30/1/2019. We support the proposal to amend the distribution arrangements and access criteria for the funding of dasatinib.
We raise some concerns about the education of patients and prescribers particularly around supply of this medicine and the time needed for the pharmacy to order it.
We also asked that PHARMAC encourage DHBs to consider funding a nationally consistent service for the disposal of cytotoxic medicines to remove the responsibility and financial burden from community pharmacy.
18/1/2019. We support the proposal to open access to atomoxetine and to change the funded brand. Removing all funding criteria will provide more options to patients with ADHD who previously were not eligible to access atomoxetine.
21/12/2018. We support the proposed listing of a new pack size of modafinil for narcolepsy.
We support the proposed listing of a new brand of methylphenidate extended-release tablets and the cost saving for the pharmaceutical budget that this will incur.
We support the proposed listing of glatiramer 40mg prefilled syringe and the resultant change in distribution arrangements for this medicine.
We support the change to distribution arrangements for Interferon beta-1-alpha (Avonex) and interferon-1-beta (Betaferon). We have always believed that it is in the best interest of patients to have their regular medicines managed and dispensed by community pharmacy.
21/12/2018. The Guild supports the proposal to list a new presentation of raltegravir and amend arrangements for raltegravir and posaconazole.
20/11/2018. We agree there is an issue with the mechanism of the current wastage rule and would support a change in the wastage rule where there would be less financial risk to community pharmacies. However, the Guild considers there is insufficient detail provided in the consultation to give an informed opinion on the proposal to change how discarded medicines are reimbursed. We request the opportunity to sit down in a wider stakeholder group to gather more information on the proposal to ensure that an appropriate solution can be found.
19/11/2018. We support the listing of colecalciferol oral liquid (Puria) in community and hospital from 1 January 2019. We agree that it will be beneficial to have a Vitamin D-only product available on the Pharmaceutical Schedule. We would encourage PHARMAC to ensure that a supply of Vitamin A-only liquid is found, also before the delisting of Vitadol C in order to ensure a continuous supply for patients.
7/11/2018. We supported the proposal to award sole supply and maintain existing brands for four antiretrovirals therapies (ARTs). We also supported the proposal to award sole supply and change brands for three ARTs and we also asked PHARMAC to provide patient education material to support the brand changes and apply the wastage rule should the new ARTs be high cost items when they become listed.
25/10/2018. We supported the proposal to decrease the price and award sole supply for alendronate.
26/9/2018. We opposed the proposal to move to one funded brand of lamotrigine. We felt the pharmaceutical savings would be insignificant when counterbalancing the potential implications that the proposal could have at a patient level. We would be supportive to fund multiple brands to the proposed subsidy for Logem and apply a manufacturer’s surcharge when these brands are dispensed.
17/9/2018. We supported the proposal to list sapropterin for use in pregnancy by women with phenylketonuria.
10/9/2018. We supported the proposal to change the funded brand of epoetin alfa as the access and supply criteria will remain unchanged. We also requested a brand switch fee to reflect the extra work involved for community pharmacy.
4/9/2018. We supported the proposal to fund nintedanib (Ofev) for idiopathic pulmonary fibrosis (IPF), this will provide an additional treatment option for eligible IPF patients and could be accessed earlier than the currently available option. It is a high cost medicine so we asked for the wastage rule to be applied.We supported removing Special Authority for tiotropium, which will provide improved access for patients with respiratory conditions for which tiotropium is indicated. We also recommended PHARMAC ensure the distributor holds sufficient stock to satisfy any increase in prescription volume.
25/07/18. We supported the proposal to delist the 35 ml vial presentation of heparin sodium injection 1,000 iu per ml. We also noted that community pharmacy had supported patients through the change from 35 ml vial to 5 ml ampoules for no extra payment when the supply interruption occurred in October 2017.
23/7/2018. We supported the proposal to fund five new treatments, widen access to three currently funded treatments and change the contractual terms for two currently funded treatments. We asked PHARMAC to apply the wastage rule to all strengths of two new high cost treatments to reduce the burden on pharmacies having to carry redundant stock unnecessarily.
11/06/2018. We supported the proposal to widen access and change the funded enzyme replacement therapy for Gaucher disease.
23/4/2018. We supported the proposal to remove the funding restrictions for candesartan.
20/4/2018. We supported the proposal to list mercaptopurine oral suspension.
16/4/2018. We supported the proposal to fund aflibercept and to open list rivaroxaban tablets.
26/3/2018. We supported the proposal to widen access by removal of restrictions for endorsement and Special Authority and change the funded brand of tenofovir disoproxil and entecavir. We requested pharmacy and GP software support and educational material for pharmacists, prescribers and patients to enable a smooth transition for these medicines.
6/03/2018. We opposed the Sustagen Hospital Formula list price increase and change to part charge. We raised our concerns about the financial impact supplying special foods has on community pharmacy. We also requested resources to help explain PHARMAC price changes and for processes on dealing with PHARMAC related consumer complaints.
