Summary of COVID-19 regulatory changes
This information was last updated Tuesday 20 December 2022
The tables below provide a summary of the arrangements available to support continuity of treatment (medicines) for patients during and beyond the COVID-19 pandemic.
PSA has prepared this information using the best and most up-to-date information that we have received. This is constantly changing. We are in constant contact the Australian Government and the state and territory governments and will update this information regularly.
This information is a guide and should not be used as a substitute or replacement for review of regulation and legislative instruments.

Digital image prescriptions ~ (26 October 2022)
Digital image prescriptions were the paperless transfer of prescriptions from a prescriber to a pharmacist to support telehealth consultations during COVID-19. This temporary measure was supported through existing territory regulation, temporary state regulatory amendments, public health emergency orders and a PBS Special Arrangement.
The PBS Special Arrangement ended on 31 March 2022 (except within hospitals), as did the legal authority to supply under temporary authorisations in all jurisdictions other than NSW. In NSW this arrangement came to an end on 30 September 2022 (except within hospitals) This information remains available as prescriptions written prior to the expiry date of relevant orders, including where repeats are authorised, can continued to be supplied within these requirements until the prescription expires.
Prescriptions ineligible for supply as digital image prescriptions may be able to be supplied under other existing state and territory regulations – see phone/fax order by prescriber.
Digital image prescriptions are NOT examples of electronic prescriptions or electronic prescribing. Electronic prescribing information is available at PSA’s dedicated electronic prescriptions web page. Find out more at www-dev/ep
Transition arrangements
The Department of Health (Australian Government) has advised the following provisions for the end of the digital image prescription special arrangements from 31 March 2022:
Fact Sheet – National Health Plan: A guide for prescribers Arrangements for prescribing of medicines
Fact Sheet – National Health Plan: A Guide for Pharmacists Arrangements for prescriptions for supply of medicines
The implementation of this measure was only intended as an interim arrangement to support the community during COVID-19, which must now be ceased due to the associated increased risk of fraudulent behaviour.
Electronic prescribing has replaced the need for this temporary PBS measure. The Department of Health considers that electronic prescribing is now widely available nationally and will continue to support telehealth arrangements for the long term. Electronic prescribing, unlike digital image prescriptions, allows patients to receive their prescriptions electronically via email, SMS or mobile app, which they can send to their pharmacy to dispense their medicines.
The Department of Health advise most stakeholders now support the cessation of image-based prescribing in the community setting from 31 March 2022, noting the widespread access to electronic prescribing.
A “hospital” is an approved hospital authority as defined by section 94 of the National Health Act 1953, which is approved to supply pharmaceutical benefits to patients in or at that hospital whether private or public.
Limited image-based prescribing activities may continue for prescriptions written for hospital patients until 31 March 2023. A prescription written for a hospital patient can only be lawfully dispensed by a hospital pharmacy. This arrangement will only extend until 31 March 2023. The amendments limit the supply of pharmaceutical benefits to hospital settings, as defined by section 94 of the National Health Act 1953, which is an approved hospital authority who is approved to supply pharmaceutical benefits. This includes both public and private hospitals.
The changes to image-based prescribing remove the restriction on the supply of pharmaceutical benefits:
– For Schedule 4 Appendix D and Schedule 8 Medicines
– Under the National Health (Highly Specialised Drugs Program) Special Arrangement 2021 (HSD Special Arrangement)
The end date relates to the date of prescribing.
Transitional provisions that will recognise image-based prescriptions as legally valid if they have been prescribed before the end date of the Special Arrangement, but need to be dispensed after the end date.
Prescriptions written before 31 March 2022 with existing repeats will continue to be honoured after 31 March 2022
While the PBS Special Arrangement has ended, in NSW digital image prescriptions remained legal for the prescribing and supply of medicines until 30 September 2022. However, as these prescriptions were unable to be supplied as PBS prescriptions, in effect only non-PBS prescriptions can be supplied under this measure (except hospitals).
Prior to supplying PBS prescriptions from a fax, pharmacists should confirm with prescribers whether they intend to send the paper prescriptions under phone/fax arrangements.
The Department of Health (Australian Government) has updated relevant fact sheets and webpages that provide an overview of the amended image-based prescribing arrangement:
For best viewing experience on a mobile we recommend using landscape mode.
Requirement for supply under PBS – Commonwealth legislation | Legality to supply – ACT regulation | |
---|---|---|
Effective to | PBS special arrangement ended on 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. | Ongoing under existing ACT legislation |
Effective from | 20 March 2020 | N/A |
Prescriber |
|
For faxed prescriptions – The original written paper-prescription must be sent to the patient’s pharmacy within 24 hours of sending the faxed prescription |
Pharmacist |
|
(Refer to requirements under Commonwealth Special Arrangement)
June 2020 amendment to faxed prescription requirements
Sections 31A and 120A have been added to the Regulation to exempt the requirement to send or receive the original of a faxed prescription where the supply is made for a medicine in accordance with a Commonwealth special arrangement that requires prescribers to retain the original.
The Commonwealth Pharmaceutical Benefits Scheme (PBS) interim arrangements for telehealth consultations during COVID-19 are an example of where this applies.
