Prescribing by registered nurses and pharmacists

1.1. Which regulatory option do you support for prescribing by designated registered nurse prescribers (DRNP)?

Four options on how the Medicines and Poisons Regulations could be amended to authorise prescribing by DRNP are described in the Consultation discussion paper. Please read the Consultation discussion paper: Prescribing by pharmacists and registered nurses for further detail about the options, including the advantages and disadvantages of each option.

Option 1: Do not authorise DRNP to prescribe in Western Australia (no change to the Regulations).

Option 2: Authorise prescribing and require adherence to the Nursing and Midwifery Board of Australia (NMBA) guidelines.

Option 3: Authorise prescribing and detail any additional requirements in the Regulations.

Option 4: Authorise prescribing and detail any additional requirements in a mandatory 'prescribing instrument', referenced in the Regulations.

Option 1 - no change, DRNP not authorised to prescribe in Western Australia Option 2 - authorise DRNP prescribing and refer to NMBA guidelines Option 3 - authorise DRNP prescribing and include requirements in Regulations Option 4 - authorise DRNP prescribing and include requirements in a mandatory 'prescribing instrument' None of the options are suitable Unable to comment

1.2. If you supported Regulatory Option 3 or Regulatory Option 4, please comment on whether any of the suggested requirements described in the Consultation discussion paper should be modified or removed, and what modification should be made:

The suggested requirements are detailed on pages 10 and 11 of the Consultation discussion paper.

1.3. If you supported Regulatory Option 3 or Regulatory Option 4, are there additional specific requirements that should be included in the Regulations or in a 'prescribing instrument'?

1.4. If you selected Regulatory Option 1 (Do not authorise prescribing by DRNP), please explain why you chose that option and, if applicable, provide information about other mechanisms that could be used to authorise prescribing by DRNP:

1.5. Which autonomous prescribers should be able to enter into a prescribing agreement with a DRNP?

Medical practitioner Nurse practitioner Dentist Endorsed midwife Endorsed podiatrist Endorsed optometrist

1.6. If you did not select all the autonomous prescribers in Question 1.5, please explain why you excluded certain classes of autonomous prescriber:

1.7. How supportive are you of DRNP issuing prescriptions for Schedule 8 (S8) medicines?

Schedule 8 (S8) medicines (also known as controlled drugs) include medicines like morphine, oxycodone, tapentadol, dexamfetamine and methylphenidate.

Very supportive Somewhat supportive Neither supportive nor unsupportive Somewhat unsupportive Very unsupportive

1.8. If you answered 'very unsupportive' or 'somewhat unsupportive' at question 1.7, please explain why you chose this option:

1.9. Please select any of the following factors that would increase your level of support for Schedule 8 (S8) prescribing by DRNP:

Limit S8 prescribing to oral opioids for acute pain. Only allow DRNP to prescribe up to 14 days treatment. Not allow repeats to be prescribed. Only allow DRNP to prescribe S8 medicines in circumstances where no WA Department of Health authorisation is required (see below for explanation). Only allow prescribing of fully TGA registered products (this means medicinal cannabis would be excluded). Not allow prescribing of stimulant medicines, even if the stimulant was commenced by a specialist prescriber. Only allow S8 prescribing when DRNP have access to ScriptCheckWA, with the exception of prescribing for hospital inpatients and people in residential care or custodial settings. Only allow DRNP to prescribe S8 medicines for adult patients. None of the above factors would increase my support for S8 prescribing by designated registered nurse prescribers.

Prescribing authorisation from the WA Department of Health is required in high-risk circumstances. Examples include:

If the patient is experiencing, or has a history of, drug dependence.
If high doses of opioids are to be prescribed.
If injectable forms of S8 medicines are to be prescribed (except for 'end of life' care).

1.10. If there are any other factors which would increase your support for Schedule 8 (S8) prescribing by DRNP, please provide details:

Prescribing by registered nurses and pharmacists

1. Designated registered nurse prescribers (DRNP): regulatory options and Schedule 8 prescribing