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DISCUSSION PAPER

Analysis of the Impact of Public Hospital Pharmaceutical


Reforms on Discharge Medication Supply
John K Jackson

ABSTRACT after discharge (if this is solely to obtain prescriptions)


The use of the Pharmaceutical Benefits Scheme (PBS) for dis- and delays in transfer of information from the hospital to
pensing discharge prescriptions in public hospitals and the post-hospital carers regarding changes to the patient's
implementation of national guidelines to improve the quality therapy.
of care of patients in transition between hospital and commu- The Commonwealth has stated that the current dual
nity have been proposed by the Commonwealth. Issues rele- funding systems have 'the potential to lead to poor qual-
vant to the implementation of these reforms include the financial ity health outcomes for patients, inequities in the range
risks to States and hospitals, the impact of PBS procedures on of drugs available in each sector and perverse incen-
hospital practices and the availability of pharmacists. If im- tives for cost shifting between the State(s) and Com-
plemented, the dual sources of pharmaceutical funding would monwealth'. 3 Consequently, it has proposed reforms
remain, perpetuating the opportunities for cost shifting, and aimed at addressing these issues.
inequities in access would continue. An alternative reform could Under the proposal the PBS would be used for pa-
entail the Commonwealth funding all pharmaceuticals in hos- tients on discharge, and for outpatients of public hospi-
pitals using a model developed specifically to complement tals; the States would continue to fund inpatient drug
hospital practices. Support for hospitals to improve the qual- supply. The Commonwealth would also fund high-cost
ity of patient care should be provided regardless of the phar- anticancer drugs for public hospital day patients and, in
maceutical funding model. return for the new funding streams, public hospitals
Aust J Hosp Pharm 2001; 31: 295-9. would be required to implement national quality use of
medicines guidelines developed by the Australian Phar-
INTRODUCTION maceutical Advisory Council (APAC). 4 The offer is based
Australia has an equitable and efficient program of com- upon it being cost neutral to the Commonwealth, with
munity-based pharmacy services, in the form of the Com- the risk of exceptional growth in costs being shared with
monwealth-funded Pharmaceutical Benefits Scheme the States.
(PBS). There is also a high standard of pharmacy servic- Whereas the proposal was offered as part of the
es within the State- and Territory-funded public hospi- Health Care Agreements in 1998, it took until2000 for the
tals. However, at the point of transition between the first State (Victoria) to accept in principle. Protracted
hospital and community sectors, services are poorly in- negotiations regarding implementation have resulted in
tegrated.12 the number of hospitals likely to introduce the reforms
For over a decade, public hospitals in most States falling progressively, and the proposed commencement
have transferred drug costs to the Commonwealth by being delayed a number of times.
reducing the quantities of PBS-listed drugs dispensed
on discharge or at outpatient clinics from one month to a ANALYSIS OF THE PROPOSAL
maximum of one week of therapy and often less. Patients In this paper I will analyse the Commonwealth's propos-
have been advised to visit their general practitioners to al insofar as it relates to the care of patients on discharge
obtain PBS prescriptions for ongoing supply. Some public from hospitals. The analysis will consider whether the
hospitals have also devised arrangements to enable the reforms, if implemented, would achieve the Common-
use of the PBS for high-cost anticancer drugs. These wealth's objectives. It will also cover issues related to
practices have increased Commonwealth PBS and Medi- implementation and the probable response of the stake-
care costs. holder groups.
Concern regarding the quality of care on discharge
has arisen due to patients being prescribed different The Two Sectors
brands of equivalent drugs in the generic-based hospi- The total Australian hospital pharmaceutical market of
tal system and brand-based PBS system. There is a risk approximately $1 billion per annum is growing at 8%. 5
that this may affect the patients' comprehension of their The State-funded public hospitals operate capped phar-
medication, their compliance and continuity of therapy. macy budgets and use a range of strategies to control
Other quality of care issues include patient inconven- pharmaceutical expenditure including formulary restric-
ience due to the need to see general practitioners soon tions, generic drug policies, prescribing guidelines and
active monitoring of drug use. Responsibility for these
controls resides in the hospitals' multidisciplinary phar-
macy committees, which have the capacity to tailor re-
John K Jackson, BPharm, GradDipHospPharm, Integrated Pharmacy strictions in response to exceptional local situations. 67
Services, Melbourne, Victoria
Address for correspondence: John Jackson, 40 The Avenue, Windsor Vic. By comparison, expenditure on the PBS for the twelve
3181, E-mail: jjackson@interpharm.com.au months to March 2001 was more than $4 billion. 8 It is