This means that prescribers do not need to send the original of a faxed prescription to a pharmacist where it is prescribed during a telehealth consultation while the PBS special arrangements is in place. Pharmacists are also not obligated to receive the original in these circumstances |
Eligible medicines | Excludes medicines in S8 and S4 + Appendix D in the Poisons Standard*
*Unless state and territory legislation allows supply via a digital image |
Pharmacists may dispense and claim PBS items from a digital image of a prescription sent through by the prescriber (including S8 medicines, and S4 + Appendix D medicines as supported by existing ACT legislation) This includes for faxed prescriptions. |
Legislative instrument/s | ||
Relevant resources |
For best viewing experience on a mobile we recommend using landscape mode.
Requirement for supply under PBS – Commonwealth legislation | Legality to supply – NSW regulation | |
---|---|---|
Effective to | PBS special arrangement ended on 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. | 30 September 2022 |
Effective from | 20 March 2020 | 17 April 2020 |
Prescriber |
|
|
Pharmacist |
|
|
Eligible medicines | Excludes medicines in S8 and S4 + Appendix D in the Poisons Standard*
*Unless state and territory legislation allows supply via a digital image |
Excludes:
Schedule 8 medicines and drug classes:
Schedule 4 Appendix D medicines and drug classes
|
Legislative instrument/s | ||
Relevant resources |
For best viewing experience on a mobile we recommend using landscape mode.
Requirement for supply under PBS – Commonwealth legislation | Legality to supply – NT regulation | |
---|---|---|
Effective to | PBS special arrangement ended on 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. | Ended 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. |
Effective from | 20 March 2020 | 20 March 2020 |
Prescriber |
|
(Refer to requirements under Commonwealth Special Arrangement)
|
Pharmacist |
|
(Refer to requirements under Commonwealth Special Arrangement)
|
Eligible medicines | Excludes medicines in S8 and S4 + Appendix D in the Poisons Standard*
*Unless state and territory legislation allows supply via a digital image |
S8 and S4Ds medicines are excluded from the temporary PBS image based prescription measure |
Legislative instrument/s | Medicines, Poisons and Therapeutic Goods Act 2012 | |
Relevant resources | Pharmacy information notice – May 2020 |
For best viewing experience on a mobile we recommend using landscape mode.
Requirement for supply under PBS – Commonwealth legislation | Legality to supply – QLD regulation | |
---|---|---|
Effective to | PBS special arrangement ended on 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. | when the Commonwealth Special Arrangement ends |
Effective from | 20 March 2020 | 26 March 2020 (retrospective) |
Prescriber |
|
(Refer to requirements under Commonwealth Special Arrangement)
|
Pharmacist |
|
(Refer to requirements under Commonwealth Special Arrangement)
|
Eligible medicines | Excludes medicines in S8 and S4 + Appendix D in the Poisons Standard*
*Unless state and territory legislation allows supply via a digital image |
Pharmacists may dispense and claim PBS items from a digital image of a prescription sent through by the prescriber (including S8s and restricted drugs, noting hardcopy requirements outlined above) |
Legislative instrument/s | ||
Relevant resources |
For best viewing experience on a mobile we recommend using landscape mode.
Requirement for supply under PBS – Commonwealth legislation | Legality to supply – SA regulation | |
---|---|---|
Effective to | PBS special arrangement ended on 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. | 31 March 2022 |
Effective from | 20 March 2020 | 27 March 2020 |
Prescriber |
|
(Refer to requirements under Commonwealth Special Arrangement) – see dot points at left
|
Pharmacist |
|
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Eligible medicines | Excludes medicines in S8 and S4 + Appendix D in the Poisons Standard*
*Unless state and territory legislation allows supply via a digital image |
(Refer to requirements under Commonwealth Special Arrangement) – i.e. S8s and S4Ds cannot be supplied on a digital image of a prescription |
Legislative instrument/s | ||
Relevant resources |
For best viewing experience on a mobile we recommend using landscape mode.
Requirement for supply under PBS – Commonwealth legislation | Legality to supply – TAS regulation | |
---|---|---|
Effective to | PBS special arrangement ended on 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. | 31 March 2022 |
Effective from | 20 March 2020 | 15 April 2020 |
Prescriber |
|
More information in the fact sheet for prescribers |
Pharmacist |
|
Pharmacists can access additional information in the fact sheet |
Eligible medicines | Excludes medicines in S8 and S4 + Appendix D in the Poisons Standard*
*Unless state and territory legislation allows supply via a digital image |
Excludes (i.e. cannot be supplied on a digital image of a prescription) S8s and S4 declared restricted medicines as outlined in the Poisons (Declared Restricted Substances) Order 2017 |
Legislative instrument/s | Poisons Regulations 2018 | |
Relevant resources |
For best viewing experience on a mobile we recommend using landscape mode.
