Sophie Scamps (Mackellar, Independent) Share this | Hansard source

I rise to speak on the Health Legislation Amendment (Prescribing of Pharmaceutical Benefits) Bill 2025. This bill amends the National Health Act 1953 and the Health Insurance Act 1973 to enable registered nurses, or RNs, who meet specified criteria to prescribe certain medications under the Pharmaceutical Benefits Scheme. The bill implements reforms identified by the government's Strengthening Medicare Taskforce and Unleashing the potential of our health workforce: scope of practice review. These explored the system changes and improvements needed to support health professionals and multidisciplinary team members to work at their full scope of practice. The aim is to deliver best practice primary health care.

The Australian Nursing & Midwifery Federation has welcomed this bill that removes barriers and finally allows highly qualified nurse practitioners and endorsed midwives to work autonomously to their full scope, providing people with better access to quality care without the need to visit their GP or a hospital emergency department. The federation has pointed to the success of nurse led clinics in Tasmania and the ACT that have empowered more nurse practitioners and endorsed midwives to work to their full skill set, thereby expanding the provision of health care in those communities. There is a clear need to enable future designated nurse prescribers to prescribe PBS medications within their scope of practice and as part of collaborative prescribing agreements.

However, despite endorsing the intentions of this bill, serious concerns have been raised by the Royal Australian College of General Practitioners, the RACGP, and the Australian Medical Association, the AMA. Both of these professional medical bodies believe this bill, in its current form, does not provide sufficient protection for patients. Specific concerns include, firstly, that designated nurse prescribers should not be able to prescribe schedule 8 medicines, otherwise known as drugs of addiction, under the PBS; secondly, that there is no requirement for an eligible nurse prescriber to undertake relevant, real-time prescription monitoring or to make contributions to the national medicines record; thirdly, that PBS prescribing reforms should not occur before nurse practitioner accreditation standards scope boundaries and professional safeguards are finalised; and, lastly, that the definition of an authorised practitioner is not limited to a medical practitioner, which poses the risk of unintended consequences, including cross-jurisdictional inconsistency and safety gaps.

Currently in Australia, to be able to prescribe medications, a health practitioner must meet certain criteria, including having completed accredited prescribing education and training that is consistent with their scope of practice, being registered with the national board of their speciality, being approved under the National Health Act 1953 for prescriptions of PBS or Repatriation PBS medicines, and being approved under relevant state and territory legislation and regulation. In September last year, a new registration standard for nurse practitioner prescribing came into effect under AHPRA, the Australian Health Practitioner Registration Agency. This standard, called the 'endorsement for scheduled medicines—designated registered nurse prescriber', sets out how suitably qualified RNs can qualify to prescribe scheduled medicines 2, 3, 4 and 8 in partnership with an authorised health practitioner. The Australian College of Nursing has stated that this standard aligns Australian nursing with international best practice, following successful implementation in countries such as New Zealand, the UK, Ireland and the Netherlands.

The intent of this bill, and the expansion of the integral role that nurse practitioners play in healthcare delivery, has also been welcomed by professional doctors' groups, including the RACGP and the AMA. However, as previously mentioned, these professional medical bodies also have several serious concerns with this bill in its current form.

Neither group supports the prescription of schedule 8 medicines by designated nurse prescribers. Schedule 8 medicines are those that have a high potential for abuse, dependence, addiction and harm, including opioids like morphine, oxycodone and fentanyl. The RACGP and the AMA recommend the bill explicitly prohibit designated nurse prescribers from prescribing schedule 8 medications.

With my 20 years of experience as a GP and emergency doctor, I wholly concur that there is serious risk in significantly expanding the number of prescribers of S8 drugs. There can be enormous pressure for prescribers to provide scripts for these drugs of addiction. Some people will go to extreme lengths to ensure their stories are highly convincing and backed with manufactured evidence. Increasing the number of people who can prescribe these addictive medications, paired with a possible fragmentation of patient care, will mean more opportunities for these medications to be erroneously prescribed.

Another serious risk identified by the RACGP is the absence of a requirement that nurse prescribers undertake real-time prescription monitoring—a national system designed to monitor the prescribing and dispensing of controlled medicines with the aim of reducing their misuse in Australia. This should be absolutely necessary.

