NSW Real Time Prescription Monitoring submission

Submission to the NSW Government’s Regulation to support Real Time Prescription Monitoring (RTPM) consultation paper

This RACP submission to the NSW Ministry of Health has been led by the Australasian Chapter of Addiction Medicine (AChAM) with input from the RACP-affiliated Australasian Society of Clinical and Experimental Pharmacologists and Toxicologists (ASCEPT) in response to the NSW Government’s Ministry of Health’s consultation paper on RTPM¹.

We welcome the Commonwealth Government and the NSW Government’s actions towards implementing RTPM of targeted high-risk medications as a way of reducing harm from prescription medicines. We regard the roll-out of RTPM as a rational response to consistent evidence of growing harms associated with certain prescription medications, particularly prescription opioids.

Prescription opioids, often combined with benzodiazepines, contribute to more deaths than illicit drugs in Australia. The latest figures from the Australian Bureau of Statistics (ABS)² on opioid-induced deaths in Australia show that opioids accounted for just over three deaths per day in 2018, the majority of which were unintentional overdoses in middle-aged males involving the use of pharmaceutical opioids, often in the presence of other substances. ABS data also show that prescription opioids were identified in over 70 per cent of these deaths with the natural and semi-synthetic opioids, including codeine, oxycodone and morphine being the most common prescription opioids present, followed by synthetic opioids.

RTPM can reduce the harm from overuse or inappropriate use of prescription medicines in two ways:

1. as a means to prevent more than one doctor from prescribing sedating medication to one patient at the same time 
2. by assisting in the identification of people who are most probably prescription drug dependent and for whom unsupervised sedative medication presents a particularly high risk. For opioid-dependent patients, supervised dosing for (for example with methadone or buprenorphine) may be the most appropriate course of action.

We support the proposed amendments to the legislation as set out in the NSW Ministry of Health’s Consultation Paper. We recommend that the NSW Ministry of Health and the NSW Government:

1. Implement wider service planning focused on improving availability and access to multidisciplinary teams of qualified health professionals with expertise in addiction medicine and pain management; increasing funding for addiction medicine and other evidence-based alcohol and drug treatment services more broadly, and training GPs in managing patients with prescription drug and other substance use disorders.
2. Ensure that prescribers are well informed about RTPM and how to support patients identified by the system through the development of the proposed training for all prescribers (i.e. both specialist physicians and GPs in addition to pharmacists) with expert input from addiction medicine specialists.
3. Develop clinical guidelines aimed at all prescribers to complement this training. These guidelines need to cover issues such as what actions prescribers should take when a patient is identified through RTPM, how prescribers should communicate with each other regarding notifications about an individual patient in their care and where prescribers should direct patients identified as having a substance use disorder for support and assistance.
4. Ensure that clear evidence-based guidance on safe and effective opioid tapering are made available to all prescribers.
5. Invest in research, evaluation and service models that combine pain and addiction medicine to build the evidence-base on how best to treat complex patients with concurrent chronic pain and substance use disorders.
6. Implement ongoing monitoring and evaluation of RTPM to ensure the system can be improved to best serve the health needs of patients and the broader community.

Sustained, long-term funding to increase the capacity of drug and alcohol services to meet the demand for treatment, combined with real and persistent efforts to reduce disadvantage and inequities within society, is the only real solution to reducing substance dependency. Access to quality treatment, delivered by a suitably trained workforce, is fundamental for anyone struggling with addiction, and this should be the main priority for policy development and investment in this area.

Read RACP submission

Footnote
1 NSW Health Regulation to support RTPM
2 ABS (2019), Opioid-induced deaths in Australia