Requirement for supply under PBS – Commonwealth legislation | Legality to supply – VIC regulation | |
---|---|---|
Effective to | PBS special arrangement ended on 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. | 13 April 2022. Exception: order extended for hospital pharmacy only until 13/10/22 |
Effective from | 20 March 2020 | 7 April 2020 |
Prescriber |
|
(#See Eligible medicines section below)
|
Pharmacist |
|
Must record that supply was made under the public health emergency order (PHEO #4) |
Eligible medicines | Excludes medicines in S8 and S4 + Appendix D in the Poisons Standard*
*Unless state and territory legislation allows supply via a digital image |
Excludes drugs of dependence (i.e. all S8 medicines, benzodiazepines anabolic steroids and phentermine
For clarity: tramadol, pregabalin, gabapentin, z-drugs, retinoids, reproductive medicines and S4 codeine preparations are not listed in Schedule 11 of the Act, and are therefore not ‘drugs of dependance’ excluded from PHEO#4.
#Pharmacists must confirm that a prescriber is authorised to prescribe the medicine as a pharmaceutical benefit |
Legislative instrument/s |
|
|
Relevant resources |
For best viewing experience on a mobile we recommend using landscape mode.
Requirement for supply under PBS – Commonwealth legislation | Legality to supply – WA regulation | |
---|---|---|
Effective to | PBS special arrangement ended on 31 March 2022, except for prescriptions prescribed and dispensed within hospitals. | Prescriptions written before 31 March 2022 |
Effective from | 20 March 2020 | N/A |
Prescriber |
|
In WA, prior to 31 March 2022, prescribers were able to direct a pharmacist to supply a S4 or S8 medicine, in an emergency, including via a digital image (which is classified as ‘other electronic means’)
|
Pharmacist |
|
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Eligible medicines | Excludes medicines in S8 and S4 + Appendix D in the Poisons Standard*
*Unless state and territory legislation allows supply via a digital image |
Pharmacists may dispense and claim PBS items from a digital image of a prescription written prior to 31 March 2022 sent through by the prescriber (including S8s, noting hardcopy requirements outlined above) |
Legislative instrument/s | ||
Relevant resources | Fact sheet – digital image prescribing |
Continued dispensing is the supply of a standard quantity (usually 1 month’s supply) of an essential Prescription Only Medicines (S4) without a prescription in an emergency.
Prior to COVID-19, PBS Continued Dispensing was limited to oral contraceptives and statins. PBS Expanded Continued Dispensing and state/territory regulation have enabled supply of nearly all Prescription Only Medicines via this temporary measure during COVID-19; subject to professional and regulatory requirements.
These temporary PBS arrangements ended on 1 July 2022 and have been replaced by permanent measures. These permanent PBS Continued Dispensing measures, based of a list of medicine endorsed by PBAC in November 2021:
- include a substantially larger formulary of medicines for stable chronic diseases than what was in place prior to 2019
- do not include a large range of medicines able to be supplied under the temporary measures in place since early 2020.
Some states/territories continue to allow non-PBS supply (private supply) of most Prescription Only Medicines under temporary emergency authorisations, while others do not.
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Legality to supply – ACT regulation
These requirements must be met to supply as PBS Continued Dispensing or private supply |
Eligibility to supply under the PBS – Commonwealth legislation
These requirements must be met, in addition to state requirements, to supply as PBS Continued Dispensing medicines |
|
---|---|---|
Effective to | Permanent (PBS Continued Dispensing)
Duration of public health emergency (where PBS Continued Dispensing does not apply) |
Permanent |
Summary of conditions | A Schedule 4 medicine may be supplied to a patient without a prescription in an emergency if the pharmacist is satisfied:
|
The National Health (Continued Dispensing) Determination 2022 allows eligible PBS medicine to be supplied to a patient without a prescription if:
|
Eligible medicines and subsidy |
These measures only applies to Prescription Only Medicines (Schedule 4) which are not anabolic steroids, designated Appendix D medicines, benzodiazepines. Controlled Drugs (Schedule 8) cannot be supplied without a prescription. |
Medicines listed in Schedule 1 of the National Health (Continued Dispensing) Determination 2022:
Eligible medicines are subsidised by the PBS; usual co-payment applies. CTG applies for eligible patients. |
Quantity |
|
|
Record and communication |
|
Must record supply as outlined in National Health (Continued Dispensing) Determination 2022 and PSA Guidelines for the Continued Dispensing of eligible prescribed medicines by pharmacists, including:
Must provide written communication to patient’s usual prescriber advising of Continued Dispensing supply in a ‘timely manner’ |
More information | – |
Last updated 20 December 2022 (ACT)
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Legality to supply – NSW regulation
These requirements must be met to supply as PBS Continued Dispensing or private supply |
Eligibility to supply under the PBS – Commonwealth legislation
These requirements must be met, in addition to state requirements, to supply as PBS Continued Dispensing medicines |
|
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Effective to |
|
Permanent |
Summary of conditions | A Schedule 4 medicine may be supplied to a patient without a prescription in an emergency if the pharmacist is satisfied:
Emergency supply under this authority is permitted if patient has not received any such emergency supply of the medicine from any NSW pharmacy in previous 12 months Pharmacist must promptly report supply to regular or most recent prescriber |
The National Health (Continued Dispensing) Determination 2022 allows eligible PBS medicine to be supplied to a patient without a prescription if:
|
Eligible medicines and subsidy |
Temporary authority only applies to Prescription Only Medicines (Schedule 4) which are not Schedule 4D medicines. Controlled Drugs (Schedule 8) cannot be supplied without a prescription. |
Medicines listed in Schedule 1 of the National Health (Continued Dispensing) Determination 2022:
Eligible medicines are subsidised by the PBS; usual co-payment applies. CTG applies for eligible patients. |
Quantity |
|
|
Record and communication | Must record consistent with the requirements of temporary authority, including:
The pharmacist must report the supply to the patient’s usual or last known prescriber. |
Must record supply as outlined in National Health (Continued Dispensing) Determination 2022 and PSA Guidelines for the Continued Dispensing of eligible prescribed medicines by pharmacists, including:
Must provide written communication to patient’s usual prescriber advising of Continued Dispensing supply in a ‘timely manner’ |
More information |
Last updated 7 December 2022 (NSW)
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Legality to supply – NT regulation
These requirements must be met to supply as PBS Continued Dispensing or private supply |
Legality to supply – NT regulation | |
---|---|---|
Effective to | As per Commonwealth instrument | Permanent |
Summary of conditions | Commonwealth instrument automatically adopted – Continued Dispensing fully enabled under the Act (see also information sheet) | The National Health (Continued Dispensing) Determination 2022 allows eligible PBS medicine to be supplied to a patient without a prescription if:
|
Eligible medicines & subsidy |
Privately funded and non-PBS prescriptions are not permitted under this measure |
Medicines listed in Schedule 1 of the National Health (Continued Dispensing) Determination 2022.
