Prescribing rights have been extended beyond the traditional remit of doctors and dentists to other healthcare professionals (e.g. nurse practitioners, podiatrist) as a way to enhance the range of services provided to clients and improve access to healthcare. This is often referred to as 'non-medical prescribing'.

In Victoria, the Drugs, Poisons and Controlled Substances Act 1981 and the Drugs, Poisons and Controlled Substances Regulations 2017 authorise certain registered professionals to prescribe scheduled medications.

To ensure that non-medical prescribing at Ballarat Health Services is carried out in accordance with relevant State and National legislations, and is supported by local guidelines.

AHPRA: Australian Health Practitioner Regulation Agency.

Local Formulary: An approved list of medications from which suitably endorsed health practitioners may prescribe from whilst practicing at Ballarat Health Services. It may contain medications that can be prescribed independently and medications which must be prescribed in consultation with a Medical Practitioner.

Non medical prescribers: Any registered health professional other than registered doctors and registered dentists who are endorsed to prescribe by their associated Board.

Notation Category: The categories of Nurse Practitioners listed by the Australian Health Practitioner Regulation Agency for the purposes of prescribing in Victoria.

Nurse Practitioner: A nurse whose registration has been endorsed by AHPRA as a nurse practitioner under Section 95 of the Health Practitioner Regulation National Law Act. The endorsement is attached to specific clinical areas of practice.

Registered health professional: A person registered under the Health Practitioner Regulation National Law to practise in his/her profession.

Non medical prescribers intending to prescribe medications for patients of Ballarat Health Services (including inpatients, outpatients, community and regional health services arrangements) must firstly obtain:

• Registration with AHPRA. Nurses wishing to prescribe must be registered as a Nurse Practitioner or Midwife (as applicable).

and

• A notation category/categories or endorsement from AHPRA for the purposes of prescribing in Victoria relating to their area of expertise and scope of practice.

and

• Work within their scope of practice. Non medical prescribers, with the exception of nurse practitioners must provide an individual local formulary approved by the BHS Medication Safety Committee from which to prescribe.

It is the responsibility of any non medical prescriber to prescribe only in accordance with his or her area of competence, following local guidelines and relevant legislation.

Obtaining an Approved Formulary

To obtain an approved formulary at Ballarat Health Services, the non medical prescriber seeking approval must forward to the Secretary of the BHS Medication Safety Committee:

• His or her name and AHPRA registration number.
• His or her notation category/categories (nurse practitioners) or endorsement for the purposes of prescribing in Victoria.
• A list of medications (if applicable) to be prescribed independently.
• A list of medications (if applicable) to be prescribed in consultation with an appropriate Medical Officer (if required).

The non medical prescriber’s formulary, where required, must only include medications which the prescriber is competent and confident in using, and which appear on the relevant list of medications for their notation category/endorsement published by the Victorian Health Minister.

The non medical prescriber must also remain informed about any changes to the medications that can be prescribed within his/her notation category/endorsement and advise the BHS Medication Safety Committee as soon as possible for consideration of any amendments to the formulary.

Formulary Approval

Upon receiving an application for a non medical prescriber’s formulary, the BHS Medication Safety Committee must:

• Ensure all listed medications can be legally prescribed by the applicant by checking with the most up to date list from the Victorian Department of Health.
• Ensure that all medications listed are safe and appropriate for use by the non medical prescriber.

The BHS Medication Safety Committeee may, where appropriate, authorise restrictions on the prescription of medications by non medical prescribers.

The BHS Medication Safety Committee will advise the non medical prescriber of any changes made to the proposed formulary. Once approval is granted, the BHS Medication Safety Committee will inform the Pharmacy Department, the applicant, the relevant Director and the Medical Advisory Committee of the approval in writing, including a final copy of the formulary. Each non medical prescriber’s formulary will be available as an Appendix to this Policy.

The non medical prescriber must immediately inform the BHS Medication Safety Committee if any restrictions have been placed on their prescribing by AHPRA or their notation becomes non current.

Updating the Non Medical Prescriber’s Formulary

A non medical prescriber can update his/her formulary by submitting a revised list to the BHS Medication Safety Committeee for consideration.  The submission must include his/her name and notation category/endorsement, a list of changes and the reason for these changes. The non medical prescriber must also undertake a review of his/her formulary every five years and submit to the BHS Medication Safety Committee for endorsement.

Prescribing

For medications which the non medical prescriber is able to prescribe within their scope of practice, no specific requirements beyond this document need be followed.

For medications which the non medical prescriber is able to prescribe in consultation with a Medical Officer under his/her formulary, the Medical Officer must be an advanced trainee or consultant within the area of notation/endorsement. The non medical prescriber must endorse the prescription with the name of the Medical Officer consulted.

It is the responsibility of the prescriber to ensure that he/she is not prescribing outside of legal requirements.

The prescriber must sign the prescription or order and specify their name, role and notation category/endorsement on each prescription or order.

The prescriptions must meet all legal requirements as outlined in the applicable legislation (including compliance with restrictions placed on their prescribing by AHPRA) and align with PBS requirements.

As per the Drugs, Poisons and Controlled Substances Regulations 2017 (Vic)

An authorised prescriber must not issue a prescription for a Schedule 4 or Schedule 8 poison unless:

• the prescription is for the treatment of a person other than the prescriber; and
• that person is:
  • under the precriber's care; and
  • named in the prescription; and
• the prescriber has taken all reasonable steps to ensure a therapeutic need exists for that poison; and
• the prescription is issued not merely for the purpose of supporting the drug dependence of a person; and
• if the poison is a drug of dependence, the prescriber has taken all reasonable steps to ascertain the identity of the person for whose treatment the prescription is issued.

Podiatrists and optometrrist must not issue a prescription, write an order for, sell, administer or supply:

• an ovulatory stimulant; or
• a prostaglandin; or
• a retinoid; or
• thalidomide; or
• methadone.

Prescribing Under the Pharmaceutical Benefits Scheme (PBS)

Where possible, prescribing for outpatients, or on discharge, must utilise the PBS for funding. Certain medications have one of the following designations attached to their PBS listing:

• Shared Care Model (SCM). PBS subsidy is only available for these items where there is a formalised arrangement to share care of a patient with a Medical Practitioner.
• Continuing Therapy Only (CTO). PBS subsidy is only available for these items where a Medical Practitioner has initiated supply and a non medical prescriber is continuing supply.

Note that the availability of PBS funding for a medicine does not imply that it is legal for a non medical prescriber to prescribe that medicine in Victoria. It is simply an approval of funding, where the prescription is otherwise legal. Similarly, a lack of PBS funding does not imply that a non medical prescriber cannot prescribe the medicine legally.