The Australian Journal of Hospital Pharmacy Volume 31, No. 4, 2001. 295
effectively uncapped and growing at approximately 17% would still exist. The proposal would limit PBS funding
per annum. 9 The PBS operates a nationwide formulary to discharge and outpatient supplies and budget restric-
and as the Commonwealth has little control over the tions will still apply to pharmaceutical use in other sec-
number of prescriptions written and dispensed, it has tions of hospitals. One example of where new cost
attempted to limit PBS expenditure growth through re- shifting could arise is in accident and emergency depart-
strictions on the clinical conditions for which high cost ments. A patient presenting with a diagnosis of myocar-
drugs can be prescribed. It has also enforced rigid pre- dial infarction could be admitted to the emergency
scribing and dispensing regulations and operational department or coronary care unit and treated at the hos-
controls such as maximum prescription quantities and pital's expense with the fibrinolytic drug alteplase at a
dispensing frequencies. 10 cost of more than $1500. 10 Alternatively, they could be
registered as an outpatient and receive the same drug on
THE COMMONWEALTH'S OBJECTIVES the PBS for a maximum of $21.50 in a specially equipped
Quality of Patient Care outpatient clinic.
The APAC 'quality use of medicines' guidelines have The Commonwealth does not propose funding non-
been shown to contribute to an improved standard of PBS drugs for discharge (or outpatients) so the public
care at the time of discharge. Problems that arise as a hospitals would continue to be responsible for their
result of changing between various brands of the same supply.
product are able to be addressed, patients receive a higher Creating two funding sources for the range of drugs
level of counselling regarding their medication and a that have historically been prescribed on discharge may
comprehensive record of changes to prescribed therapy lead to changes in hospital formularies and prescribing
is able to be transmitted to the patient's post-hospital habits. Furthermore, if a hospital reaches its budget limit
carer.n 12 The guidelines were developed by the Federal for PBS drugs and starts to incur risk-sharing penalties,
Minister of Health's advisory committee specifically to the opportunity to revert to the current practice of trans-
address these issues. Although resource intensive, if ferring drug costs to non-hospital PBS supply would
proven to be cost effective, they would contribute to the remain.
Commonwealth's objective of improving quality of care.
ISSUES RELATED TO IMPLEMENTATION
Equity of Access and Range of Drugs Liability of the State Governments
Issues of equity arise when patients in one sector (hos- The Commonwealth has proposed it will meet the cost of
pital or community) do not have access to the types, hospital-initiated PBS prescriptions up to the rate of
brands or quantities of drugs that are available in the growth for non-hospital PBS in the State. Growth above
alternate sector. this level would be shared on a 50:50 basis? Similar cost
Some drugs readily available in community practice sharing arrangements exist for oncology drugs.
are restricted in hospitals. As stated, the quantity dis- The New South Wales Health Department advised
pensed on discharge (or for outpatients) of some public the 1999 Senate inquiry on public hospital funding that
hospitals has been much less than normal PBS quanti- it had reservations about the Commonwealth's proposal
ties. Furthermore, public hospitals have, through formu- as it 'transferred the risk to the States' and that it was a
lary restrictions, limited the number of brands of 'take it or leave it offer'. At the time of the inquiry, the
generically equivalent drugs, the options within thera- Queensland Government reported it did not think the
peutic classes (e.g. angiotensin converting enzyme in- 'risk sharing arrangements are acceptable' . 13 (Queens-
hibitor drug class) or the absolute availability of particular land signed in principle acceptance of the proposal in
drugs. The objectives of these restrictions have been to 2001 14). Sources in all State health departments have re-
promote rational prescribing and good stock manage- iterated the risk to their State of uncontrolled PBS ex-
ment as much as budget control. penditure as being a major impediment to implementing
The Commonwealth's proposed reforms may resolve the proposal. Some aspects of this risk are more pro-
issues of equity relating to the quantity supplied, but nounced at the State level, others at the hospital level.
hospitals are likely to find it appropriate to continue the While the States currently carry all financial risks
other restrictions for quality of care and efficiency pur- associated with hospital prescribing, capped pharmacy
poses. Hospitals would be likely to continue to stock budgets and control measures applied by the hospitals'
only one brand of each drug and to limit the choice of pharmacy committees dampen expenditure growth. If the
drugs with similar therapeutic action. PBS is introduced, hospitals would be exposed to the
Some drugs available in hospitals are not readily growth pattern of PBS expenditure and, as the proposal
available in community practice. Due to their medical is to be cost neutral for the Commonwealth, State au-
conditions, hospital patients often need a broader range thorities would have to agree to share the risk of excep-
of drugs than those used in the general community. Some tional growth in PBS prescribing within the hospitals.
drugs prescribed at discharge will not be on the PBS at The cost to the Commonwealth of the PBS grew at
all (e.g. some drugs for palliative care) and some will be 17.6% per annum in the four years to 1996. 9 In compari-
prescribed for non-PBS indications. Patients will still need son the total Australian hospital pharmaceutical market
to attend public hospitals to obtain these drugs at sub- growth was 6.84% to August 2000 and 8.66% to August
sidised prices. 2001. 5 Under the PBS funding model, the States would
Inequity of access occurs in both sectors and the have a reduced influence over matters that may result in
reforms only go part of the way in solving the problems. further growth in expenditure, such as listing of new
drugs on the PBS or changes to reimbursement formu-
Cost Shifting Practices lae, but would be exposed to the financial risks of those
A number of areas of potential drug-based cost shifting decisions, particularly if the pattern of use of the drug

