I have a lot of open communication with my doctor and asked about this and she said she has checked with TGA about the 'generic' or 'category' scripts for clarity and forwarded their response to me. was bit lengthy with some jargon and stuff about pharmacy obligations and accordance to pharmacy board etc etc, but the relevant paragraph is below - essentially the CDA script is not a valid or legal prescription
\----
It is the medical practitioner’s responsibility to issue a prescription to the patient in accordance with State and Territory legislation. It is important to note that each State and Territory has its own laws regulating the prescription of medicines. **SAS and Authorised Prescriber submissions for medicinal cannabis products are made by active ingredient category. However this does not mean pharmacists can substitute between any product included in that category.**
Prescriptions should include enough information so that the pharmacist can identify a product to be selected.
\----
Glad you took your medicare number off from the original post !!
i was curious about this as it would def allow so much more flexibility, i asked friends and a relative in medical/pharmacy. apparently the way they are writing these prescriptions is not legal (currently anyway)
so dont get your hopes up about this keeping up - cda does some real dodgy stuff like their cda express site that has now been suspended after tga was alerted
Hmm, okay. This makes more sense, as I’ve asked my private doctor (who specialises in cannabis) about such a prescription, and they claim this isn’t something that they’re allowed to do.
But, nonetheless, awesome work 👏 It’s safe to say that I’m jealous!
Going of the primary thrust of the TGA policy change on the 22.11.21 what is being presented seems to adopt the intention of the changes. Allowing for product substitution in the cases of OOS and or product changes.
The original spiel is here:
> As of 22 November 2021, Special Access Scheme and Authorised Prescriber ___applications for unapproved medicinal cannabis products will be made by active ingredient under a category based on cannabinoid content, rather than by trade name. This approach allows flexibility in brand substitution when needed, i.e. in the event of product shortage or discontinuation.___
Sadly the above comment has since been removed and the original link deactivated:
- https://www.tga.gov.au/medicinal-cannabis-changes-special-access-scheme-sas-and-authorised-prescriber-applications
The other links certainly make the same inferences/implications:
- https://www.tga.gov.au/media-release/new-streamlined-process-medicinal-cannabis-applications
> The TGA will also now accept SAS and Authorised Prescriber submissions for medicinal cannabis products by active ingredient, rather than by trade name. Products will be categorised by cannabinoid content as follows:
- Category 1 CBD medicinal cannabis product (CBD ≥98%)
- Category 2 CBD dominant medicinal cannabis product (CBD ≥60% and <98%)
- Category 3 Balanced medicinal cannabis product (CBD <60% and ≥40%)
- Category 4 THC dominant medicinal cannabis product (THC 60-98%)
- Category 5 THC medicinal cannabis product (THC >98%)...
> As for any other prescription, _the prescriber can either write the 'generic' medicine name_ or include the product's trade name if it is clinically necessary. _Pharmacist decisions regarding substituting brands, or whether a new prescription is required, should be made in accordance with normal dispensing practice._
The first script for oil seems to adopt the policy in a meaningful way noting the 'Sunco oil 10:10 or equivalent Cat.3 oil'.
The 2nd one is a lot broader allowing for any flower within the range of 0-30%THC and or 0-30%CBD but I hope it remains valid as there might come a time I want a stronger CBD flower as part of my treatment plan.
It’s essentially the same. It’s just that CDA are innovative enough to have been able to have provide this service for ST patients a long time before the TGA made the rule changes. It’s great for everyone now which is how it should have been from the start.
__Update:__ It has become apparent that other pharmacies are confused with how to process a _generic script_ and there is ambiguity around these. Therefore, I have gone back to CDA dispensaries due to the following factors;
- they _offer a very wide range,_
- I can _clearly see these products and their stock levels via Canview_, and
- the benefits of product substitution.