Eligible medicines are subsidised by the PBS; usual co-payment applies. CTG applies for eligible patients. |
Quantity |
|
|
Record and communication | Must record supply as outlined in National Health (Continued Dispensing) Determination 2022 and PSA Guidelines for the Continued Dispensing of eligible prescribed medicines by pharmacists, including:
Must provide written communication to patient’s usual prescriber advising of Continued Dispensing supply in a ‘timely manner’ |
|
More information |
Last updated 1 July 2022 (NT)
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Legality to supply – Queensland regulation
These requirements must be met to supply as PBS Continued Dispensing or private supply n |
Eligibility to supply under the PBS – Commonwealth legislation
These requirements must be met, in addition to state requirements, to supply as PBS Continued Dispensing medicines |
|
---|---|---|
Effective to | Permanent (PBS Continued Dispensing)
Duration of public health emergency (where PBS Continued Dispensing does not apply) |
Permanent |
Summary of conditions | A Schedule 4 medicine may be supplied to a patient without a prescription in an emergency if the pharmacist reasonably believes:
|
The National Health (Continued Dispensing) Determination 2022 allows eligible PBS medicine to be supplied to a patient without a prescription if:
|
Eligible medicines & subsidy |
These measures only applies to Prescription Only Medicines (Schedule 4). Controlled Drugs (Schedule 8) cannot be supplied without a prescription. Diversion-risk medicines may only be supplied under this measure where a decision not to supply the medicine could be life-threatening for the person. |
Medicines listed in Schedule 1 of the National Health (Continued Dispensing) Determination 2022.
Eligible medicines are subsidised by the PBS; usual co-payment applies. CTG applies for eligible patients. |
Quantity |
|
|
Record and communication | Supply must be recorded, including:
The pharmacist must notify the authorised prescriber as soon as practicable, but no later than 7 days later |
Must record supply as outlined in National Health (Continued Dispensing) Determination 2022 and PSA Guidelines for the Continued Dispensing of eligible prescribed medicines by pharmacists, including:
Must provide written communication to patient’s usual prescriber advising of Continued Dispensing supply in a ‘timely manner’. |
More information | Updates and alerts – Queensland Health |
Last updated 20 December 2022 (Queensland)
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Legality to supply – South Australian regulation
These requirements must be met to supply as PBS Continued Dispensing or private supply |
Eligibility to supply under the PBS – Commonwealth legislation
These requirements must be met, in addition to state requirements, to supply as PBS Continued Dispensing medicines |
|
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Effective to |
PBS Continued Dispensing: Ongoing |
Permanent |
Summary of conditions | A Schedule 4 medicine may be supplied to a patient without a prescription if the pharmacist is satisfied:
|
The National Health (Continued Dispensing) Determination 2022 allows eligible PBS medicine to be supplied to a patient without a prescription if:
|
Eligible medicines & subsidy |
Excludes:
|
Medicines listed in Schedule 1 of the National Health (Continued Dispensing) Determination 2022.
Eligible medicines are subsidised by the PBS; usual co-payment applies. CTG applies for eligible patients. |
Quantity |
|
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Record and communication |
|
Must record supply as outlined in National Health (Continued Dispensing) Determination 2022 and PSA Guidelines for the Continued Dispensing of eligible prescribed medicines by pharmacists, including:
Must provide written communication to patient’s usual prescriber advising of Continued Dispensing supply in a ‘timely manner’ |
More information | Regulation 21(2f) of the Controlled Substances (Poisons) Regulations 2011 |
Last updated 7 July 2022 (SA)
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Legality to supply – Tasmanian regulation
These requirements must be met to supply as PBS Continued Dispensing or private supply |
Eligibility to supply under the PBS – Commonwealth legislation
These requirements must be met, in addition to state requirements, to supply as PBS Continued Dispensing medicines. Only eligible restricted substances (see left column) can be supplied. |
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Effective to | Ongoing | Permanent |
Summary of conditions | An eligible restricted substance (see below) may be supplied to a patient without a prescription if:
|
The National Health (Continued Dispensing) Determination 2022 allows eligible PBS medicine to be supplied to a patient without a prescription if:
|
Eligible medicines & subsidy | Eligible restricted substances able to be supplied only include the following substances:
Name of substance must be listed in National Health (Continued Dispensing) Determination |
Medicines listed in Schedule 1 of the National Health (Continued Dispensing) Determination 2022.