The Australian Journal of Hospital Pharmacy Volume 31, No. 4, 2001. 296
related to hospital care was greater than in community from manufacturer. There is a risk that pharmaceutical
care. manufacturers would eventually withdraw preferential
An example of a change to reimbursement formulae public hospital drug prices for PBS-listed drugs as the
occurred when the Commonwealth took unilateral ac- low prices may impede their negotiations with the Com-
tion and announced its intention to reduce the whole- monwealth regarding PBS prices. This has already be-
saler margin for certain PBS-listed drugs in the 2001 come an issue in private hospitals and would have an
federal budget. 15 As the Commonwealth does not pay adverse impact on public hospital budgets.
wholesalers directly, these changes will be achieved by While the Commonwealth has stated funding under
reducing the 'price to pharmacist' for these drugs. This the current Commonwealth-State funding agreements will
price is the basis for reimbursement to public hospitals not be modified in the light of these reforms, it is not
under the proposal and unless addressed, hospitals known how these reforms would affect future agree-
would receive a lesser amount when dispensing these ments and whether States or hospitals will be financially
drugs than previously budgeted. 3 better off than in their current restricted budget pos-
Prior to this budget decision, the Commonwealth itions.
had stated that reimbursement at the 'price to pharma-
cist' rate would provide hospitals an 11.1% mark-up on Impact of PBS Regulation on Hospitals
all PBS prescriptions. This assumes hospitals are able to PBS regulations become all pervasive in the workplace.
purchase all PBS drugs at the 'price ex manufacturer' In accepting PBS funding for discharge drugs, public
(directly from the manufacturer at the price they normal- hospitals would need to recognise the high level of con-
ly sell to wholesalers) and while low prices are achieved trol the Commonwealth seeks to maintain over PBS pre-
through State tenders, particularly for drugs off patent, scribing and dispensing practices.
there are many items that hospitals must purchase from Experience in private hospitals has shown the PBS
wholesalers and for which the resultant 'mark-up' will be prescribing and dispensing regulations are not suited to
much less than 11.1%. 3 hospital inpatient (including discharge) practice. 16 The
The PBS reimbursement formula for public hospitals PBS defines not only what can be prescribed but how it
would not include the professional and commercial fees is to be prescribed, how much can be dispensed and
paid to private pharmacists. Consequently the hospitals how often it can be dispensed. While these regulations
would need to fund from other sources the additional may be necessary for the success of the PBS in ambula-
computing infrastructure, stock and facility costs and tory care, they impede the effective provision of hospi-
staffing to operate PBS dispensing. tal pharmacy services.
Furthermore, reimbursement from the Commonwealth Without modification of these PBS procedures to
would be net of the relevant patient contribution fees complement hospital practice plus adequate compromise
and hospitals would face major issues in attempting to by the Health Insurance Commission (the government
collect prescription fees at the time of discharge from a department responsible for payments in relation to the
largely pensioner-aged population. If the patient contri- PBS), implementation of the policy has the potential to
bution is not collected it may be significantly more cost- adversely affect the functioning of public hospitals. The
ly to the hospital to dispense the full PBS quantity than extended delay between Victoria agreeing in principle to
it would under the current supply model. the proposal and the scheduled implementation reflects
This can be illustrated using lisinopril 10 mg tablets the difficulties in negotiating acceptable arrangements.
with a PBS 'price to pharmacist' of $20.22 for 30 tablets
(Table 1). If the hospital purchases the drug at the 'price THE STAKEHOLDERS
ex manufacturer' of $18.38 it would be able to dispense 7 Impact on the Patients
tablets on discharge under current arrangements at a Although patients stand to benefit from the implementa-
cost of $4.29. Under the PBS reform, depending on the tion of the APAC guidelines, the benefits have not been
concessional status of the patient and whether the pa- forthcoming as a result of the guidelines being linked to
tient contribution fee is collected, the hospital's posi- the PBS and oncology aspects of the policy. Patient rep-
tion for dispensing the PBS pack of 30 tablets would resentative groups, particularly those that are members
range from a 'profit' of $3.12 to a 'loss' of $18.38. 9 of APAC, would welcome the implementation of the
guidelines as soon as possible (personal communica-
Table 1. Lisinopril 10 mg 30 tablets tion with J Donovan, Consumer Health Forum, 31 May
2001).
For 30 tablets Concession patient General patient
If public hospitals dispense PBS quantities (up to
Patient fee collected Yes No Yes No one month of therapy rather than the current one week
Patient fee income $3.50 $0.00 $21.50 $0.00 supply or less), there would no longer be an imperative
for patients to see their general practitioners for follow-
me rebate* $16.72 $16.72 $0.00 $0.00
up prescriptions until much later than currently occurs.
Hospital income $20.22 $16.72 $21.50 $0.00 Some patients may find the process more convenient
Cost of drug $18.38 $18.38 $18.38 $18.38 and theoretically this could result in a reduction in Medi-
care payments by the Commonwealth. In practice, many
Profit (loss) $1.84 ($1.66) $3.12 ($18.38)
patients, particularly the elderly and those on complex
* 'Price to pharmacist' less relevant patient contribution fee regimens, would still need to be directed to their general
practitioner for early review after discharge.
The only margin on stock a hospital could achieve
would arise from buying the drug at less than the 'price The Role of the Pharmacist
to pharmacist' via contract purchasing or direct supply The Society of Hospital Pharmacists of Australia has

