Prescribing and Medicines Concerns: What Regulators Look For

A prescribing concern is about how a practitioner prescribes, supplies, administers, stores or records medicines. It applies to every practitioner with medicines authority: doctors, nurse practitioners, endorsed midwives, dentists, pharmacists, optometrists and podiatrists with scheduled medicines endorsements, paramedics administering under protocols, and others working under state and territory arrangements.

Concerns come from patients and families, pharmacists, other practitioners, employers, coroners and regulators such as state and territory pharmaceutical services units and the Professional Services Review. They range from a single dispensing or dosing error to sustained prescribing of drugs of dependence without adequate assessment.

Prescribing authority comes from several layers at once: the Poisons Standard, state and territory drugs and poisons laws, PBS rules for subsidised prescriptions, and your National Board registration and any endorsement. Lawful authority is often narrower than it looks, and it never exceeds your competence. Your Board's code applies to every prescribing decision, including adequate assessment, records and working within your competence.

Real-time prescription monitoring (RTPM) systems now operate in every jurisdiction and connect through a national exchange. Whether checking is a legal requirement depends on where you practise, and the rules have changed several times since 2020. For example, Victoria made checking SafeScript mandatory for prescribers and pharmacists in April 2020, subject to exceptions; Queensland's Medicines and Poisons (Medicines) Regulation 2021 requires specified prescribers and pharmacists to check QScript before prescribing, dispensing or giving a treatment dose of a monitored medicine; South Australia has required use of ScriptCheckSA for certain monitored medicines since 1 April 2022; and Western Australia made registration with ScriptCheckWA mandatory in June 2025 for those who prescribe or dispense monitored medicines.

Professional obligations go beyond the legal minimum. If a patient is harmed and the history that would have changed your decision was available in a monitoring system you did not check, it will be difficult to argue that your prescribing met the expected standard, whether or not checking was mandatory where you work. An alert calls for a conversation and judgement, not automatic refusal or abrupt cessation. Document what you saw, what you discussed and why you decided as you did.

Telehealth adds another layer. Prescribing drugs of dependence by telehealth requires a real-time consultation, identity checks and an RTPM check, and you need to know which jurisdiction's rules apply when the patient is elsewhere. If you prescribe cosmetic injectables, see also our page on cosmetic practice concerns.

Ahpra assesses the concern against what it knows about you and your practice, and requests records, often together with dispensing and monitoring data. Because prescribing leaves a detailed trail, a pattern is usually visible: quantities over time, intervals between supplies, co-prescribed sedatives, and whether reviews, monitoring checks and approvals are recorded. Where one patient is named in the notification, investigators commonly look at others.

Assessment considers your regulatory history, your response and actions, and the support your workplace provides. Outcomes range from no further action, through cautions and conditions such as restrictions on prescribing Schedule 8 medicines, supervision, audit or education, to suspension or cancellation in the most serious cases. Prescribing to oneself, diversion of stock or prescribing in exchange for money can prompt immediate action where a Board reasonably believes there is a serious risk to the public.

Separate processes may run alongside: a state or territory medicines regulator can restrict your authority, and the Professional Services Review can examine PBS prescribing. Restrictions imposed by a medicines and poisons regulator must be notified to Ahpra within seven days.

The skipped check

A dentist planning a three-day supply of oxycodone after a complex extraction skips the monitoring check because he is running late. The pharmacist finds two recent oxycodone supplies from other dentists and a current benzodiazepine. The dentist changes to a non-opioid plan, documents why and adds the check to his standard post-extraction workflow. Handled this way, it becomes a learning point rather than a notification.

The long-term patient

A GP inherits a patient on high-dose opioids and a benzodiazepine, renewed for years without documented review. When a pharmacist raises a concern, the question will be what the GP did once the care was theirs: whether they reviewed goals, checked monitoring, discussed tapering, offered naloxone and sought approvals. Continuing an inherited regimen unchanged is still a prescribing decision.

The favour for a friend

A nurse practitioner writes a short course of a sleeping tablet for a close friend who is struggling after a bereavement. It feels compassionate. It breaches the expectation not to prescribe medicines of dependence for people close to you, and may breach drugs and poisons law. The safe answer is warm and brief: suggest the friend sees their own practitioner, and help them book.

Where a prescribing concern has been raised, the Board's focus is on whether the risk has been managed. That usually means evidence of changed practice: a policy, audit results, supervision reports, and documented learning. Education can help you understand the legal layers and the standards behind each decision, and our courses each include a reflective account to record what you have changed.

A course can support your learning but does not by itself satisfy any condition or undertaking. If you have conditions on prescribing, comply exactly and seek advice from Ahpra and your MDO or indemnity insurer about what a condition permits. Confirm with Ahpra or your Board whether any proposed education is acceptable. Our courses are independent and are not accredited and not approved by Ahpra or any National Board, and no course can guarantee any regulatory outcome. If you are working under conditions, our course on complying with conditions and undertakings explains how to stay compliant and build towards a review.