Paperless outpatient prescribing from the DHB - the challenge of "Class C" drugs

Many DHBs (including our own) are trying to facilitate paperless prescribing. Advantages include:

  • Clinicians who are doing phone clinics could prescribe to patients and send script electronically to pharmacy directly
  • Discharge scripts could aslo go directly to pharmacy, reducing a patient having to wait around while their script is made up from a paper copy.

To help facilitate this, the Ministry of Health has intruduced new rules to allow for a signature to not be required on an electronic prescription under certain conditions:
https://www.psnz.org.nz/Folder?Action=View%20File&Folder_id=96&File=MoH%20remote%20prescribing%20advisory%20(200331).pdf

The problem is this doesn’t include “Class C” drugs. Class C drugs are usually written on a standard paper script form (rather than a controlled drug form), and include drugs such as codeine, and benzodiazepines.

My understaning is that the Director General of Health has the power to make the above new rules as a waiver under the Medicines Regulations act, but the Class C drugs come under a different act (Misuse of Drugs Act) making a waiver more difficult to achieve (may require an act of parliament to alter??)

The problem this creates however is that we would then have 3 modes of prescribing instead of the previous 2. To quote a colleague:

  • Previously 1. Ordinary prescriptions. 2. Controlled drug prescriptions (classes A/B).
  • Now. 1. Ordinary prescriptions. 2. Class C controlled drug prescriptions. 3. Class A/B controlled drug prescriptions

This can add confusion and complexity. Prescribing clinicians may not be immediately aware which drugs they normally prescribe on a normal sript pad are class C or not, likely leading to the wrong mode being used.

Whare are other DHBs doing to mitigate this risk?

@jon_herries are you aware of any plans or options from the Ministry of Health perspective to address this?

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Greetings
In primary care the only requirement for signature are controlled drugs which are DDA script required . We would have done these on triplicate form previously but now with NZePS we just need one signed and seperate form. Benzodiazepine and codeine do not required controlled rug form so would be done on normal unsigned E prescription as far as I am aware . Unsure why this would be different in hospital practice .
Grahame

Thanks for this @grahame.jelley It would certainly interesting to find out the answer.

I’m fairly new to looking into this area, but from what I can see on the ministry references: https://www.health.govt.nz/system/files/documents/pages/remote_prescribing_faqs_final_3_april_2020_final_.pdf
it seems to say that class A, B, and C do require a signature. However there may be a way around it in that this publication states that

“The prescription does not include Controlled Drugs (Class A, B or C) but can include an exempted drug or partially exempted drug as defined by the Misuse of Drugs Act 1975”

So now we just need to find what the list of exempted or partially exmpted drugs are as defined by the Misuse of Drugs act. Can anyone provide any leads on this?

Hi Grahame, codeine and benzodiazepines and other class C controlled drugs are not exempt from requiring a prescriber’s signature because the legal requirement for this is contained in the Misuse of Drugs Act/Regs not the Medicines Act. The DG of Health has no authority to waive this.

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The ultimate pathway is through NZePS. The NZTLG pushes the waiver through and we were reluctant to add cat C at the time for many of the reasons you describe. We are looking for a temporary fix in CWS and then will look to provide prescribing directly through NZePS…

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@Ruth_Large thanks . So are you indicating a difference in process between electronic prescribing in our hospitals compared to NZePS. I have never had to prescribe codeine or benzodiazepine on a controlled drug form. NZePS allows us to remove the requirement for triplicate forms but the recent allowances for non signed emailed scripts has controlled drug scripts still to be signed

Thanks @Ruth_Large

But will the NZePS solve the class C issue, or are you still required to make a signed paper script for class C drugs even within the NZePS as per MOH info sheet from my post above ?
https://www.health.govt.nz/system/files/documents/pages/remote_prescribing_faqs_final_3_april_2020_final_.pdf

Thanks also for your comments on the telehealth site which was also pointed out to me.
I’m copying the link here to so others can read:

https://www.telehealth.org.nz/news/waiver-from-ministry-offers-opportunity-to-trial-e-prescription

Hi Damon,

Partially exempt drugs are listed in the Misuse of Drugs Act Schedule 3 Part 3 (e.g. Pholcodeine) and exempted drugs are in Schedule 3 part 6 (e.g. codeine formulated in combination with paracetamol).

http://www.legislation.govt.nz/act/public/1975/0116/latest/DLM436723.html?search=sw_096be8ed818b92cc_exempt_25_se&p=1

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In the interim, whilst working an NZePS solution, you could consider putting all controlled drugs (other than exempt/partially exempt) on the triplicate prescription forms to avoid having 3 types of scripts. It could be seen as a waste of CD scripts but the alternative may be more costly…

The question for the longer term is what happens after the temporary waiver expires or is revoked? If we go back to how it was a few weeks ago, all NZePS scripts and other electronic scripts covered by the waiver will need physical signatures again unless the Medicines Act/Regs are amended to include electronic signatures.

Hi all, I am a community pharmacist and trying to help the local prescribers and pharmacists understand this deluge of half finished paperless prescriptions in the wake of the arrival of COVID 19.
The comments re the waiver for controlled drugs B and C are correct but there is work being done in the MOH to have legislation changed so that the waiver would cover these. I wouldn’t use triplicate forms for all controlled drugs.
MedTech 32 wasn’t a very prescription friendly system before and quite outdated and now it is being asked to jump 1000m in half a minute, when it should that taken it 6months…
It would be great if the script did say please print sign and fax/email to pharmacy but the PMS doesn’t. So the prescribers have to know and that’t not easy as it isn’t something that is often thought about but the main two groups are codeine and benzodiazepines. Zopiclone and tramadol do not.
I believe that there is work being done so that the “signature exempt” scripts that are allowed now through NZePS will continue to be allowed after the levels are lowered, The only thing that will change is the ones written in a hospital or by a dentist, midwife etc.
But COVID 19 has shown that the IT can be run out quickly if necessary, but there are lots of holes and lots of confusion on the way.
The most important thing is please do your best to ensure that the patient doesn’t bring a potentially contaminated piece of paper to the community pharmacy. Happy to answer any more questions. Keep well, keep safe Clare

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A post was split to a new topic: How to cross post to Health Forum NZ

Thanks Clare
Most useful commentary. Enabled me to clarify with my practice
Grahame

Hi Clare and @Ruth_Large

Does that mean those Class C drugs which would previously needed a physical signature but could be on a regular script (not a triplicate form) would then be eligibility for the electronic scripts? So we would be back to two options. What is
the status of the waiver extension?

If the hospitals can setup a link into NZePS then they could continue with electronic scripts post-Covid. I can’t see GPland and patients wanting to stop, so don’t see why outpatients and potentially on discharge should be any different.

Cheers Inga

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