Painaustralia’s policy team working for you

As mentioned above, it has been a busy time for Painaustralia drafting submissions to several reviews, guidelines and consultations including:  

Guiding Principles for Medication Management in the Community and Guiding Principles for Medications Management in Residential Aged Care Facilities

In April this year, the Commonwealth Department of Health (the Department) engaged the Australian Commission on Safety and Quality in Health Care (the Commission) to lead a review and update of the Guiding Principles for Medication Management in the Community and Guiding Principles for Medication Management in Residential Aged Care Facilities.  This update will consider best-practice evidence, standards and advice from experts, providers, and users of medicines in the health and aged care sectors.

Painaustralia made submissions to the review of both these guidelines that were being held simultaneously. Our submissions endorsed the guidelines but recommended that the resources be expanded to include resources and programs to provide consumers with knowledge to seek out the most appropriate pain management options; and give prescribers the tools they need to deliver best-practice pain medicine in aged care facilities and the wider community.

Review of the National Medicines Policy

Painaustralia made a submission to the review in which we highlighted several areas that could be fine-tuned and improved to make things better for people living with chronic pain. Some of Painaustralia’s comments and suggestions for improving the NMP included:

• adding a principle of being ‘outcomes focused’;
• while the NMP’s role in addressing chronic disease is a critical one, there is no mention of ‘chronic disease’ in the current NMP and this needs to be addressed;
• the definition of the word ‘medicine’ needs to include any product that acts like a medicine, which focuses on the therapeutic effect of a good rather than its form. After all, medicines are no longer just a pill;
• while the inclusion of consumers on several initiatives related to the NMP is a positive step, Painaustralia would also welcome the participation of consumers who are living with or affected by the condition and use medication as part of future Government consultation processes;
• clear messaging regarding decisions and changes to medicines-related policy needs to be considerate of the implications for specific consumer groups;
• consumer needs must be recognised in the pursuit of advancing medical technologies; and
• Painaustralia noted a lack of focus in the document on implementation including goals, measures, reporting and review frameworks which we suggested should be addressed in future versions.

The NMP review provides an important opportunity to fundamentally change the way Australia’s medicines policy works to advance better health outcomes for consumers. To achieve this, it must not just be a set of words we can all agree to. An implementation plan supported by measurable, reported and regularly reviewed outcomes measures must sit alongside the policy. It is only by adopting this outcome informed approach that a high-level policy like the NMP can have positive impact in alleviating pressure on our health system.

The Painaustralia NMP Review Submission 2021 is available on our website here.

Post-market Review of Opiate Dependence Treatment Program (ODTP) Medicines

There are currently three medicines available for the treatment of opioid dependence under the Pharmaceutical Benefits Scheme (PBS) Opiate Dependence Treatment Program (ODTP). These medicines are buprenorphine (tablets and modified release injections), buprenorphine with naloxone (films) and methadone (oral liquid).

The ODTP Post Market Review was an opportunity to review the current program arrangements to ensure that Australians who have an opioid dependency continue to have access to medicines to help treat their opioid dependence.

Painaustralia’s response to this review was provided through the lens of those living with chronic pain who use some form of opiate medication to manage their condition, including those who may wish to start on an ODTP.

In the response, we called for an ODTP service model that:

• is consumer focussed;
• is easily accessed in terms of location and minimal out of pocket expenses;
• is agile and adaptive to individual patients’ needs; and
• Takes a multidisciplinary approach to pain treatment and management.

The Australian Medical Research Future Fund Strategies and Priorities consultations

In this submission Painaustralia provided feedback on:

• how the Strategy and Priorities can be altered to better meet the purpose set out in the MRFF Act;
• the most critical current and future issues and factors impacting on the health system, including primary prevention, and on the health and medical research sector that the next Strategy and Priorities need to address;
• options for how the next Strategy and Priorities could address these critical issues; and
• given the new and significant impact of COVID-19 on health services and health research, how should the new Strategy and Priorities address COVID-19 related topics.

In our response, we called for the Strategy to be updated to include chronic conditions and to adhere to the strategies outlined in the National Strategic Action Plan for Pain Management as well as funding to be directed to new and emerging treatments for chronic pain.

The Opioid Analgesic Stewardship in Acute Pain Clinical Care Standard consultation.

In April 2020, the TGA engaged the Australian Commission for Safety and Quality in Healthcare to develop a framework for a National Opioid Analgesic Stewardship program, and an accompanying clinical care standard, which together support the opioid analgesic regulatory changes. The aim of the TGA regulatory changes, the National Opioid Analgesics Stewardship program and the accompanying clinical care standard is to minimise the risk of harm associated with opioid analgesic use.

Painaustralia’s response focused on the consumer perspective, based on the experience of our members, Consumer Advisory Group, and our broader consumer network. The submission outlined overarching principles and factors that need to be considered in the development of the Standard. In our submission we made a number of recommendations including:

• ensuring opioids are prescribed appropriately, especially in the case people with chronic pain who are admitted to hospital; and
• that the Standard mandates and monitors the documentation of management and de-escalation plans.

Making sure proper consultation is built into a patient’s discharge protocols if they are prescribed opioids; and when appropriate, patients should be provided with take home resources that includes information about the medications they are prescribed, the duration and dose and the review protocol.