The public health bureaucracy planning to put regular over-the-counter pain relief out of reach for millions of Australians admits its intervention will cost taxpayers hundreds of millions of dollars.
In a pre-Christmas sneak release reminiscent of the Australian Bureau of Statistics’ controversial 2015 census announcement, yesterday the Therapeutic Goods Administration announced it would ignore public opinion and cut access to all pain relief products containing codeine except via prescription. A public outcry forced the health bureaucrats to pause a planned ban in 2015. But from 2018, Australians wanting access to codeine, which is a more effective form of pain relief than supermarket-sold paracetamol products, will have to go to a GP to obtain a script.
The public health lobbyist body the Advisory Committee on Medicines Scheduling, run by government-appointed health bureaucrats and academics, made the decision based on a report commissioned by the TGA by consultants KPMG. The male-dominated committee decision has already been criticised for ignoring the needs of women with endometriosis. Given the TGA originally proposed the ban, it remains the case that no independently commissioned study has been done of the proposal.
Doctors’ groups were originally highly supportive of the ban, which would mean Australians would be forced to visit GPs more in order to access any pain relief products beyond the low-impact headache tablets available from supermarkets. However, that necessarily means a big additional call on taxpayers via the Medical Benefits Scheme, as well as some additional Pharmaceutical Benefits Scheme costs. A report commissioned by the Pharmacy Guild — which opposed the change — claimed that, after removing the variety of circumstances in which no additional GP visit would be necessary for someone who had previously purchased codeine over the counter from pharmacists, the proposal would require 8.7 million additional GP visits per year at an annual cost of $316 million, or more than $4 billion over a decade, adjusted for inflation.
While this industry costing is clearly self-interested and probably overstated, the KPMG offers a figure every bit as problematic: it claims the number of additional GP visits would be less than 10% of the number proposed by the Pharmacy Guild report — just 540,000 a year — and the whole cost would substantially fall after the first year because (for reasons not explained) costs “would taper off over time”. KPMG’s cost of the impact of the ban on the MBS and PBS is just $268 million over a decade.
But some of the assumptions underpinning the report appear, to the layperson, at least eccentric. Most bizarrely, the report assumes that non-codeine pain relief — for example, paracetamol from the local shops — can be readily swapped with codeine without any diminution of benefit for users: “for most of these consumers, as the evidence indicates, there is no incremental health effect of the use of low dose codeine combination products compared to using these analgesics without codeine”. Those who rely on codeine to manage intermittent but serious pain might take a different view from the consultants employed by the public health lobbyists.
The report arbitrarily assumes that five deaths will be prevented each year by the ban, and also assumes that most consumers will have ready to hand a valid repeat script for codeine-based pain relief from their GP when needed, rather than needing to undertake an additional visit to a GP to obtain a new script. The report also assumes that the government will fund an education campaign relating to the ban and ways for consumers to access pain relief. However, “the question of how an education campaign for consumers would be funded, and what form it might take is still to be determined and is dependent on the regulatory process changes, if any. The cost of this campaign was not included in these costings.”
Remarkably, the modelling and regulatory impact statement for the decision include no assessment of the tighter restrictions on availability introduced after the TGA’s first, abortive effort to ban access to codeine in 2015. The Pharmacy Guild rolled out MedsASSIST nationally after a New South Wales and Queensland trial in April this year, to track people’s purchase of codeine products — the reason why you’re now asked to produce a driver’s licence or other ID when you purchase Panadeine Extra at the chemist. Indeed, KPMG explicitly rejected using data from MedsASSIST in its work. The TGA has decided to ignore MedsASSIST entirely in its decision.
Averaging the cost estimates of the PGA and KPMG reports suggests that the total cost to taxpayers of the ban via higher MBS and PBS costs would be over $2 billion over the coming decade. But assuming the PGA report significantly overstates those costs would still mean a substantial impact on taxpayers in a health system where funding is already under serious pressure and the government is looking to curtail, not increase, cost pressures within the MBS and PBS budgets.
And that’s separate from the core problem of the TGA’s ban: that its committee of public health lobbyists knows better than individual Australians how to sensibly manage their pain without calling on governments to regulate and fund them.