The Australian Journal of Hospital Pharmacy Volume 31, No. 4, 2001. 297
expressed its support for changes that improve the con- AN ALTERNATIVE PROPOSAL FOR
tinuum of care between hospitals and the community; DISCHARGE MEDICATION SUPPLY
however, it advised the Senate inquiry that the PBS, a To resolve the quality, equity and funding issues raised
community-based system, is not suitable for use in hos- by the Commonwealth it will be necessary to formulate
pitals, is fundamentally flawed, and would not achieve and evaluate alternative proposals compatible with hos-
the intended improvements. 17 pital activities.
Hospitals may not have the capacity to implement
the proposal, due to the nationwide shortage of pharma- The Potential for an Alternate Proposal
cists. Hospitals in all States report unfilled pharmacists The delay in implementation of the current proposal and
positions and the introduction of this policy may exacer- the decision of most States to wait and see what hap-
bate the problem, not only because of the increased pens in Victoria means that negotiation of the next Health
workload but also because of increased attrition. Of the Care Agreement will commence before many States have
pharmacists practising in hospitals, the majority have a made progress on this issue. This provides the opportu-
strong professional focus, reflected in the high percent- nity to consider alternative proposals.
age who have completed postgraduate clinical pharma- Support for modification of the current proposal is
cy studies (34.2% of hospital pharmacists hold likely to arise if the consumer groups perceive the bene-
postgraduate degrees compared with 6.6% of communi- fits from the APAC guidelines are being unduly delayed
ty pharmacists). 18 Some have elected to work in a pro- as a result of being linked to the implementation of the
fessionally satisfying environment rather than PBS funding model.
taking financially more rewarding community pharma- The following matters should be considered in an
cy appointments. 19 alternative proposal.
Some of the existing staff would be expected to leave
if the PBS operating procedures are not modified to suit Quality of Care
the hospital environment and they are forced to work Implementation of the APAC guidelines should be in-
under quasi retail pharmacy arrangements. Industrial corporated into the body of the Health Care Agreements,
bodies representing hospital pharmacists have expressed rather than being linked to a particular drug funding ini-
concern about the impact of the reforms on staff. 20 tiative in a schedule of the Agreements. The 1998 Agree-
At the same time the Commonwealth must be cogni- ments include a section on Quality Improvement and
sant of its relationship with community pharmacy through Enhancement. This involves the Commonwealth fund-
the Third Pharmacy Government Agreement. The Com- ing practices that contribute to healthcare safety and
monwealth has estimated 5% of the PBS could be dis- quality improvement and the guidelines should be fund-
pensed in hospitals and a significant transfer of PBS ed under this section. 21
dispensing from community pharmacists to public hos- The program should include funding for liaison phar-
pitals is likely to result in the Pharmacy Guild seeking macists, able to work between hospitals and the commu-
redress from the Commonwealth. 3 nity, to ensure drug-related issues during transition into
and out of the hospitals are appropriately managed.
Prescibers
General practitioners have received little advice regard- Cost Shifting
ing the policy but their representatives are adamant that Retention of rigid budgets within hospitals while out-
the prescription funding procedures should not be the side the PBS remains uncapped will perpetuate cost shift-
means of manipulating the schedule of medical consul- ing. Establishing an equitable single funding arrangement
tations. Early post-hospital contact with general practi- for all pharmaceuticals is the only way to eliminate bound-
tioners, particularly by elderly and debilitated patients, aries and stop cost shifting practices in drug therapy
is seen as essential. While the policy may address is- (although boundaries would remain between drug and
sues such as confusion about generic drugs, it has the non-drug therapies). As the Commonwealth operates the
potential to increase readmissions to hospital if patients PBS, it is the only realistic single funding body and
are not seen by their general practitioners soon after should accept responsibility for all hospital drugs. Suit-
discharge. able adjustments to Commonwealth-State health fund-
ing agreements would be required.
SUMMARY OF ANALYSIS
The policy has the potential to improve quality of care Funding Model and Coordination of Care
on discharge; however, it maintains the existing dual fund- Because the funding model should complement clinical
ing model, changing the boundary between the State practice and hospital procedures, the current PBS regu-
and Commonwealth's responsibilities and so creating lations are not appropriate. The PBS and HIC should
new cost shifting opportunities. It also creates a finan- accept a hospital prescribing and supply process that
cial risk that most States seem unwilling to accept. results in 'PBS equivalent' outcomes. It is essential that
If implemented, it is likely the lack of compatibility of hospitals retain their cost control strategies and incen-
PBS procedures and hospital activities would create tives should be introduced for hospitals to continue to
workplace problems that would be exacerbated by short- develop cost-effective, evidence-based drug use. At the
ages in hospital pharmacy staffing. same time they must be able to utilise drug distribution
It must be emphasised that the conclusions from methods appropriate to the care of the patient and the
analysis of issues in relation to discharge dispensing do nature of the drug, rather than be forced to use standard
not necessarily apply to the other components of the prescriptions, prescription quantities and dispensing
proposal. processes just to obtain funding.