27/02/2018. We supported the proposal to open list montelukast tablets, removing all restrictions on the funding criteria to give patients ready access to another form of treatment for asthma and allergy.
4/11/2017. We supported the proposal to widen funded access to emtricitabine with tenofovir disoproxil fumarate (Truvada) for HIV PrEP. We asked for the OP or wastage rule to me applied to this medicine.
28/11/2017. We supported the proposal to remove the MELD score requirement for ledipasvir with sofosbuvir, as this would increase access. We raised our concerns with the XPharm supply model. We supported the proposal to widen access to tenofovir disoproxil fumarate to include women of child bearing age with active hepatitis B. We asked for the OP or wastage rule to me applied to this medicine. We supported the proposal to widen the funding criteria for paromomycin to allow treatment of E. histolyica carriage.
20/11/2017. We supported Infatrini being available to those who need it through their community pharmacy. We raised our concerns about the financial impact supplying special foods has on community pharmacy.
20/11/2017. We supported the proposal to list methylnaltrexone bromide injections for opioid induced constipation in palliative care patients. We were pleased that both a single pack and pack of seven injections will be available.
9/11/2017. We supported the proposal to widen access to zoledronic acid for early breast cancer. We did not see any concerns for community pharmacy in this proposal.
9/11/2017. We supported the proposal to fund pregabalin and change the funded brand of gabapentin and listing restrictions. We would like to understand how the funding restriction preventing concurrent use of gabapentin and pregabalin will be administered and monitored. We are pleased pharmacies will be able to claim a brand switch fee for dispensings of Apo-Gabapentin from 1 November 2018.
03/10/2017. We supported the funding of zoster vaccine to people aged 65. We voiced our disappointment that pharmacists will not initially be able to supply funded zoster vaccine to their patients, and advocated on your behalf for PHARMAC to reconsider this decision.
03/10/2017. We supported the proposal to have funded dexamethasone 700 mcg ocular implants available through community pharmacy for patients who meet the funding criteria of diabetic macular oedema.
30/08/2017. Our submission covered pack size preference, that preference should be given to a company who can supply a pharmaceutical across the different strengths, the issues very plain and generic packaging can cause, required shelf-life of pharmaceuticals, out of stock arrangements and recalls. We also opposed the proposed provision to amend the terms and conditions relating to price changes.
28/8/2017. We supported the decision to widen access to funded ciprofloxacin 0.3% eye drops for the second line treatment of chronic suppurative otitis media (CSOM), however we expressed our concern that they want to introduce subsidy by endorsement for this product.
25/8/2017. This consultation was to expand the range of CareSens self-monitoring diagnostic meters and associated test strips in the community to include a meter that tests both blood glucose and ketones (CareSens Dual) and to widen the access to diagnostic testing for all people who may need ketone testing. While we were supportive of the proposal, we requested that PHARMAC consider a reimbursement fee for community pharmacy that adequately reflects the additional work required in managing the changeover of meters.
11/8/2017. We strongly supported the proposal to allow pharmacists to provide funded NRT and ECP without a prescription. We see this as a step in the right direction for providing nationally consistent pharmacy-based services. We believe this proposal will enable the CPSA pharmacy based smoking cessation services.
11/8/2017. We supported increasing access to aripiprazole. We raised concerns about sole supply arrangements and the work required by pharmacists to switch patients from one brand to another. If the proposal goes ahead we requested pharmacies are paid a brand switch fee.
3/8/2017. We supported to continue to fund the Habitrol brand of nicotine gum, lozenges and patches supplied by GlaxoSmithKline Consumer Healthcare Limited (GSK). We raised a concern about the new 1-week packs being listed in the Schedule if supply is not through community pharmacy.
21/6/2017. While we supported the proposal for iron infusions to be fully funded when dispensed from a community pharmacy for patients with a prescription and a valid Special Authority. We pointed out community-based infusion services are not nationally consistent and would require general practices or other primary health providers to be appropriately trained, as well as to have a minimum standard of safety equipment, including resuscitation equipment. There also needs to be collaboration between the prescriber and community pharmacy to inform patients about the availability of local community-based infusion services and any related-service charges.
26/6/2017. In this submission we supported the decision to allow patient switching between erlotinib and gefitinib and the decision to list the 15mg strength of lenalidomide. We requested the wastage rule to be applied to erlotinib, gefitinib and thalidomide, and that the 5mg strength of lenalidomide was also listed. We felt we could not support the change in claiming category for thalidomide from PCT only to Retail pharmacy unless community pharmacies are reimbursed a higher handlining fee for dispensing thalidomide.
26/5/2017. In this submission included we supported changes in the funding criteria for antiretrovirals, azithromycin, lamivudine, ledipasvir and sofosbuvir, and roxithromycin, as this would improve access to these medicines. We requested the OP or wastage rule was applied to antiretrovirals and lamivudine. We asked for the supply model of ledipasvir and sofosbuvir to be revised, and we thought the funding of roxithromycin dispersible tablets should be extended to include adults and children over 12 years of age who are unable to swallow tablets.
