2012 06 29 Feedback on PHARMAC proposal on montelukast ...

<strong>29</strong> June <strong>2012</strong>Christine ChapmanTherapeutic Group ManagerPHARMACSent via e-mail to: christine.chapman@pharmac.govt.nzDear ChristineRE: PROPOSAL TO LIST MONTELUKAST SODIUM AND IVERMECTINThank you for the opportunity to provide feedback on the above proposal.The Pharmacy Guild of New Zealand (Inc.) (the Guild) is a national membership organisation representing themajority of community pharmacy owners. We provide leadership on all issues affecting the sector andadvocate for the business interests of community pharmacy. Our feedback on this consultation is restricted toconsideration of general economic, funding and supply issues. Nothing in this submission should be taken asany endorsement of or any attempt to comment on issues of safety, efficacy or individual patient utility.The Guild supports the proposal to fully fund and list montelukast sodium (Singulair) in Section B of thePharmaceutical Schedule (the Schedule) subject to Special Authority criteria restricting its use to preschoolwheeze and exercise induced asthma. We see this as a positive step for that small number of young patientswhose asthma is sufficiently non responsive to current therapy to the extent that hospital admissions arewarranted. We agree with the Pharmacology and Therapeutics Advisory Committee (PTAC) that montelukastshould be funded for those patients who are already using maximal asthma therapy and continue toexperience frequent episodes of exercise induced asthma.Optimal use of medicine in the community should reduce hospital admissions and make significant savings inthe overall health budget. We look forward to community pharmacy having more input into this with the rollout of the new Community Pharmacy Services Agreement from 1 July <strong>2012</strong>.While the Guild supports the overall proposal to fully fund and list ivermectin (Stromectol) in Section B of theSchedule subject to Special Authority criteria, we do have several concerns.

We agree that ivermectin is no more effective for scabies infestations than topical treatments. Toavoid inappropriate over reliance on oral therapy this ought to be emphasised to those institutionsthat may consider its use.Consideration needs to be given to Age Related Residential Care (ARRC) facilities that are not certifiedto provide hospital care services. They are unable to order medicines by bulk supply under currentregulations. It is unclear to us how these facilities will access ivermectin for those who have come intocontact with the hyper infested individual. One option would be to have a separate Special Authoritynumber for each patient to be treated. Another option could be to have a single Special Authoritynumber for the person who qualifies and the prescription written to cover sufficient quantity to treatall those who need treatment.Best practise would suggest that complete medication records should be held at the communitypharmacy for each individual patient. Ideally, a separate prescription should be presented for eachpatient. Under the Special Authority criteria listed in the current proposal, this would be unable tohappen in the institutional setting.Some ARRC facilities have hospital and non hospital beds. We are concerned that in cases when thescabies infestation only affects the rest home patients, some ARRC facilities may be tempted tomanipulate the current Bulk Supply rules so as to obtain funding for ivermectin treatment. The BulkSupply rules clearly state that medicines obtained by Bulk Supply orders are only to treat “as yetunidentified Service Users” who are in hospital designated beds.We agree that there is a need to be able to supply ivermectin in bulk for severe outbreaks but believeconsideration needs to be given to the above points.Thank you for taking the time to read our feedback. If you have any questions about our feedback, pleasecontact our Guild Policy Advisor, Jasmine Freemantle, at jasmine.freemantle@pgnz.org.nz or 04 802 8205.Yours sincerely,Karen CrispExecutive Chair