What the UK medical cannabis industry can learn from Australia
Releaf Group's Neil Cartwright shares lessons from Australia's experience regulating CBPMs
As a frequent visitor to cannabis industry events, I’ve seen there’s no shortage of frustrations shared by most stakeholders. Among the foremost for the UK are the difficulties in increasing the number of patients who have access to cannabis-based products for medicinal use (CBPMs).
Professor Mike Barnes of Maple Tree Consultants estimates that there are about 32,000 cannabis patients in the UK. By comparison Australia had 316,879 patients in 2022, according to the Therapeutic Goods Administration – a huge discrepancy given that Australia has a population of 25 million against the UK’s 67 million,
The obvious question is: why?
Similarities in regulation, sourcing and marketing
There are plenty of similarities between the Australian and British approaches to medical cannabis. Both countries legalised cannabis for medical use at similar times – 2016 in Australia and 2018 in the UK.
Strains come from similar sources, primarily Canada, yielding similar product ranges and comparable prices. Perhaps relatedly, both countries share challenges with supply chains and quality.
Most cannabis is prescribed by specialist doctors in the UK and Australia, with the TGA and the Medicines and Healthcare products Regulatory Agency (MHRA) taking an equally rigorous approach to auditing, compliance and restrictions.
In both territories there are restrictions on how cannabis is marketed. Since the majority of CBPMs are not licensed, there are severe restrictions on what can be said in marketing communications. In Australia strains cannot contain food names like ‘gelato’, for example.
British and Australian police can also both be found confiscating legal cannabis from patients due to lack of education among the forces. And public attitudes to cannabis drug reform are similar in both countries, roughly split into thirds in favour, opposed to or undecided.
The two medicine rule
Clearly, there must be some crucial differences that explain the discrepancy in patient numbers.
First, Australian patients do not have to try two other medicines for their condition before they can access CBPMs. By contrast, in the UK prescribing doctors are advised to check first that a patient should “have tried two types of prescription medication or have discussed and discounted these options based on side effect profile or dependence concerns”.
This has serious drawbacks for a patient considering whether cannabis is right for them. For instance, as endometriosis patients have pointed out to me, this painful condition doesn’t have any prescribed medicine available. So how can a patient have previously tried two?
I’ve also spoken to many self-medicating patients with pain conditions who are worried they’ll be forced to try opioids – the exact thing they’re trying to avoid – before they can get a cannabis prescription.
In contrast, while Australia issues strict guidance around cannabis prescriptions, there is no requirement for a patient to have tried two types of prescription medication.
The second factor behind Australia’s larger cannabis patient numbers are the role of GPs in prescribing CBPMs.
There are two routes for a patient to get a cannabis prescription in Australia. The first is through an authorised prescriber, a role that resembles what happens in the British system. A doctor can opt to specialise in CBPMs and subsequently issue prescriptions.
Less reminiscent of the British system is the Special Access Scheme which allows Australian GPs to prescribe cannabis, so long as the prescription is first approved by the TGA. This now typically takes between one and two days, down from two weeks when the scheme was first launched.
While British GPs can prescribe CBPMs, this only includes a couple of licensed products for highly specific conditions. As sufferers of Lennox-Gastaut syndrome will attest, getting an NHS prescription is far from straightforward.
An Australian doctor can also issue a prescription for up to two years. Electronic prescriptions have also allowed Australian patients to pick up CBPMs from their local pharmacies, with QR codes enabling the pharmacies to monitor how many prescriptions a patient has received.
The effect is striking. According to Releaf estimates, more than 90% of CBPM prescriptions in Australia are done via local GPs, simplifying the process and greatly reducing costs to patients.
That means that in Australia medical cannabis prescriptions have dramatically shifted away from specialised doctors to GPs. When Releaf first launched it relied on specialists – and employed them in our clinics. Now our pharmacies fulfil far more prescriptions made by GPs.
By comparison, British CBPM prescriptions are cumbersome. Patients must take a physical copy of their prescriptions to a pharmacy, and repeat prescriptions must be signed off every 30 days. While the UK government has signalled it will allow electronic prescriptions in the future, these measures have yet to be introduced.
Supply chain issues
The other major obstacle to increasing cannabis patient numbers in the UK concerns the supply chain behind the sector.
Unlike in Australia, in the UK there are a plethora of onerous rules about how much cannabis can be stored by wholesalers and pharmacies. This creates significant logistical challenges, as suppliers constantly have to second guess demand for products. It also means patients often must wait for their medicine to be delivered, while substitutions caused by unavailable products are common.
In Australia, individual pharmacies can store the amount of cannabis medicine they need based on actual demand. This enables them to fulfil an order minutes after a patient presents a prescription physically or digitally.
How the UK can improve
While these challenges in the UK are substantial, Australia’s success suggests that the British medical cannabis industry can bring about the necessary changes to improve patient numbers. Doing this will require sustained engagement and education with the MHRA, the NHS and the government.
Neil Cartwright is head of product at Releaf Group, Australia’s largest cannabis dispensary chain. Based in the UK, he globally sources CBPMs for import to Australia.
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