Submission to the Australian Centre for Cannabinoid Clinical and Research Excellence (ACRE) consultations on the draft NSW Cannabis Medicines Prescribing Guidelines.
Painaustralia was pleased to provide a response to the Australian Centre for Cannabinoid Clinical and Research Excellence (ACRE) consultation on the draft Prescribing Guidance Prescribing Cannabis Medicines for Non-Cancer Pain (CNCP).
Despite the lack of an evidence-base, medicinal cannabis may be considered an option of last resort where a range of other therapies have been exhausted.
While Painaustralia supports current efforts to enable expedient access to medicinal cannabis where it has been correctly prescribed, we remain concerned about the unintended consequences of inappropriate cannabis prescribing on a uniquely vulnerable cohort of consumers.
The development of a sound evidence base remains a critical enabler to ensure safe and effective use of medicinal cannabis in CNPC and requires further research and investment as we still have much to learn about the role medicinal cannabis can play in addressing chronic pain conditions.
Submission to the RACGP Aged Care Guidelines: Medical care of older persons in residential aged care facilities.
Painaustralia provided input to the Royal Australian College of General Practitioners (RACGP)’s review of the draft aged care clinical guide (Silver Book). It is estimated up to 80% of aged care residents have chronic pain, however more than half of residents (52%) in aged care facilities in Australia have a diagnosis of dementia while two in three (67%) require high-level care to manage behaviour. This suggests a high proportion of people with chronic pain also have cognitive or communicative impairment and inability to report pain.
Chronic pain is a common condition among consumers of aged care services and effective pain management should be a core responsibility of all providers. Unfortunately, evidence suggests many people with pain are poorly treated or under-treated. Painaustralia consulted with several stakeholders, including pain specialists and geriatricians to inform our response to this consultation.
Submission to TGA Consultation on Proposed reclassification of spinal implantable medical devices.
Painaustralia provided input to the Therapeutic Goods Administration’s (TGA) consultation around the proposed reclassification of spinal implantable medical devices. Spinal implants can provide significant benefits to patients with diseases or injuries of the spine and can contribute to improvements in quality of life. For example, reduction in back pain increases productivity, reduces dependence on medications, and in general facilitates more activity, leading to improvements in quality of life.
Recent device failures and subsequent findings have revealed a poorly regulated industry that has put consumers at considerable risk of harm, including those with persistent and chronic pain. In particular this has highlighted the need for more patient education and information around medical devices and the potential risks that they may pose.
Overall, Painaustralia is supportive of the proposed reclassification of all spinal implantable medical devices (excluding some ancillary components) from Class IIb (medium-high risk) to Class III (high risk).
Submission to TGA prescription medication under evaluation Consultation
Painaustralia welcomed the opportunity to provide input to the Therapeutic Goods Administration’s (TGA) consultation around whether the TGA should publish that a prescription medicine is under evaluation.
The availability of information is a cornerstone of informed decision making. From a patient perspective earlier knowledge about potential availability of treatments, should they be approved, may be considered as part of discussion about options for medical treatment and care with their healthcare practitioners. It is equally important to ensure that consumers also have all the facts before they can make such informed decisions which will impact their treatment pathways.
Painaustralia supports Option 2: listing of all applications accepted for evaluation. This will ensure the highest level of application transparency based on evidence of efficiency of applications and this option is also consistent with the approach used by some comparable overseas regulators.
Submission to Productivity Commission Inquiry into Mental Health
Painaustralia provided a submission to the Productivity Commission (the Commission) Inquiry into the role of improving mental health to support economic participation and enhancing productivity and economic growth. The issue of mental health is an important one for us and our members, as the comorbidity between mental and physical health problems is well documented, especially when illness becomes chronic. Nowhere do psychiatric and medical pathologies intertwine more prominently than in pain conditions. Painaustralia ran a national survey to inform our response to the Inquiry and received an overwhelming response with 550 participants, highlighting the widespread concern about both issues.
Prioritising pain and pain management together with mental health policy would significantly reduce the burden of mental health conditions, especially in rural and remote areas.
The relationship between mental health and pain is overwhelming and tackling both health challenges is required to improve the quality of life for many Australians impacted by these conditions particularly those living outside the major cities.
The Commission’s Inquiry provides us with a unique opportunity to address crucial public health challenges presented by chronic pain and mental health.
MBS Review Taskforce
The MBS Review Taskforce released their recommendations for consultation. The Review has provided Painaustralia with a copy of their recommendations, with the Committee making 32 suggestions across three major areas – recommendations for change, deletion and referrals and new items. Painaustralia coordinated a sector wide response following a meeting with the Taskforce chair, Professor Bruce Robinson, also provided written input.
Like all chronic conditions, chronic pain is best managed in the community and evidence supports a multidisciplinary model of care that takes into account the physical, psychological, social and environmental factors that influence the experience of chronic pain.
In its current form, the MBS does not support the realisation of a multidisciplinary, patient-centred approach in primary, secondary or tertiary healthcare settings. This approach continues to be endorsed by the pain sector and is articulated in the National Pain Strategy (the Strategy) which provides a blueprint for the treatment and management of acute, chronic and cancer pain. The growing evidence base continues to support the Strategy as best practice. As noted in the draft recommendations, as the specialism of pain management matures, it is clear that the structure that supports it needs to mature.
Strategic action is now vital in tackling the growing burden of pain. Since the inception of the Taskforce and the establishment of the Pain Management Clinical Committee, new data has emerged that highlights the need for urgent policy change. The cost and impact of pain has grown exponentially in our community, and it is vital that we act fast to manage this pressing issue.
Overall, Painaustralia is supportive of the Committees recommendations and the directions outlined in the report. Our submission predominantly focussed on the recommendations for the addition of new MBS items.
National Strategic Action Plan for Pain Management (the Action Plan)
Painaustralia has received feedback on the National Action Plan from the Department of Health and all States and Territories. Painaustralia met with the Department to consolidate the feedback and has provided them with a final version of the plan. Advice is that the plan will be heading to the next Australian Health Ministers Advisory Committee (AHMAC) at the second COAG meeting of 2019, with Federal Health Minister Greg Hunt expressing certainty that the plan will go forward beyond the term of any Government.
It identifies specific actions to address the health issues that affect women and girls throughout their lives and aims to reduce inequities in health outcomes between men and women, and between sub-population groups of women and girls.
Importantly, this includes recognising chronic pain as one of the eight major chronic conditions (arthritis, asthma, back pain and problems, cancer, cardiovascular disease, chronic obstructive pulmonary disease, diabetes or mental health conditions).
Painaustralia is pleased to be a signatory to the consensus framework for ethical practices in health care, developed in collaboration by a large group of Australian health leaders, and endorsed by Australian federal, state and territory health ministers.
More than 50 signatory bodies have signed the framework, which was developed in collaboration with a host of Australian professional health bodies, industry organisations, hospital and health services associations, regulators, patient and advocacy groups and other related organisations. Signatories to the Australian Consensus Framework for Ethical Collaboration are committed to delivering the best outcomes for patients. Collectively they share similar challenges and hopes – including the desire to maintain and improve ethical behaviour.
More information on the framework can be found here.