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JUNE,Edition # 28, 2001

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ALLAN JELLEFF

MEDICAL CENTRES
Revisiting the Approval Number Debate (Part 1)


Editor's Note:
Late last year we ran a series of articles on medical centres.
The corporate model which appeared set to dominate the development of medical centres created a number of potential and actual problems for pharmacists (and GP's), in that the model was a public company entity geared to satisfying a maximum dividend to shareholders, while seeming to pay lip service to patient needs.
Vertical integration and concentration of services meant that so called "leakages" were minimised, and those services not located within the medical centre were then put under stress.
These centres, however, satisfied a basic patient need.
For the first time, many patients were able to make an appointment and have it kept down to the minute. Never mind that the service provided could only be a very basic one....this is what most patients seemed to think they required.
So the concept has proved popular with patients, with an added incentive that bulk billing is automatically provided. This in turn has put pressure on the federal government to increase Medicare rebates to doctors, because the medical centre operators take approximately fifty percent for their cut.
Pharmacists have had additional difficulty in locating into medical centres, because of Guild pressure to maintain location restrictions.
The logic behind the restrictions is irrational and should not exist.
It is also a decision that will return to haunt the Pharmacy Guild.
Allan Jelleff, a medical centre pharmacist from Western Australia, is practicing without an approval number, because of Guild restrictions.
He outlines his problems.

Allan Jelleff:
"I would like to further the debate regarding new and relocated PBS approval numbers that began in your 18th edition, December 2000.
Unfortunately, the Guild spokesman did a very good job of not answering your questions and attempting to muddy the waters on the issue.
My discussion is centred on the question of if the relocation restrictions actually deliver a benefit to the profession as a whole.
The guild has put these restrictions to the profession as a saviour, but in reality it is an apartheid-like policy that pits pharmacist against pharmacist.
The relocation rules do not protect anyone from the exorbitant rents charged (a cost which must be passed on) and prevent pharmacists from locating their businesses in the most economically viable and professionally appropriate positions.

Your questions and the guild spokespersons' answers are a good place to start the discussion."

[Computachem]
* Would medical centre developers bother with doctor dispensing if they were able to have a pharmacy on site?

[Kos Sclavos]
The Guild is not opposed to medical centre pharmacies per se.
In fact I have owned a medical centre pharmacy, sub-leasing from a corporate medical centre group for over 12 years. A special rule for medical centres was looked at in the Guild/ Govt negotiations but in the end they all had loopholes for medical centre developers and unethical pharmacists to get around.
Do you base it on size of the medical centre.
Do you base it on the number of doctors or do you base it on the number of patients seen per week? A right of refusal to the local pharmacist was considered. (Why would you move from 250m2 to 1000m2) In any of these cases I could do a deal a deal with doctors in a couple of days and have a medical centre up. I would then apply for an approval number and I have my pharmacy. Three months later the surgery closes but I still have my approval number. The whole exercise would cost me no more that $50000.
A cheap approval number I suggest.
The fact is that all models had loopholes.