The RACGP has also raised the concern that the definition of an 'authorised practitioner' is not limited to medical practitioners. This poses a risk of unintended consequences, including cross-jurisdictional inconsistency and safety gaps. While nurse practitioners would be classified as authorised health practitioners within prescribed agreement frameworks, the RACGP points out that nurses do not undergo the same breadth or depth of training as medical practitioners, including in pharmacology, diagnosis, the interpretation of tests and medication monitoring. As such, the RACGP urge that the medicines prescribed by nurse practitioners need to be carefully selected to ensure patient safety is maintained. Because state and territory legislation defines who can prescribe what, the RACGP and the AMA warn that a vague 'authorised practitioner' label will create cross-jurisdictional inconsistency and safety gaps. They assert that the definition is too broad and ambiguous and that supervising or partner prescribers must have extensive prescribing experience. In practice, these prescribers should be medical practitioners—not a wider group that could include other, non-medical practitioners.

Prescribing agreements for designated RN prescribers must clearly document the roles of the RN and the authorised practitioner. There needs to be clarity that this role is medically led and auditable by the organisations in which designated RN prescribers work and/or by the Nursing and Midwifery Board of Australia. Where RN endorsement involves mentoring, there must be certainty that the mentors are clearly qualified for broad prescribing and are accountable within robust clinical governance.

While the College of GPs support strengthening the Professional Services Review to ensure consistent oversight of designated RN prescribers, they warn that proceeding with PBS prescribing reforms before nurse practitioner accreditation standards, scope boundaries and professional safeguards are finalised would risk undermining patient safety and the integrity of collaborative care models. The college also warns that reforms to nurse practitioner accreditation standards have removed some of the existing safeguards. This includes the abolition of collaborative arrangements which legally required nurse practitioners and midwives to work in structured partnership with medical practitioners. This mandatory requirement was abolished in November 2024.

Admission criteria to nurse practitioner training programs have also been relaxed significantly to reduce the prerequisite total hours of clinical and advanced nursing experience as an RN. Of particular concern is the proposal for nurse practitioners to be subject to only 30 hours of continuing professional development annually. This does not align with the minimum 50 hours of continuing professional development annually that GPs must undertake. The AMA has also consistently advocated that any prescribing of schedule 2, 3 or 4 medications must only occur within medically led, delegated team environments and always under an active prescribing agreement with a medical practitioner.

While the AMA notes that not all their concerns have been addressed, they acknowledge that the Nursing and Midwifery Board of Australia has incorporated several important safeguards into the national prescribing framework introduced under the new registration standard. These include that designated RN prescribers, firstly, can only prescribe a limited range of medicines only for defined conditions and only within their scope of practice; must have at least 5,000 hours of recent clinical experience; and must complete an Australian Qualifications Framework level 8 qualification and have accredited training aligned with predetermined competencies. They must also have a six-month mentorship and a documented collaboration protocol within the prescribing agreement.

The AMA also joins the RACGP in its concern that the bill does not clearly define the term 'authorised health practitioner'. They are concerned that one of the approval criteria allows prescribing agreements to be established with one or more PBS prescribers. This potentially opens the door for non-medical practitioners, including pharmacists or podiatrists, to act in this supervisory role in the future. The AMA argues strongly that only medical practitioners or nurse practitioners acting within their scope are suitably qualified to supervise prescribing. The AMA warns that permitting agreements with other professions risks undermining the collaborative model. They stress that doctors and nurses need to work together within defined protocols and safeguards. When care moves away from collaboration towards independent prescribing, risks multiply due to the fragmentation of care, gaps in clinical oversight and reduced continuity of care for patients.

What is clear from the evidence presented by both the RACGP and the AMA is that prescribing is not an administrative function; it is a clinical responsibility grounded in deep training, broad diagnostic expertise and ongoing professional oversight. Australians rightly expect that the medicines they are prescribed, particularly higher-risk medications, are supported by robust safeguards and delivered within a model of care that protects continuity, safety and accountability.

I agree wholeheartedly with the intent of this bill to expand access and support a more flexible and responsive primary healthcare workforce. But intent alone is not enough. It is one thing to extend access to medical care, but we must absolutely be resolute in ensuring that this greater access does not undermine patient safety and outcomes. For these reforms to succeed, the safety concerns of professional medical bodies with deep experience in the field of prescribing and patient care must be heeded, and the safeguards they urge must be implemented.

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