AMA Queensland members will be relieved to see Queensland Health has taken doctors’ feedback about QScript on board and will be implementing some long overdue changes from 1 July 2024. The amendments include exemptions for patients in low-risk circumstances including:

• in hospital settings
• in aged care facilities
• prisons
• end-of-life care situations

More information can be found in Queensland Health’s overview and in updates to be provided on the Department’s QScript landing page and Medicines and Poisons Act ‘Fact sheets and support documents’ page.
 

Queensland Health invited submissions on its proposed changes to QScript and the Monitored Medicines Standard (MMS) in February 2024. 

The changes include amendments for which AMA Queensland has advocated for some time, including exempting QScript look-up requirements for in-patients and Residential Aged Care Facilities (RACF) residents. The proposal also includes exemptions for prisoners and patients in certain end-of-life situations.

In addition to QScript changes, Queensland Health is also proposing to reduce the scope of the MMS to just the existing, minimum requirements applicable to patients currently registered on the Queensland Opioid Treatment Program.

AMA Queensland welcomes the reforms as evidence that Queensland Health has heard our members’ concerns about QScript and the need to cut unnecessary red tape that wastes clinicians’ valuable time. We anticipate the changes will significantly alleviate the regulatory burden on both hospitalists and general practitioners.

AMA Queensland members have raised concerns that QScript is not adequately detecting patients who try to obtain multiple/denied medications from different practitioners (i.e. so-called ‘doctor-shopping’).

Practitioners understand the issue may be arising because patients can register their Medicare card with a practice but if their date of birth or other identifying information is out slightly or they have an alias, QScript is not nuanced enough to recognise the discrepancy. Doctors were particularly concerned about breaching QScript requirements where patient details have been so registered and they prescribe medication for which the patient has already obtained a script elsewhere or should not have been prescribed.

QScript have provided additional advice on this issue and steps practitioners can take to ensure patients are not being prescribed medications in breach of the requirements. 

The following in an excerpt from an email from the Director, Monitored Medicines Unit Dr Bill Loveday.

Thank you for your email seeking information in relation to the recording, reporting and matching of patient information in QScript. 

Creation of patient profiles
Data populated into QScript is gathered from a range of sources. Patient profiles in QScript are either:

• automatically created based on information received in medication events (i.e. prescription data sent from pharmacy dispensing software and clinic prescribing software) 
• manually created by Queensland Health staff (e.g. when recording prescribing approvals). 

Information gathered from these sources is then matched with prescription events and verified using a range of matching criteria and a patient profile is created in QScript. 

The national real-time prescription monitoring (RTPM) solution (which includes QScript) uses multiple data elements to match prescription events to patient profiles, including:

• Individual Health Identifiers (IHIs)
• Department of Veterans Affairs (DVA) numbers
• patient first name, surname and date of birth.

If there are variations in the patient information received by or input into QScript or a transcription/data-entry error made at source clinical software systems, duplicate patient profiles may be created in QScript. If AMA Queensland members have identified duplicate patient profiles in QScript, they can contact QScript technical support on 1800 776 633 or IT.QScript@health.qld.gov.au, and:

• provide details of each duplicate profile identified e.g. first name, middle name, surname, date of birth, address, Individual Healthcare Identifier etc. (you may wish to provide a screenshot)
• identify which profile(s) has the correct information (if known). 

Importantly we encourage all practitioners to check that a patient’s information is accurately recorded in their clinical software including checking that:

• the patient’s name is correct – ideally this should be the name recorded with Medicare
• the patients date of birth is accurately recorded – it is a requirement under section 124(1)(d)(ii) of the Medicines and Poisons (Medicines) Regulation 2021 that the patient’s date of birth is included in all monitored medicine prescriptions.
• where possible:
  • the patient’s IHI has been recorded and validated
  • the patient’s Medicare and/or DVA number has been recorded.

Ensuring these key identifiers are recorded and accurate will help promote patient safety and a better QScript user experience, through improved data integrity. To that end, users of clinical software systems are encouraged to ensure they are using the software to the vendors’ specifications (including the validating of IHI numbers) to ensure information is recorded accurately within their software which supports data accuracy within QScript and the wider digital health ecosystem.

Patient searches
Minimum requirement P1-1 of the Monitored Medicines Standard requires prescribers to be able to provide evidence of the reasonable steps they have taken, prior to prescribing a monitored medicine, to confirm the patient’s identity. Pages 11–13 of the Monitored Medicines Standard Companion Document provides some guidance on this, which may be of assistance to your members. 

In particular, prescribers are encouraged to consider whether the information they find in QScript (including a search result of ‘no matching record found’) is consistent with their knowledge of the patient. If this is not the case, they may wish to conduct additional searches using different permutations of the patient’s details or—if the patient’s IHI has been validated—the prescriber can manually search for the patient in QScript using just the patient’s IHI.

