Australian Health Practitioner Regulation Agency - Restriction: Supervised access to medication(s) - Entire SUSMP schedules
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Restriction: Supervised access to medication(s) - Entire SUSMP schedules

National Restrictions Library 2.0: This restriction applies to restictions imposed or accepted from 16 September 2024. For restrictions imposed or accepted before this date please see the National Restrictions Library 1.0.

Restriction description

A practitioner with this restriction must not practise until we publish approved practice locations. When assessing suitability of practice locations, we check that the practitioner has systems to ensure their compliance with the restrictions.

A practitioner with this restriction must only access medications listed in the restriction when another registered health practitioner supervises them. The listed medications can be an entire group of similar medications or only specific substances. This requirement refers to practitioners prescribing, administering, dispensing or handling those medications.

We usually apply this restriction due to concerns about a practitioner's health, conduct or performance. These concerns are often raised by a complaint.

We monitor compliance by checking that:

  • a senior person at each practice location understands the requirements of the restriction
  • the practitioner has disclosed all practice locations
  • the practitioner meets all required timeframes
  • the logbook matches patient records or independent data from Services Australia (where applicable)

Full text of restriction

  1. From #start date#, the practitioner must not practise other than at practice locations that are approved and published below. 
    #No practice locations have been approved. / The following practice locations are approved #approved practice locations effective on #date#.
  2. After approval of practice locations, the practitioner must not be the only #registered health practitioner/profession# at any practice location.
  3. The practitioner must not access any substance listed in Schedule(s) #relevant schedule# of the Standard for the Uniform Scheduling of Medicines and Poisons (the SUSMP) as amended from time to time and as published at Therapeutic Goods Administration (TGA) website, and any pharmaceutical items with an active ingredient listed in #relevant schedule# of the SUSMP unless directly observed by a nominated observer who is a #registered health practitioner/profession#.
    1. This restriction does not apply to access to medications prescribed to the practitioner for a genuine therapeutic purpose by another registered health practitioner. 
    2. <include if required> (medical practitioners) This includes any emergency treatment supplies or doctor’s bag stock.

Option 1:

  1. The practitioner must:
    1. comply with the Ahpra Protocol: Supervised access to medication(s) (283 KB,PDF) in force at the date these conditions are imposed and then as updated from time to time. 
    2. <remove if not required> maintain a log (the log) detailing every case where the practitioner has accessed the substances detailed above and provide the log on a #timeframe# basis or as otherwise required. 

Option 2: For S8’s for podiatrists and all non-PBS substances or off-label use of PBS items

  1. The practitioner must undergo audits of their practice (the audit), including any supporting records. 
    1. The audit and the audit report are to focus on the practitioner’s compliance with the requirement to not access medications unless directly observed by a nominated observer and must include, at a minimum, #audit requirement#. 
    2. The practitioner must complete a period of audits, with the first audit being within #timeframe# of approval of a practice location and thereafter on a #frequency# basis or as otherwise directed.
  2. The practitioner must:
    1. comply with the Ahpra Protocol: Supervised access to medication(s) (283 KB,PDF) and the Ahpra Protocol: Complete audit (293 KB,PDF) in force at the date these conditions are imposed and then as updated from time to time. 
    2. <remove if not required> maintain a log (the log) detailing every case where the practitioner has accessed the substances detailed above and provide the log on a #timeframe# basis or as otherwise required.

You will receive a monitoring plan that details contact information, due dates, and the information you will need to provide to show that you are complying with your restrictions.

Forms

Links to the required forms will be available here prior to 16 September 2024.

Please contact your case officer for more information. 

For general information see our Frequently asked questions about Monitoring and compliance page

If you have not yet received contact details for your case officer, please email your enquiry.

We are here to support and guide you through your compliance. 

The contact details for your case officer are included on all our correspondence with you.

We also encourage you to use independent support services, including those provided on our Practitioner support services page.

You can also contact your legal representative or professional union to support you.

You are not permitted to practise without an approved and published practice location.

You must not commence practise or recommence practise until after we have assessed and approved a practice location and the approval has been published on the public register. 

We will consider any practise without published approval to be a breach of the restrictions and may take further regulatory action, even if your nominated practice location is subsequently approved.

For these restrictions, we need to be confident that there are adequate processes for monitoring your compliance with the restrictions at each practice location. 

We consider how appropriate a practice location is for a practitioner who is subject to these restrictions. We place significant weight on practice locations having independent people who we can communicate with and seek assurance from about the practitioner’s compliance.

Generally, we will provide a further opportunity to nominate a different practice location, or to address any shortfalls in the nomination. 

You must continue to not practise until such times as the approval of a practice location has been published on the public register. 

The senior person plays an important role in protecting the public as they are responsible for the provision of accurate practice information, and are, in general terms, the primary contact for us to seek assurances from regarding your practise and whether there is any evidence that your health condition is impacting on your ability to practise safely. The senior person should be sufficiently independent from you to be reasonably relied upon by to allow for adequate monitoring.

You should notify your case officer using the contact details on your monitoring plan. You will be required to nominate a new Senior Person within 14 days.

Send us confirmation  that you no longer practise at the location. For example, a termination letter.

We will remove the publication of the practice location from the public register.

If you only had one approved practice location, you must stop practising until we publish another approved practice location on the public register. If you want to start practising at a new location, you must nominate a new practice location in line with the requirements of the restrictions and the Protocol. 

If you had more than one approved practice location, you can continue practising at your other approved practice location while we assess your new nomination. 

You must notify your case officer of any incident where, due to a medical emergency, you accessed medication that you were not permitted to access or were otherwise non-compliant with your restriction.

We will assess whether the circumstances were such that compliance with the condition would directly affect your ability to provide care that would have a direct benefit to a patient in a medical emergency.

A medical emergency is defined as an event where it is not possible or reasonable to have a patient with a serious or life threatening condition seen by another practitioner or transferred to the nearest hospital.

We will treat any failure to notify of non-compliance in the circumstances of a medical emergency as a breach of the condition and may take further action in relation to a breach of conditions.

In considering the appropriateness of a practice location for a practitioner subject to these restrictions, we place significant weight on the presence of independent persons with whom we can communicate and seek assurances from regarding the practitioner’s compliance. 

If there is no senior person or you are the senior person at the practice location, we may refuse your nomination of a practice location or may seek additional assurances that you are complying with the requirements of the restrictions. These may include the requirement for regular audit and independent reporting from local drugs and poisons authorities or Services Australia. 

You must contact your Ahpra case officer or team as soon as possible if you have had a change of circumstances or are unable to comply with the requirements for any reason. See your monitoring plan for contact information. 

You may be able to apply for a change in your restrictions, or an extension of the date of commencement of the requirement for supervision. Circumstances are considered on a case-by-case basis.

 
 
 
Page reviewed 23/08/2024