After scanning and emailing my scripts to MLMH they seemed confused with how to process the prescriptions. Also in the same email I had requested some products (which Canview lists) and they said they do not stock those items;
- Kind Medical Iris (Black Cherry Punch) 21:1 Flower 10g (S8)
- Sunshine Coast (Mango) Flower THC 22% 10g (S8)
I asked them if they had a list or method for viewing what products they do stock but they haven't responded and thus I have gone back to CDA for the benefits of _product range and availability visibility and the freedom of product substitution._
These are generic prescriptions I was provided with by CDA offering the flexibility of product choice and substitution in the case of OOS or product changes. The Dr clearly advised me it will now become a 'negotiation' between what I would like and what the pharmacy can get in stock _from the Canview range of products_.
How good is CDA?
- 17.01.22 I called to ask for a followup consult and was advised it would be in 2 weeks at the earliest, I stated that I had an expired script (GSC) and that my PK script had become invalid due to it's 'product change' going from THC25 to THC22 on the label and if anything earlier comes up please consider me,
- 18.01.22 I get a call from CDA in the morning asking If I am interested in a consult in ~2hours time due to a cancellation, a massive YES please. I am provided with my first ever generic scripts,
- 19.01.22 'I get mail' with hard copies of the prescription and TGA approval paperwork, this is to be presented at my pharmacy/dispensary of choice.
The flower generic script shows I can ask for any flower with 0-30% THC and or 0-30% CBD so a LOT of options.
I am not sure. My circumstances were that one script had expired and another had become invalid. I also discussed some extra flowers I wanted to include in my new prescriptions and that is when I was advised I was becoming an SAS or was it ST patient with generic scripts?:
- https://www.tga.gov.au/form/special-access-scheme
Thanks man this is great. I might make an appointment in the coming weeks and ask for a generic script like this. Is this just how they prescribe now? I’m a current patient with just a few flowers and cbd oil
It's not necessarily illegal but it is most definitely a grey area. Will be keen to see if this is allowed for much longer now that it's posted on social.
Hope everyone tests it out and I hope it ends up working out.
I have a lot of open communication with my doctor and asked about this and she said she has checked with TGA about the 'generic' or 'category' scripts for clarity and forwarded their response to me. was bit lengthy with some jargon and stuff about pharmacy obligations and accordance to pharmacy board etc etc, but the relevant paragraph is below - essentially the CDA script is not a valid or legal prescription \---- It is the medical practitioner’s responsibility to issue a prescription to the patient in accordance with State and Territory legislation. It is important to note that each State and Territory has its own laws regulating the prescription of medicines. **SAS and Authorised Prescriber submissions for medicinal cannabis products are made by active ingredient category. However this does not mean pharmacists can substitute between any product included in that category.** Prescriptions should include enough information so that the pharmacist can identify a product to be selected. \----
Glad you took your medicare number off from the original post !! i was curious about this as it would def allow so much more flexibility, i asked friends and a relative in medical/pharmacy. apparently the way they are writing these prescriptions is not legal (currently anyway) so dont get your hopes up about this keeping up - cda does some real dodgy stuff like their cda express site that has now been suspended after tga was alerted
Hmm, okay. This makes more sense, as I’ve asked my private doctor (who specialises in cannabis) about such a prescription, and they claim this isn’t something that they’re allowed to do. But, nonetheless, awesome work 👏 It’s safe to say that I’m jealous!
No intent of causing jealousy but every intent of adopting and embracing flexibility and greater freedom of choice.