The Australian Journal of Hospital Pharmacy Volume 31, No. 4, 2001. 298
Whatever funding model is established it should 7. Dartnell J. Activities to improve hospital prescribing. Australian Prescriber
2001; 24: 29-31.
utilise e-commerce and not rely on paper records for 8. Health Access and Financing Division, PBS Prescription Volume. Govern-
purposes of funding and audit. The audit document for ment cost and patient contributions, year ending March 2001. Canberra:
funding should be the drug therapy chart or hospital Commonwealth Department of Health and Aged Care. Available from:
www.health.gov.au/pbd/pubs/pbbexp/pbmar01/book0.2htm [Accessed 13 Oct
discharge summary, these being the primary documents 2001].
for drug ordering in hospitals. 9. Pharmaceutical costs an 'enormous' challenge. Australian Pharmacist 2001;
The Commonwealth should also fund the adminis- 20: 362.
10. Commonwealth Department of Health and Aged Care. Schedule of pharma-
trative, professional, education and audit functions of ceutical benefits for approved pharmacists and medical practitioners. Canberra:
the pharmacy service that are necessary for drug use Commonwealth of Australia; May 2001.
and expenditure monitoring. The supply of medication 11. Stowasser D. Medication information and health outcomes - development
on discharge should be considered part of the episode and evaluation of a medication liaison service [Doctor of Philosophy]. Bris-
bane: University of Queensland; 2000.
of care and appropriately funded without the need to 12. Mant A. Final report of the Continuity of Care in Therapeutics from Hospital
recover contribution fees from patients. This is the mod- to Community Project. South East Sydney Area Health Service; 2000.
el of funding used by the Department of Veterans Af- 13. Senate Community Affairs References Committee. Healing our hospitals.
Report on public hospital funding. Canberra: Commonwealth of Australia;
fairs with approved private hospitals and is proposed December 2000.
for public hospitals. 14. PBS etc. Pharmaceutical Advisory Service, Queensland Health. 2001 (Jun);
Additional staffing would be required to manage the issue No. I.
15. Thornton M. How will wholesaler cuts affect you? Australian Pharmacist
more intensive and higher quality of care on discharge 2001; 20: 491.
and remuneration restructured to attract pharmacists. 16. Jackson J. Use of the Pharmaceutical Benefits Scheme in private hospitals:
I. Associated problems. Aust J Hasp Pharm 2001; 31: 194-8.
17. SHPA Position Statement. Pharmaceutical funding reforms. Proposed in-
SUMMARY troduction of the Pharmaceutical Benefits Scheme into public hospitals. Aust
The Commonwealth should fund programs to improve J Hasp Pharm 2000; 30: 254.
the quality of patient care as an essential and distinct 18. Gysslink P. Community and hospital pharmacists' remuneration survey
report. Melbourne: Salaried Pharmacists' Association; 1997.
component of the Health Care Agreements. It should
19. Health Care Intelligence Pty Ltd. A study of the demand and supply of
fund both PBS-listed and non-PBS pharmaceuticals for pharmacists, 1995-2010. Canberra: The National Pharmacy Workforce Refer-
all patients in public hospitals at all stages of their care ence Group; 1999.
using a funding model built around hospital drug sup- 20. PBS update. Victoria: Association of Hospital Pharmacists; June 2000.
21. Australian Health Care Agreement between the Commonwealth of Australia
ply procedures. Hospitals should be supported and and the State of Victoria, 1998. Commonwealth Department of Health and Aged
obliged to maintain cost control strategies and to pro- Care. Available from: www.health.gov.aulhaf/docslbcalvic/pdf [Accessed April
mote evidence-based prescribing. 2001].