Eligible medicines are subsidised by the PBS; usual co-payment applies. CTG applies for eligible patients. |
Quantity |
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Record and communication |
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Must record supply as outlined in National Health (Continued Dispensing) Determination 2022 and PSA Guidelines for the Continued Dispensing of eligible prescribed medicines by pharmacists, including:
Must provide written communication to patient’s usual prescriber advising of Continued Dispensing supply in a ‘timely manner’ |
More information | Regulation 48: Poisons Regulations 2018
Note: Prior to 1 July 2022, PBS Continued Dispensing was enabled by an emergency order. This order issued by the Secretary in accordance with section 14 of the Public Health Act 1997 ceased to be in effect at when the Public Health Emergency Declaration expired at 12.01am on 1 July 2022. |
Last updated 1 July 2022 (Tasmania)
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Legality to supply – Victorian regulation These requirements must be met to supply as PBS Continued Dispensing or private supply |
Eligibility to supply under the PBS – Commonwealth legislation
These requirements must be met, in addition to state requirements, to supply as PBS Continued Dispensing medicines |
|
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Effective to | 22 December 2022 | Permanent |
Summary of conditions | A Schedule 4 medicine may be supplied to a patient without a prescription in an emergency if the pharmacist is satisfied:
|
The National Health (Continued Dispensing) Determination 2022 allows eligible PBS medicine to be supplied to a patient without a prescription if:
|
Eligible medicines & subsidy |
PHEO#2 only applies to Prescription Only Medicines (Schedule 4). Controlled Drugs (Schedule 8) cannot be supplied without a prescription. |
Medicines listed in Schedule 1 of the National Health (Continued Dispensing) Determination 2022.
Eligible medicines are subsidised by the PBS; usual co-payment applies. CTG applies for eligible patients. |
Quantity |
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|
Record and communication |
|
Must record supply as outlined in National Health (Continued Dispensing) Determination 2022 and PSA Guidelines for the Continued Dispensing of eligible prescribed medicines by pharmacists, including:
Must provide written communication to patient’s usual prescriber advising of Continued Dispensing supply in a ‘timely manner’ |
More information |
|
Last updated 19 October 2022 (Victoria)
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Legality to supply – WA regulation
These requirements must be met to supply as PBS Continued Dispensing or private supply |
Eligibility to supply under the PBS – Commonwealth legislation
These requirements must be met, in addition to state requirements, to supply as PBS Continued Dispensing medicines |
|
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Effective to | Permanent | Permanent |
Summary of conditions | An Schedule 3 or Schedule 4 medicine listed in the Continued Dispensing determination may be supplied to a patient without a prescription if:
|
The National Health (Continued Dispensing) Determination 2022 allows eligible PBS medicine to be supplied to a patient without a prescription if:
|
Eligible medicines & subsidy |
|
Medicines listed in Schedule 1 of the National Health (Continued Dispensing) Determination 2022.
Eligible medicines are subsidised by the PBS; usual co-payment applies. CTG applies for eligible patients. |
Quantity |
|
|
Record and communication |
|
Must record supply as outlined in National Health (Continued Dispensing) Determination 2022 and PSA Guidelines for the Continued Dispensing of eligible prescribed medicines by pharmacists, including:
Must provide written communication to patient’s usual prescriber advising of Continued Dispensing supply in a ‘timely manner’ |
More information | Note: Between March 2020 and June 2022, through a special authority linked to a declaration of public health emergency enabled PBS and non-PBS supply of most Schedule 4 medicines under this measure. This authority has now been revoked. The SASA has also been updated to align with the National Health (Continued Dispensing) Determination 2022. | Non-PBS medicines are not subsidised under the PBS |
Last updated 8 July 2022
Medicine shortages: Therapeutic substitution (updated 20 December 2022)
Therapeutic substitution is the supply of alternative strengths, quantities or dose forms of a medicine by a pharmacist without prior approval from the prescriber. This is to ensure continuity of therapy during a verified national shortage of the prescribed medicine.
Supply of a substitutable (alternative) medicine by a community pharmacist must be in accordance with a specific Serious Scarcity Substitution Instrument (SSSI).
Current SSSIs
PBS subsidy: arrangements are in place for the substitutable (alternative) medicines under the amoxicillin SSSI – refer to PBS website.
Scarce medicine | Substitutable (alternative) medicine | Note |
cefalexin 125 mg/5 mL (100 mL) |
|
250 mg of cefalexin is equivalent to:
|
cefalexin 250 mg/5 mL (100 mL) |
|
250 mg of cefalexin is equivalent to:
|
cefalexin 500 mg capsules |
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One 500 mg cefalexin capsule is equivalent to:
|
Other substitutions without a new prescription are not permitted. For example, substitutions of 500mg capsules for oral suspensions – and vice versa – are not permitted.