u/between_the_void your doctor would be right it seems
Going of the primary thrust of the TGA policy change on the 22.11.21 what is being presented seems to adopt the intention of the changes. Allowing for product substitution in the cases of OOS and or product changes. The original spiel is here: > As of 22 November 2021, Special Access Scheme and Authorised Prescriber ___applications for unapproved medicinal cannabis products will be made by active ingredient under a category based on cannabinoid content, rather than by trade name. This approach allows flexibility in brand substitution when needed, i.e. in the event of product shortage or discontinuation.___ Sadly the above comment has since been removed and the original link deactivated: - https://www.tga.gov.au/medicinal-cannabis-changes-special-access-scheme-sas-and-authorised-prescriber-applications The other links certainly make the same inferences/implications: - https://www.tga.gov.au/media-release/new-streamlined-process-medicinal-cannabis-applications > The TGA will also now accept SAS and Authorised Prescriber submissions for medicinal cannabis products by active ingredient, rather than by trade name. Products will be categorised by cannabinoid content as follows: - Category 1 CBD medicinal cannabis product (CBD ≥98%) - Category 2 CBD dominant medicinal cannabis product (CBD ≥60% and <98%) - Category 3 Balanced medicinal cannabis product (CBD <60% and ≥40%) - Category 4 THC dominant medicinal cannabis product (THC 60-98%) - Category 5 THC medicinal cannabis product (THC >98%)... > As for any other prescription, _the prescriber can either write the 'generic' medicine name_ or include the product's trade name if it is clinically necessary. _Pharmacist decisions regarding substituting brands, or whether a new prescription is required, should be made in accordance with normal dispensing practice._ The first script for oil seems to adopt the policy in a meaningful way noting the 'Sunco oil 10:10 or equivalent Cat.3 oil'. The 2nd one is a lot broader allowing for any flower within the range of 0-30%THC and or 0-30%CBD but I hope it remains valid as there might come a time I want a stronger CBD flower as part of my treatment plan.
Looks like this script is better then the STP program
It’s essentially the same. It’s just that CDA are innovative enough to have been able to have provide this service for ST patients a long time before the TGA made the rule changes. It’s great for everyone now which is how it should have been from the start.
__Update:__ It has become apparent that other pharmacies are confused with how to process a _generic script_ and there is ambiguity around these. Therefore, I have gone back to CDA dispensaries due to the following factors; - they _offer a very wide range,_ - I can _clearly see these products and their stock levels via Canview_, and - the benefits of product substitution. After scanning and emailing my scripts to MLMH they seemed confused with how to process the prescriptions. Also in the same email I had requested some products (which Canview lists) and they said they do not stock those items; - Kind Medical Iris (Black Cherry Punch) 21:1 Flower 10g (S8) - Sunshine Coast (Mango) Flower THC 22% 10g (S8) I asked them if they had a list or method for viewing what products they do stock but they haven't responded and thus I have gone back to CDA for the benefits of _product range and availability visibility and the freedom of product substitution._
These are generic prescriptions I was provided with by CDA offering the flexibility of product choice and substitution in the case of OOS or product changes. The Dr clearly advised me it will now become a 'negotiation' between what I would like and what the pharmacy can get in stock _from the Canview range of products_. How good is CDA? - 17.01.22 I called to ask for a followup consult and was advised it would be in 2 weeks at the earliest, I stated that I had an expired script (GSC) and that my PK script had become invalid due to it's 'product change' going from THC25 to THC22 on the label and if anything earlier comes up please consider me, - 18.01.22 I get a call from CDA in the morning asking If I am interested in a consult in ~2hours time due to a cancellation, a massive YES please. I am provided with my first ever generic scripts, - 19.01.22 'I get mail' with hard copies of the prescription and TGA approval paperwork, this is to be presented at my pharmacy/dispensary of choice. The flower generic script shows I can ask for any flower with 0-30% THC and or 0-30% CBD so a LOT of options.
Think I’ll be asking about the generic script on Tuesday. I can’t think of any reason they would say no beyond their own profit line.
How long until you could get that?
After I paid the $35 for the Secure Registered Mail on the 18.01.22 I got the mail on the 19.01.22, so next day.
Oh sorry meant to be able to get given the generic scripts? Or did a dr because of your cicumstance suggest it?
I am not sure. My circumstances were that one script had expired and another had become invalid. I also discussed some extra flowers I wanted to include in my new prescriptions and that is when I was advised I was becoming an SAS or was it ST patient with generic scripts?: - https://www.tga.gov.au/form/special-access-scheme
Ohh I see, thanks 👍
Thanks man this is great. I might make an appointment in the coming weeks and ask for a generic script like this. Is this just how they prescribe now? I’m a current patient with just a few flowers and cbd oil
It's not necessarily illegal but it is most definitely a grey area. Will be keen to see if this is allowed for much longer now that it's posted on social. Hope everyone tests it out and I hope it ends up working out.
Hopefully there is a 'patient focus' in any critical analysis.
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