As a result of this submission PHARMAC decided to add the OP rule to lamivudine oral liquid 5 mg per ml.
26/5/2017. We supported the decision to fund modified-released melatonin for insomnia in children and adolescents with neurodevelopmental disorders subject to Special Authority conditions. We also suggested the funding was extended to include treatment of insomnia in people aged 55 and over.
16/5/2017. While we supported the proposal to change the way in which funded condoms and nicotine replacement therapy (NRT) pharmaceuticals are delivered in bulk to certain organisations, we did not feel the proposal would meet PHARMACs goals of widening options for providing funded pharmaceuticals to patients, removing barriers to access and ensuring that the pharmaceutical funding system remains fit-for purpose and sustainable. We proposed an alternative supply model through community pharmacy which would allow request of supplies by these organisations on an as needed basis.
12/5/2017. We supported midazolam injections being made available on PSO for use in status epilepticus. We however requested the quantity to be changed to reflect an original pack size. We also supported enoxaparin access being widened to include during home haemodialysis. We asked for the OP or wastage rule to be applied to all dispensings of enoxaparin.
As a result of this submission PHARMAC changed the quantity of midazolam available on a PSO equal to that of an original pack.
10/04/2017. While we had no reasons to object the decision to list AstraZeneca’s Betaloc CR brand of metoprolol succinate long-acting tablets, we raised our concerns about sole supply arrangements and continuity of supply.
22/02/2017. We strongly support the proposed changes to the Pharmaceutical Schedule to fund the provision of influenza vaccine (flu vaccine) in community pharmacies to people 65 years and over and pregnant women. These changes will make use of the additional skills of vaccinating pharmacists, and support an integrative care model.
13/12/2016. Our submission covered pack size preference, that preference should be given to a company who can supply a pharmaceutical across the different strengths, the issues very plain and generic packaging can cause, required shelf-life of pharmaceuticals, out of stock arrangements and recalls.
6/12/2016. We believe that community pharmacies should become Authorised Providers to provide increased access to NRT service for patients attempting to quit smoking, including the benefit of the ‘walk-in’ no appointment service that community pharmacies offer.
28/10/2016. We supported the addition of pirfenidone capsules to the Pharmaceutical Schedule for the treatment of idiopathic pulmonary fibrosis. We ask that PHARMAC lists the 63 capsule pack of pirfenidone to prevent wastage of this medicine. If it is not possible to list this alternative pack size then please apply the wastage or original pack rule to pirfenidone to reduce this significant financial risk to community pharmacies when they dispense this potentially life changing medicine.
We supported the addition of Harvoni and Viekira Pak, as these treatments would provide funded access to major advances in Hepatitis C treatment for New Zealanders infected with the disease. We raised concern about these products being listed in Section B of the Schedule as XPharm items, as this means pharmacies would not be able to claim subsidy as alternative distribution arrangements would be put in place by PHARMAC. PHARMAC received a lot of feedback regarding the proposed direct distribution mechanism for the hepatitis C treatments from the pharmacy sector. We have been advised that this feedback will result in some changes being made to the originally proposed distribution mechanism.
We supported the decision to widen the access for longer term azithromycin treatment to include the prevention of exacerbations of non-cystic bronchiectasis for children, and mycobacterium avium intracellular complex infections, and agreed that for short courses of azithromycin should be limited for specific indications only. We however raised concerns regarding the administration of the subsidy by endorsement for short courses, as in the past subsidy by endorsement has proven to be problematic, as the endorsement is often absent from the prescription. Our view was that the prescribing of short courses of azithromycin should remain a responsibility of best practice through prescribing guidelines rather than requiring an endorsement by the prescriber.
We supported the intention of the proposal to widen access for particular patient groups to certain Special Foods however, this proposal provides another example of community pharmacies carrying the burden of some Schedule changes. We reminded Pharmac that community pharmacies are losing money when dispensing Special Foods and cannot sustain the ongoing loss through the provision of special foods to their patients. We requested an acknowledgement in the schedule that special foods are not fully reimbursed into pharmacy and a mechanism, like the product premium, to formalise the current situation whereby pharmacists pass on funding shortfalls on special foods to their patients.
We responded to Pharmac’s proposal for allowing community funded medicines (initially vaccines) and devices to be distributed directly to primary care providers. We believe that patients already have excellent access to medicines in General Practice through the existing mechanisms and wanted to understand how the approach outlined would improve patient access and safety. The Guild’s view is that it is vital that a distinct separation exists between prescribing and dispensing of a medicine. Community pharmacy is an important gatekeeper of medication safety. Changing the system so that some of that supply came from GPs would be hugely inefficient, as this would involve distribution of smaller orders to many more sites with no expectation of improvement in patient safety or adherence and in fact potentially the opposite.