Further, members may wish to refer to the following resource for further guidance and troubleshooting assistance for specific technical issues users may encounter including when conducting a patient search:

QScript troubleshooting - Version 1.0 (May 2022) (health.qld.gov.au)

Please note, there is a national issue impacting all Australian RTPM systems that impacts how and when patient demographic information is updated. Queensland, along with our jurisdictional colleagues and the Australian Digital Health Agency, are currently working with the RTPM vendor (Fred IT Group) to resolve a range of data quality issues. 

QScript maintains an audit trail of the patient searches a health practitioner has performed and which patient records they have viewed i.e. evidence the health practitioner has checked QScript.

AMA Queensland provided feedback on Queensland Health’s review of QScript look-up and Monitored Medicines Standard compliance requirements.

Submission - 23 February 2023

Queensland Health’s Monitored Medicines Unit (MMU) has provided an updated response to AMA Queensland’s concerns about emails sent to doctors alleging they breached QScript requirements. The MMU’s letter also attached the latest data about practitioner use of QScript and the progress of the QScript Review.

The correspondence indicates there is still much work to be done to improve the functionality of QScript. AMA Queensland will continue to work with the Department to ensure the platform protects patients with the least burden possible on health practitioners.
 

AMA Queensland continues to liaise with Queensland Health’s Monitored Medicines Unit (MMU) about various matters concerning QScript. This includes many issues raised by doctors, particularly ongoing technical difficulties with the platform and QScript look-up reminder emails sent to prescribers in February.
 
The MMU gave an update on its activities to AMA Queensland in August 2023 and the following overview is provided for members.
 
Queensland Health’s QScript Review is continuing. Feedback provided by stakeholders, including AMA Queensland, has now been collated and briefings prepared for the Health Minister. The MMU said it has ‘learned a lot’, particularly about technical difficulties with the system and has already implemented some changes as a result. It said some issues will be more difficult to fix and will require national coordination.
 
The MMU advised the review has highlighted the practical limitations of QScript in certain situations, particularly in-patient settings. The Department is aware that the absence of exemptions within the legislation is creating problems for doctors and is actively considering the issue. At this stage, the MMU was unable to give timeframes for the release of its final report and recommendations but advised it was being progressed to the Minister for her consideration.
 
AMA Queensland was assured it would be consulted on the next phase of the review, including any proposed legislative amendments.
 
The MMU acknowledged the distress caused to some practitioners as a result of its look-up reminder emails sent in February 2023. Unfortunately, the Department have said it is not feasible to include information in the email that identifies the date/s and patient/s for whom practitioners have reportedly failed to check QScript. The Department is also still required to send the reminder emails as part of its Compliance, Monitoring and Enforcement framework.
 
In acknowledgement of AMA Queensland’s concerns, however, the Department has revised the email template and sought our input to the draft. The revised email has a more educational style and includes links to the QScript guide, help page (including phone number and email address) and registration page. AMA Queensland has also made further suggestions, including the inclusion of key information for practitioners about current compliance rates, the QScript Review, an acknowledgement of the platform’s technical difficulties and a statement that QScript is an ‘informational system’ rather than a clinical tool.
 
The MMU will consider this feedback and anticipates sending out the next round of reminder emails in September 2023.

As of 15 December 2022, only 71 per cent of Queensland medical practitioners have registered for QScript. Routine proactive monitoring of QScript will commence from 1 January 2023.

Register for QScript

Before its launch, AMA Queensland raised concerns with how practical accessing QScript would be for medical practitioners:

• working in residential aged care facilities (RACFs)
• working in accident and emergency
• doing ward rounds in public and private hospitals. 

On its launch in June 2021, AMA Queensland encouraged all members to register for QScript. We shared the many learning resources available on the QScript Learning Portal.

The QScript Management Unit intended to introduce penalties for non-compliance on 1 October 2021, but AMA Queensland successfully advocated for a 12-month grace period to allow practitioners time to adapt to this new system. 

While AMA Queensland supported the intent of the QScript legislation, QScript attracted an unprecedented level of negative feedback from our members and some specialist groups (including the Australian Society of Anaesthetists) around technical issues logging into QScript and on non-compliance notices for failing to log-in.

AMA Queensland was vocal in passing on members' concerns and the QScript Management Unit committed to providing six-monthly reports on QScript's implementation, including current status, usage and activity. 

In October 2021, AMA Queensland put a number of questions and concerns to the QScript Management Unit which prompted answers and resources from the unit. 

In response to ongoing advocacy by AMA Queensland and ASMOFQ, Queensland Health confirmed it would review the current regulations that govern the use of QScript in early 2022. The QScript Management Unit conducted a survey to identify potential improvements and how the unit could better support health practitioners to use the system. 

AMA Queensland has continued to raise doctors’ concerns about their legal liability under QScript, as set out in the Medicines and Poisons (Medicines) Regulation 2021. In September 2022, Queensland Health confirmed it was considering policy changes to address these concerns, which may require legislative amendment. 

This means the current arrangements will continue for a further 12 months, with Queensland Health monitoring, educating and encouraging (but not mandating) doctors to use QScript.

Queensland Health has confirmed AMA Queensland will be consulted on the proposed policy and legislative changes after this period.