Submitted: July 2001


Accepted after external review: November 2001
References
1. SHPA discussion paper. Funding of pharmaceuticals in hospitals. South
Melbourne: The Society of Hospital Pharmacists of Australia; November 1995.
2. AHMAC Working Party on Pharmaceuticals. Background paper. Canberra:
Australian Health Ministers Advisory Council; November 1995. Editor's note: The proposed introduction of the Phar-
3. Griffin B. Public hospital pharmaceutical reforms associated with the Aus-
tralian Health Care Agreements. Summary of proposed offer. Canberra: Pharma- maceutical Benefits Scheme into public hospitals is an
ceutical Benefits Branch, Commonwealth Department of Health and Family important topic for all pharmacists. This article pro-
Services; May 2001. vide's one persons perspective on one aspect of the pro-
4. Australian Pharmaceutical Advisory Council. National guidelines to achieve
the continuum of the quality use of medicines between hospital and community.
posed reforms. The Journal would welcome other
Canberra: Commonwealth Department of Health and Family Services; 1998. readers' viewpoints for publication in the 'Letters to
5. Wholesale market growth report. Sydney: IMS Health Aust Pty Ltd; Aug the Editor' section-submissions of approximately
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Australian hospitals. Darlinghurst: NSW Therapeutic Assessment Group; 1998. jppr@shpa.org.au .

The Australian Journal of Hospital Pharmacy Volume 31, No. 4, 2001. 299

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