Additional considerations for pharmacists:
Pharmacists are required to:
- advise the patient of the number of dose units of substitutable medicine that must be taken by the patient in substitution for the prescribed dose of scarce medicine, based on the dose unit equivalence specified in the above table
- ensure the correct dose of substitutable medicine is written in millilitres on the dispensing label (liquid formulations only)
- if multiple bottles of substitutable medicine are dispensed—ensure the patient’s treatment course will be completed prior to the expiry of each bottle;
- where cutting of the tablet is required to obtain the correct dose of substitutable medicine—provide instructions to the patient for cutting the tablet (tablets only); and,
- ensure the patient, or person acting on behalf of the patient, has access to information to support them in administering the substitutable medicine.
Further information:
- Therapeutic Goods (Serious Scarcity and Substitutable Medicine) (cefalexin) Instrument 2022 (Federal legislative instrument)
PBS subsidy: arrangements are in place for the substitutable (alternative) medicines under the amoxicillin SSSI – refer to PBS website.
Scarce medicine | Substitutable (alternative) medicine | Note |
amoxicillin 100 mg/mL (20 mL) |
|
50 mg of amoxicillin is equivalent to: (a) 0.5 mL of amoxicillin 500 mg/5 mL suspension; (b) 2 mL of amoxicillin 125 mg/5 mL syrup or suspension; (c) 1 mL of amoxicillin 250 mg/5 mL syrup or suspension |
amoxicillin 500 mg /5 mL (100 mL) |
|
50 mg of amoxicillin is equivalent to: (a) 0.5 mL of amoxicillin 100 mg/mL suspension; (b) 2 mL of amoxicillin 125 mg/5 mL syrup or suspension; (c) 1 mL of amoxicillin 250 mg/5 mL syrup or suspension |
amoxicillin 125 mg /mL (100 mL) |
|
50 mg of amoxicillin is equivalent to: (a) 0.5 mL of amoxicillin 100 mg/mL suspension; (b) 0.5 mL of amoxicillin 500 mg/5 mL suspension; (c) 1 mL of amoxicillin 250 mg/5 mL syrup or suspension |
amoxicillin 250 mg /5 mL (100 mL) |
|
50 mg of amoxicillin is equivalent to: (a) 0.5 mL of amoxicillin 100 mg/mL suspension; (b) 0.5 mL of amoxicillin 500 mg/5 mL suspension; (c) 2 mL of amoxicillin 125 mg/5 mL syrup or suspension |
amoxicillin 500 mg capsules |
|
one 500 mg amoxicillin capsule is equivalent to: (a) two 250 mg amoxicillin capsules; (b) half of a 1 gram amoxicillin tablet |
amoxicillin 1000 mg tablets |
|
one 1 gram amoxicillin tablet is equivalent to: (a) four 250 mg amoxicillin capsules; (b) two 500 mg amoxicillin capsules |
Other substitutions without a new prescription are not permitted. Substitutions of solid dose forms (tablets/capsules) with liquid dose forms (suspensions) – and vice versa – are not permitted.
Additional considerations for pharmacists:
Pharmacists are required to:
- advise the patient of the number of dose units of substitutable medicine that must be taken by the patient in substitution for the prescribed dose of scarce medicine, based on the dose unit equivalence specified in the above table
- ensure the correct dose of substitutable medicine is written in millilitres on the dispensing label (liquid formulations only)
- if multiple bottles of substitutable medicine are dispensed—ensure the patient’s treatment course will be completed prior to the expiry of each bottle;
- where cutting of the tablet is required to obtain the correct dose of substitutable medicine—provide instructions to the patient for cutting the tablet (tablets only); and,
- ensure the patient, or person acting on behalf of the patient, has access to information to support them in administering the substitutable medicine.
Further information:
-
Substitution allowed to address shortage of amoxicillin (TGA)
- Therapeutic Goods (Serious Scarcity and Substitutable Medicine) (Amoxicillin) Instrument 2022 (Federal legislative instrument)
PBS subsidy: arrangements are in place for the substitutable (alternative) medicines under the isosorbide mononitrate SSSI – refer to PBS website. If the required quantity of the substitutable medicine (60 mg) is more than the PBS maximum quantity, use the authority prescription number ‘00000246’ and disregard PBS Online warning (reason code 151).
Scarce medicine | Substitutable (alternative) medicine | Note |
Isosorbide mononitrate 120 mg tablet (sustained release)
8273K Imdur 120 mg Monodur 120 mg |
Isosorbide mononitrate 60 mg tablet (sustained release)
1558B APO-Isosorbide Mononitrate Duride GenRx Isosorbide Mononitrate ISOBIDE MR Isomonit Isosorbide AN Imdur Durule Monodur 60 mg |
One tablet of the scarce medicine is equivalent to two tablets of the substitutable (alternative) medicine |
Additional considerations for pharmacists:
- The dose and total quantity of 60 mg tablets dispensed must be equivalent to the dosage regimen and duration originally prescribed for the 120 mg tablets.
