A ‘… newly registered paramedic’ who volunteers with a General Practitioner Clinic in Western Australia asks:
… if I transition my volunteer work at the GP office (which is currently predominantly an administration-type role plus and on-the-job learning) into a clinical role, what provisions/treatments/prescriptions (if under their authority/by proxy of the GP) am I allowed at present to be able to perform in accordance with state law?
I understand from experience paramedics can dispense medications in WA if there is a poisons permit in place issued by the Department of Health, for example at remote mining sites, and metropolitan areas (such as a large resort/entertainment centre in Perth – which have CPGs and a medical director)…
As such, could the GP I volunteer for create CPGs and I work for him in a limited capacity to either act as his proxy either under direct or indirect supervision, and to what capacity – i.e. as mentioned ability to prescribe/assess patients/ create treatment plans etc.. again keeping in mind that there will be highly details clinical practice guidelines
And it is also important to note that no medications are kept or used on premises, so with regards to medications, would it be allowable for me to present a case, make a recommendation, print a script, have the medical doctor review my case and sign the prescription if they deem it reasonable, necessary, and in the best treatment choice for the patient (especially if it is a long term medications the patient has been on for a long time).
As has been noted before, the Health Practitioner Regulation National Law works via protection of title rather than identifying scope of practice. There is no law that says ‘this work is reserved for doctors, this for nurses and this for paramedics’ with the exception of writing prescriptions and claiming payment from Medicare.
Where paramedics can carry and administer drugs does depend on the Medicine and Poisons Act 2014 (WA) and the Medicines and Poisons Regulations 2016 (WA). The essential thing is the terms of any licence or authority, not the presence of Clinical Practice Guidelines and/or a medical director – see The need for a medical director in an ambulance service (May 4, 2013). It may be that the Department of Health may not issue an authority to an ambulance service without detailed CPGs and a medical director but that is not a requirement of the Act, that is the Department determining what it feels is required to ensure that the drugs are properly used. Further, rather than issue an authority to every employee, the licence or authority may allow the medical director to certify which employees are allowed to carry and use drugs. Where that is a term of the licence then it is that licence that gives the medical director the power to authorise the use and carriage of drugs, not some general power vested in any medical practitioner to authorise anyone he or she sees fit to carry drugs – see Doctors delegating authority to carry drugs (August 20, 2014).
The Code of Conduct for Paramedics (Interim) (June 2018) says at p. 7
Practitioners have a responsibility to recognise and work within the limits of their competence and scope of practice. Scopes of practice vary according to different roles; for example, practitioners, researchers and managers will all have quite different competence and scopes of practice. To illustrate, in relation to working within their scope of practice, practitioners may need to consider whether they have the appropriate qualifications and experience to provide advice on over the counter and scheduled medicines, herbal remedies, vitamin supplements, etc
For my correspondent, working in a GP practice, it will be incumbent upon both the paramedic and the medical practitioner to decide what skills the paramedic has and define the scope of practice accordingly. It is incumbent upon both to reflect on what will best serve the needs of the patients and ensure patient care is the centre of that conversation. In essence however, what “provisions/treatments/prescriptions” my correspondent can provide are those that he or she is competent to provide.
What the paramedic can’t do is actually write a prescription. A medical practitioner can prescribe a schedule 4 or 8 drug (Medicines And Poisons Regulations 2016 (WA) r 51); a paramedic cannot (r 62).
The Medicines and Poisons Act 2014 (WA) s 27 says:
Authorisation of employees and agents
(1) An employee or agent of a health professional acting within the scope of the employee’s or agent’s actual or apparent authority, may do anything that is authorised by the professional authority of the health professional, other than to prescribe a medicine.
(2) For the purposes of this Act, if an agent or employee of a health professional does something that is authorised under subsection (1) the health professional is to be taken to have also done the thing.
If my correspondent is going to work in a GP practice, he or she ‘may do anything that is authorised by the professional authority of the health professional’ remembering that this Act is about the use of poisons.
What is significant is that from 1 December 2018, paramedics will be registered. The Good medical practice: a code of conduct for doctors in Australia talks about working with other health professionals and provides for delegation – that is ‘asking another health care professional to provide care on your behalf while you retain overall responsibility for the patient’s care’ ([4.3]). Before 1 December 2018 a paramedic is not ‘another health care professional’ and after 1 December they will be. A medical practitioner can be far more confident that engaging a paramedic and delegating patient care to him or her may be considered ‘good medical practice’.
In short, the GP can employ my correspondent, a registered paramedic to do any or all of the things suggested, that is assess patients, create treatment plans etc, even “make a recommendation [and] print a script” for the doctor to sign. The doctor as employer takes the legal risk. Whether allowing any or all of those things to happen would be good medical or paramedical practice would be a matter for both the medical and paramedic practitioner to consider, as would be the question of whether and in what detail CPGs are required.
There is little law in this area. A paramedic cannot issue a prescription.
Other than that, registered health practitioners (medical practitioners, nurses, paramedics and members of the other 12 registered health professionals) are expected to act as professionals. To do that they have to keep the patient’s needs and care at the forefront of their thinking and they have to take professional responsibility for the care that they provide.
If a medical practitioner in the course of his or her practice believes that employing a registered paramedic can enhance patient care and the paramedic has clinical skills and knowledge that are appropriate to provide that care, then those practitioners can enter into an employment agreement to provide that care. It is up to them to determine the employee’s ‘scope of practice’ remembering they both have professional responsibilities and duties. There is no list of things that they can or cannot do, that’s the nature of being professionals, they have the responsibility to decide what is appropriate for the patients and what is within their respective areas of skill and competence.