledge and making judgments on when not to prescribe;
  • referring a person to another health professional when that person’s clinical condition is outside scope of practice; and
  • referring a person to a medical practitioner if they fail to improve within a specified period of time.

Conflict of Interest

It should also be a requirement that prescribing and dispensing must be kept separate to reduce the inherent conflict of interest. However, under the broad definition of medicine contained in the draft framework, it is possible that some non-medical health practitioners will be ‘prescribing’ and dispensing, e.g. Chinese medicine practitioners and herbal medicines.

Effective Communication

It is an essential core competency for practice in Australia, and critical to the quality use of medicines, that a prescriber can communicate in English.

We look forward to further involvement during the latter stages of your project, and to receiving the second draft framework for comment in due course.

Yours sincerely

Professor Geoff Dobb
AMA Therapeutics Committee