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

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We agree that ivermectin is no more effective for scabies infestati<strong>on</strong>s than topical treatments. Toavoid inappropriate over reliance <strong>on</strong> oral therapy this ought to be emphasised to those instituti<strong>on</strong>sthat may c<strong>on</strong>sider its use.C<strong>on</strong>siderati<strong>on</strong> 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 currentregulati<strong>on</strong>s. It is unclear to us how these facilities will access ivermectin for those who have come intoc<strong>on</strong>tact with the hyper infested individual. One opti<strong>on</strong> would be to have a separate Special Authoritynumber for each patient to be treated. Another opti<strong>on</strong> could be to have a single Special Authoritynumber for the pers<strong>on</strong> who qualifies and the prescripti<strong>on</strong> written to cover sufficient quantity to treatall those who need treatment.Best practise would suggest that complete medicati<strong>on</strong> records should be held at the communitypharmacy for each individual patient. Ideally, a separate prescripti<strong>on</strong> should be presented for eachpatient. Under the Special Authority criteria listed in the current <strong>proposal</strong>, this would be unable tohappen in the instituti<strong>on</strong>al setting.Some ARRC facilities have hospital and n<strong>on</strong> hospital beds. We are c<strong>on</strong>cerned that in cases when thescabies infestati<strong>on</strong> <strong>on</strong>ly 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 <strong>on</strong>ly 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 believec<strong>on</strong>siderati<strong>on</strong> needs to be given to the above points.Thank you for taking the time to read our feedback. If you have any questi<strong>on</strong>s about our feedback, pleasec<strong>on</strong>tact our Guild Policy Advisor, Jasmine Freemantle, at jasmine.freemantle@pgnz.org.nz or 04 802 8205.Yours sincerely,Karen CrispExecutive Chair

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