Comment
An exemption for new or relocated PBS approval numbers for eligible medical centres was recommended by the National Competition Policy Review of Pharmacy Legislation, if the location rules weren't scrapped.
Why does the Guild think it has the right to ignore and over-rule the findings of an independent review panel that listened to all interested parties?
The Guild spokesperson puts up arguments based on the premise using "fear tactics" that this is going to be abused.
His comments regarding abuse could only apply if all parties were unscrupulous, and if a new approval was to be granted.
I ask, what's the objection to allow relocation of existing approval numbers, as applies to shopping centres?
The Guild also objected strongly at a committee meeting of the Department of Health and Aged Care to the relocation of PBS Approval numbers into medical centres.
With regards to relocation of Approval numbers:
1. No one is going to relocate to a medical centre, just to re- relocate to another site.
2. Criteria for eligibility of a medical centre can be achieved much easier than that for shopping centre relocations:
for example, the criteria could be set that an eligible medical centre is one which sees a minimum average of 1000 Medicare billed patients per week over a six month period. These records could be easily, quickly and undisputedly verified by HIC - they've got them all on computer records.
As far as how many, well that's as easy as it was to come up with how big a shopping centre?
It just takes a will to agree on a figure. Of course if you are against the proposal, you may not agree to any number. Based on HIC figures, and average a fulltime equivalent GP should see about 130-150 patients per week. So a figure of 1000 patients per week would be equivalent to about 7 GP's. Using the patient number per week with verification by HIC over prolonged period eliminates the ability to "fudge" the figures.
3. The above model can be fine-tuned, but where is the loophole?
A medical centre of this size would certainly have a large number of acutely ill patients needing medications quickly, but it is the patients that suffer due to the Guild's interpretation of the issue.
4. Why penalise the public and the profession as a whole on the possibility that a single proprietor may attempt to act improperly. If this were thought were to apply universally, then sadly there would be no approved pharmacies at all.
5. The Guild spokesperson talks about unethical pharmacists and medical centre developers. Firstly it is a shame he has such a dim view of his own profession. If he really wants to see some money hungry developers, have a look at the leases being out forward by shopping centre developers who are definitely, unashamedly and openly only there for the maximising of their profit. I viewed a shopping centre lease recently that was over 30mm thick with conditions all designed to fleece the signatory.
Why has the Guild designed the agreement to provide exemptions to benefit shopping centre developers and not acutely ill patients or pharmacists?
Again if he is to use the argument of abuse, then it can be equally said of shopping centre developers.
In actual act, these simple criteria mentioned for medical centre eligibility above has less potential for abuse, as the figures needed to reach eligibility are supplied by the HIC, not by shopping centre developers.
6. Was the Guild spokesperson "unethical" in his dealings with his corporate medical centre group?
If no, then why punish the profession?
Or does he have information on the unethical dealings of the other 500 pharmacists that are currently in medical centres throughout Australia?
Of course not.
Like every other issue concerning pharmacists, the are the vast majority of us are ethical, honest people.
7. Do you have unethical pharmacists and shopping centre developers exploiting loopholes? There is no objection on that count from the Guild.
8. The Guild appears not want large medical centres (where these PBS prescriptions actually come from) to be able to have pharmacies relocated to them, and providing a service, which is of great benefit to the health consumer. Why?
9. As with shopping centres, where no right of refusal is allowed to pharmacists within 2 kms of the development, why then even consider it for large medical centres? In the environment of free competition, the only argument the Guild has against relocation to medical centres is to stop competition on service and price between pharmacists.
Competition, which, they have no argument with when a new shopping centre goes up - you can even have three pharmacies if it is big enough.
Based on the exemption for relocation rules with regard to shopping centres, they have no argument at all if the same rules apply for medical centre, and eligibility is the easiest hurdle, if there is a will to do it.
If the Guild is not opposed to pharmacies in medical centres, then please explain why you so vehemently opposed relocation?
One has to wonder. The Guild spokesman appears to believe doctors are a pretty corrupt lot too.
It would be well worthwhile asking the AMA and RACGP to comment on his statements. I'm sure it would enormously enrich the collaborative approach needed between pharmacists and doctors to provide quality use of medicines, a point being publicly endorsed by the Guild.

Editors Note:
It is obvious that Allan is operating under extreme and unnecessary conditions, imposed upon him by an organisation set up to represent and defend his needs.
The CoAG working committee have advised that they are not in favour of the restrictions on medical centres past July 1st 2001, and they have also further advised that they are not in favour of pharmacists being the sole owners of pharmacies. Both these items are still on the agenda and will be revisited.
These facts have not been publicised by the Guild, because it would diminish the image they are promoting i.e. as being the saviours of pharmacy.
If they, or you, are not particularly worried by these happenings, then I can only say that I am!
Allan Jelleff will conclude his contribution in the next edition of the newsletter.
Ends


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