Further information:
- Substitution instrument to address shortage of Imdur Durules and Monodur Durules isosorbide mononitrate 120 mg modified release tablets (TGA)
- Therapeutic Goods (Serious Scarcity and Substitutable Medicine) (Isosorbide Mononitrate) Instrument 2021 (Principal Instrument)
- Therapeutic Goods (Serious Scarcity and Substitutable Medicine) (Isosorbide Mononitrate) Amendment Instrument 2022 (Amendment Instrument)
General requirements and information for pharmacists – dispensing according to a SSSI
- Confirm there is evidence of a valid prescription for the scarce medicine for the patient.
- Substitution can only be made under the SSSI if the pharmacist does not have access to the scarce medicine.
- Confirm the prescriber has not indicated on the prescription for the scarce (original) medicine that substitution is not permitted.
- Apply professional and clinical judgement to determine whether the patient is suitable to receive the substitutable (alternative) medicine.
- If deemed suitable, ensure the patient is fully informed and has consented to receiving the substitutable medicine.
- The total amount of substitutable medicine dispensed must provide for an equivalent treatment regimen (dosage and duration) as the scarce medicine.
- A record of dispensing the substitutable medicine in substitution of the scarce medicine must be made at the time of dispensing.
- The pharmacist must have, and follow, an established procedure to notify the prescriber of the substitution at the time of, or as soon as practical after, dispensing the substitutable medicine.
Further general information:
- Serious Scarcity Substitution Instruments (SSSIs) (TGA) – Dispensing information and FAQs for pharmacists
- National Health (Pharmaceutical Benefits) (Pharmacist Substitution of Medicines without Prescription during Shortages) Determination 2021 (Federal instrument)
- PBS subsidy arrangements for medicines subject to a Serious Scarcity Substitution Instrument
A phone/fax order is the communication of a prescription from a prescriber to a pharmacist via phone, fax or email (where permitted). The prescriber is then responsible for immediately dispatching the original hard-copy prescription to the supplying pharmacist.
Phone/fax orders, often referred to as ‘owing prescriptions’, must generally be reconciled (‘owing mark off’) before repeats can be issued or the item claimed through the PBS.
These permanent provisions existed within state/territory regulation, and within PBS regulation, prior to COVID-19. Compliance with the requirements of these provisions continues to be relevant during COVID-19 for prescriptions not prescribed as, or eligible for transmission as, digital image prescriptions (e.g. Controlled Drugs, original prescription intended to be sent to pharmacy etc.).
Phone/fax order requirements are not relevant when electronic prescriptions are issued as the legal copy of these prescriptions is accessed via prescription exchange services and downloaded directly into a pharmacy’s dispensing software.
May be subsidised under the PBS
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Legality to supply – ACT regulation | |
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Prescriber requirements on issuing a phone/fax order |
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Requirement for prescriber to send paper prescription to the pharmacist | June 2020 amendment to faxed prescription requirements
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Permitted medicines |
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Pharmacist obligations | |
Legislative instrument | S31 and S120 Medicines Poisons and Therapeutic Goods Regulation 2008 |
Relevant resources | Telehealth prescribing fact sheet (ACT Health) |
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Legality to supply – NSW regulation | |
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Prescriber requirements on issuing a phone/fax order |
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Requirement for prescriber to send paper prescription to the pharmacist |
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Permitted medicines |
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Pharmacist obligations |
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Legislative instrument | Clauses 36, 44, 81 & 96 Poisons and Therapeutic Goods Regulation 2008 (NSW) |
Relevant resources | NSW Health Guide to poisons and therapeutic goods legislation for pharmacists |
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Legality to supply – NT regulation | |
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Prescriber requirements on issuing a phone/fax order | Verbal prescription:
Prescriptions, including faxed prescriptions, may be issued electronically in accordance with the Electronic Transactions Act (NT) 2020. |
Requirement for prescriber to send paper prescription to the pharmacist |
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Permitted medicines |
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Pharmacist obligations |
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Legislative instrument | Section 19, 61, 97 Medicines Poisons and Therapeutic Goods Act 2012 |
Relevant resources | Supplying without a prescription- Pharmacist fact sheet (NTG Department of Health) |
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Legality to supply – QLD regulation | |
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Prescriber requirements on issuing a phone/fax order | Verbal prescriptions:
Faxed prescription:
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Requirement for prescriber to send paper prescription to the pharmacist |
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Permitted medicines |
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Pharmacist obligations |
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Legislative instrument | 84, 92, 227 Medicines and Poisons (Medicines) Regulation 2021 |
Relevant resources |
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Legality to supply – SA regulation | |
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Prescriber requirements on issuing a phone/fax order | Prescription via telephone or fax:
Emailed prescriptions are not provided for in SA under the Controlled Substances (Poisons) Regulations 2011 |
Requirement for prescriber to send paper prescription to the pharmacist |
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Permitted medicines |
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Pharmacist obligations | |
Legislative instrument | Regulation 33 Controlled Substances (Poisons) Regulations 2011 (SA) |
Relevant resources |
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Legality to supply – TAS regulation | |
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Prescriber requirements on issuing a phone/fax order | Verbal prescription:
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Requirement for prescriber to send paper prescription to the pharmacist |
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Permitted medicines |
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Pharmacist obligations | |
Legislative instrument | Regulations 23 and 47 Poisons Regulations 2018 (Tas) |
Relevant resources |
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Legality to supply – VIC regulation | |
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Prescriber requirements on issuing a phone/fax order | A prescriber may issue a verbal instruction to supply a medicine an emergency.
