Highs & Lows
The Dept. of Health recently finished a consultation process in relation to a change in the Misuse of Drugs Act. The gist of it is that it is now proposed to limit benzo and the Z drug prescriptions to a maximum of three months.
Amongst other things it seeks to
“Strengthen controls on the import, export and possession of benzodiazepines and z-drugs to address the problem of illicit trading in these products,
Improve and update the rules governing the prescribing and supply of benzodiazepines and z-drugs within the health system”
If you want to see the full details then go to http://www.dohc.ie/consultations/misuse_drugs/
It seeks to makes unauthorised possession of them an offence under the same act. Submissions closed on September 6th so it is too late if you wanted to add something. All the usual suspects have made their submissions. A few pharmacists, myself included have also made submissions. I cannot speak for the others but my main motivation was to re-enforce many of the points already raised that are of particular importance to community pharmacists. If the minister’s advisers read it enough times it may just sink in.
So is it all worth the effort? Well certainly there is a healthy (unhealthy?) street trade in the afore mentioned drugs. Is this necessarily a bad thing? You could see it as a form of harm reduction. Taking these drugs reduces an addicts needs for stronger ones. However I’ll accept the argument that this street trade is a bad thing for society. But the extraordinary profits of the drug dealers cannot be wiped out by a stroke of a FEMPI empowered ministerial pen. So how does this proposed amendment measure up?
Like many thing emanating from Hawkins House the intent is good. The application however falls short. Following initial confusion where it seemed that the current hand writing requires were to be extended to benzos so a clarification had to be issued. It said that the these requirements would only apply to a note by the prescriber indicating that treatment was for longer than three months. Beyond this there is little new thinking. More paperwork for pharmacists and another stick for the PSI to beat us with. All they seem to want to do is throw in a few more regulations without any real reform. The potential is there for some real reform and improvements but the proposed draft is little more than a tidying up of the original act and all the amendments since it’s inception.
So what did I put in my submission? To begin I asked that the current hand writing requirements should be reformed. With the advent of computers in GP surgeries it is time to either drop them altogether or enforce them properly. It is an offence under the current act for a prescriber to issue an incorrectly written CD prescription. Despite this I have never heard of a prescriber being given as much as a slap on the wrist for this by the Medical Council although the PSI will jump down our throats if we dispense it. This brings me on to my next point. Pharmacists should be allowed some discretion when dealing with CD scripts. How many times have we seen patients in chronic pain or in the throes of terminal illness present a CD script which is not in adherence with the requirements. We know that the script is not a forgery, we know the details of dose, strength and quantity and we are supposed to say “On your way”. If they are fortunate the prescriber may only be a few streets away but what if it is the other side of town? Let them suffer because a prescriber cannot do their job properly? “The interests of the patient are paramount” the PSI would tell us. Except at our next inspection when pen pushing and box ticking reach a new zenith.
The Minister also wants to introduce “a requirement for community pharmacies to notify all controlled drug prescriptions (both public and private) to the Minister” More form filling. Why can’t the prescriber be obliged to notify the Minister themselves? Does the Minister not trust them? And why is their this new requirement for public prescriptions? With a quick phone call to HSE towers in Finglas and a few taps of a keyboard and all the CD scripts from the GMS and DPS are there for the asking.
If they were really serious about restricting supply then a simple step would be to do away with repeat prescriptions for these and removal of the dispensing in instalments. While this might be a bit harsh on private patients who have to pay €50-70 a pop to see their GP it would help bring home to each and every prescriber just how many of these drugs their patients are taking and how often. There is also nothing here to prevent GP shopping. Getting duplicate scripts from several GP’s and having them dispensed in different pharmacies will still be possible. Something like this might be easily picked up by monitoring GMS and DPS returns. However it would not be picked up for private and sub threshold DPS scripts. Seeing as how FEMPI has annihilated public prescriptions it would be a shame to restrict a lucrative source of private prescriptions for hard pressed pharmacists. Some pharmacists, myself included have proposed a form of benzo “passport” for patients. This would have to be filled in by both prescriber and pharmacist at time of each new prescription. While the principal might be sound I feel that it may not work out in practice. As above many prescribers are unable or unwilling to write a CD script properly so that the hope that they would complete a new set of paperwork along with the prescription is hard to imagine.
There is much more I could write about this proposed piece of legislation but this is a one page article and not War & Peace. But don’t hold your breath waiting. There will only come partially into force six months after signing and fully in force six months later. Unless of course it is activated as fast as FEMPI and all it’s associated cuts. If that was the case then all this would be old news and I would still be looking for a topic for this months article.