//Supplementary report: Undoing the knots constraining medicine regulation in Queensland

Supplementary report: Undoing the knots constraining medicine regulation in Queensland

17 December 2018

This supplementary report provides a snapshot of the current landscape of schedule 8 medications in Queensland, highlighting key initiatives and activities implemented since the 2016 investigation in response to the recommendations. This report also considers the impact of anticipated legislative change and the introduction of real time prescription monitoring (RTPM) on the use and regulation of scheduled medicines in Queensland.

In the original investigation report the then Health Ombudsman made 16 recommendations proposing solutions and risk mitigation strategies associated with five particular areas of concern or ‘knots’. The Director-General, Queensland Health accepted all 16 of the report’s recommendations and has provided regular progress updates to the office on the implementation of the recommendations.

Monitoring progress

The office actively monitors the implementation status of recommendations to:

  • support and assess the timely and appropriate implementation of recommendations
  • assure the Health Ombudsman and the public that appropriate activities and improvements have been implemented in response to systemic issues identified during an investigation
  • promote the safety and quality of health service delivery through public reporting of shared learnings.

This investigation report included a recommendation monitoring plan that outlined expectations regarding implementation and monitoring activities by the office, requiring the submission of a progress report and quarterly meetings between Queensland Health and the office.

The office received two comprehensive progress reports from the Director-General, Queensland Health, containing an explanation and evidence of actions taken by Queensland Health towards implementing the 16 recommendations. Following consultation with Queensland Health, the office is in agreement that 13 recommendations have been fully implemented and three have been partially implemented.


Legislative complexity

At present, suitable regulatory change is proceeding. The Health Ombudsman notes that two recommendations remain in progress and are on track to be fully implemented. This will occur when the proposed Bill is passed into legislation in a form that addresses the recommendations in the investigation report and a subsequent education program commences.

The Health Ombudsman acknowledges that education under the current regulatory system remains an ongoing need amongst clinicians.

Real time prescription monitoring

The value and benefits of a fully mandated and integrated system capable of accessing real time information nationally, appears to be many years away due to the inconsistent roll-out of RTPM systems across the country and a lack of federal oversight or input into the development of these systems.

Despite this, the Health Ombudsman is reassured by Queensland’s recent progress towards an RTPM system and the Health Minister’s reinforced commitment toward support for a federated approach to this issue. The Health Ombudsman considers the recommendation to review RTPM options and develop a business plan to progress implementation in Queensland has been fully implemented.

Agency roles, responses and functions

The investigation report made seven recommendations aimed at clarifying the roles, responsibilities and functions of participants in this regulatory space. Queensland Health has demonstrated a commitment to implementing the recommendations resulting in greater clarity and delineation of agency roles and avenues for communication and interface.

However, one of these seven recommendations regarding the review of MRQ and the MCHT unit’s policies and procedures remains only partially implemented. The Health Ombudsman accepted that further changes to policies and procedures will be required as a result of the implementation of the proposed Bill and RTPM system, however this does not exempt Queensland Health from the need to provide a consolidated and authoritative version of documents to provide guidance to staff on current operational processes and requirements.

Communication and collaboration

The Health Ombudsman is impressed by the commitment and problem solving strategies demonstrated by the working group and network representatives toward unravelling this knot and is satisfied the three associated recommendations have been fully implemented.


In examining the regulatory framework for managing safe and appropriate access to schedule 8 medications, the investigation report identified 16 recommendations to improve medicine regulation in

Queensland. The Health Ombudsman confirms that 13 of the recommendations have been fully implemented with two recommendations dependent on the proposed Bill passing into legislation and the roll-out of an education program.

Read the report