Faxed prescriptions: Not valid for supply without a verbal instruction (Exception: medicines supplied under PHEO#4: see digital image prescription) |
Requirement for prescriber to send paper prescription to the pharmacist |
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Permitted medicines |
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Pharmacist obligations | |
Legislative instrument | 25, 47(1), 48 Drugs, Poisons and Controlled Substances Regulations 2017 |
Relevant resources |
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Legality to supply – WA regulation | |
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Prescriber requirements on issuing a phone/fax order |
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Requirement for prescriber to send paper prescription to the pharmacist |
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Permitted medicines |
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Pharmacist obligations |
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Legislative instrument | Regulation 17 Medicines and Poisons Regulations 2016 (WA) |
Relevant resources |
Emergency supply of medicines allows a pharmacist to initiate a small quantity supply (usually 3 days’) of a Prescription Only Medicine (S4) in an emergency without a prescription when it’s not possible to contact the patient’s prescriber. Under this arrangement there is no requirement for a follow up prescription.
Medicines supplied under what is commonly known in most jurisdictions as the ‘3-day rule’ are ineligible to be supplied under the PBS and can’t be changed into a full quantity dispensing at a later date on presentation of a prescription.
These permanent provisions existed within state/territory regulation prior to COVID-19. They may remain relevant during COVID-19 if Schedule 4 medicines are unable to be supplied under Expanded Continued Dispensing and other temporary expanded emergency supply provisions.
Not subsidised under the PBS
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Legality to supply – ACT regulation | |
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Conditions which must be met to supply Prescription Only Medicine in an emergency without a prescription. | Pharmacist satisfied:
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Maximum quantity able to be supplied |
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Labelling and recording requirements |
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Medicine excluded |
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Other requirements of supply | Pharmacist must send notification to ordinary prescriber in writing within 24 hours |
Legislative instrument(s) | S251 – S254 Medicines Poisons and Therapeutic Goods Regulation 2008 |
Relevant resources |
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Legality to supply – NSW regulation | |
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Conditions which must be met to supply Prescription Only Medicine in an emergency without a prescription. | Pharmacist satisfied:
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Maximum quantity able to be supplied |
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Labelling and recording requirements |
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Medicine excluded |
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Other requirements of supply | |
Legislative instrument(s) | Clauses 7, 45, Appendix A Poisons and Therapeutic Goods Regulation 2008 (NSW) |
Relevant resources |
Last updated 7 December 2022 (NSW)
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Legality to supply – NT regulation | |
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Conditions which must be met to supply Prescription Only Medicine in an emergency without a prescription. | Pharmacist satisfied:
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Maximum quantity able to be supplied |
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Labelling and recording requirements |
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Medicine excluded |
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Other requirements of supply | |
Legislative instrument(s) |
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Relevant resources |
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Legality to supply – QLD regulation | |
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Conditions which must be met to supply Prescription Only Medicine in an emergency without a prescription. | Pharmacist reasonably satisfied:
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Maximum quantity able to be supplied |
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Labelling and recording requirements | Labeling requirements:
Recording:
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Medicine excluded |
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Other requirements of supply | |
Legislative instrument(s) |
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Relevant resources |
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Legality to supply – SA regulation | |
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Conditions which must be met to supply Prescription Only Medicine in an emergency without a prescription. | Pharmacist satisfied:
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Maximum quantity able to be supplied |
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Labelling and recording requirements |
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Medicine excluded |
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Other requirements of supply | |
Legislative instrument(s) |
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Relevant resources |
For best viewing experience on a mobile we recommend using landscape mode.
Legality to supply – TAS regulation | |
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Conditions which must be met to supply Prescription Only Medicine in an emergency without a prescription. | Pharmacist satisfied, on reasonable grounds:
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Maximum quantity able to be supplied |
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Labelling and recording requirements |
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Medicine excluded |
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Other requirements of supply | |
Legislative instrument(s) |
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Relevant resources |
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For best viewing experience on a mobile we recommend using landscape mode.
Legality to supply – VIC regulation | |
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Conditions which must be met to supply Prescription Only Medicine in an emergency without a prescription. | Pharmacist satisfied:
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Maximum quantity able to be supplied |
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Labelling and recording requirements |
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Medicine excluded |
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Other requirements of supply | |
Legislative instrument(s) | |
Relevant resources |
For best viewing experience on a mobile we recommend using landscape mode.
Legality to supply – WA regulation | |
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Conditions which must be met to supply Prescription Only Medicine in an emergency without a prescription. | Pharmacist satisfied on reasonable grounds:
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Maximum quantity able to be supplied |
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Labelling and recording requirements |
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Medicine excluded |
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Other requirements of supply | Regulation 29 Medicines and Poisons Regulations 2016 (WA)*
* information regarding non-divisible packs drawn from WA Health fact sheet |
Legislative instrument(s) | |
Relevant resources |