Real Time Prescription Monitoring(RTPM)

Why real time prescription monitoring matters for your practice

RTPM converts a clinical judgement into a documented legal obligation. Before these systems existed, a prescriber writing a script for oxycodone or diazepam had no reliable way to know what the patient had already been prescribed elsewhere, and no duty to find out. In most states and territories that has been reversed: the information is available in the prescriber's software, and the law requires them to look at it.

For a practice, the exposure is not abstract. The obligation attaches to each prescribing occasion, so a single patient over a few months can generate dozens of separate potential offences. It also sits alongside, not inside, the AHPRA system. A prescriber can be prosecuted under state drugs and poisons law, be the subject of a notification to AHPRA about the same conduct, and face a coronial inquiry, all from one course of prescribing.

The practices that manage this well treat RTPM as a system to be set up, not a habit to be encouraged: the database integrated into the clinical software, every prescriber registered before their first shift, and a documented expectation that the check happens on every occasion rather than when something feels wrong.

What counts as a monitored medicine, and when must you check?

Each state and territory runs its own system under its own legislation, so both the medicine list and the exact duty are set locally. The consistent core is Schedule 8 medicines. What varies is which Schedule 4 medicines are added.

Queensland is the clearest published example. Under Queensland Health's monitored medicines rules, monitored medicines are listed in Schedule 2, Part 4 of the Medicines and Poisons (Medicines) Regulation 2021 and include all Schedule 8 medicines, all benzodiazepines, codeine, gabapentin, pregabalin, quetiapine, tramadol, zolpidem and zopiclone. Before prescribing any of them, a relevant practitioner must check QScript unless an exemption under Schedule 18, Part 1A applies.

Victoria's SafeScript monitors strong opioid painkillers (including buprenorphine, codeine, fentanyl, hydromorphone, methadone, morphine, oxycodone, pethidine and tapentadol), benzodiazepines, the z-drugs zolpidem and zopiclone, ADHD and narcolepsy stimulants (dexamphetamine, lisdexamfetamine, methylphenidate), and other high-risk medicines including ketamine and esketamine.

The duty is usually expressed as taking all reasonable steps to check the database, on each occasion, before prescribing or supplying. Three features of that wording matter in practice:

• It is per occasion, not per patient. Checking once when a patient joins the practice does not discharge the duty for later scripts.
• It is a check, not a veto. SafeScript is explicit that the system helps identify high-risk circumstances but does not prevent a clinician prescribing a medicine they believe is clinically necessary. Nor does it license abrupt cessation, which Victorian guidance states is contrary to patient safety.
• It applies to registered users who do not look. Being enrolled in the system is not compliance. The offence is failing to check.

Limited exemptions exist in each jurisdiction, typically for emergencies or where the database is unavailable, and they are narrower than most prescribers assume.

What the regulator expects, and what happens when it is ignored

Victoria has published a compliance case study that shows exactly how this is enforced, and it is the clearest statement available of the standard expected.

A middle-aged patient died in mid-2021 of opioid toxicity (tapentadol and oxycodone). In the six months before the death, the patient received prescriptions for monitored medicines from nine different prescribers. The Department of Health investigated all nine.

One, an experienced GP registered with AHPRA for nearly 20 years, had registered as a SafeScript user in April 2020 but had never accessed a patient profile before prescribing a monitored medicine. SafeScript had by then been mandatory for over a year. Between February and May 2021 that doctor prescribed tapentadol on seven occasions, oxycodone on three and diazepam on two, without checking on any of them, and without holding a Schedule 8 Treatment Permit for the patient.

The outcome:

• 24 charges, comprising 12 summary offences under section 30F of the Drugs, Poisons and Controlled Substances Act 1981 (failing to take all reasonable steps to check SafeScript before prescribing a monitored poison) and 12 indictable offences under regulation 17(c) of the Drugs, Poisons and Controlled Substances Regulations (failing to ensure a therapeutic need existed).
• Convicted and fined $20,000, plus $8,500 in costs. The Magistrate noted that without a guilty plea the aggregate fine would have been $50,000 with conviction.
• Coronial findings concluded that the conduct of each of the practitioners, in prescribing without taking all reasonable steps to check SafeScript and heed its alerts, was connected with the patient's death.

The case study also sets out what the record would have shown had it been checked: treatment with a Schedule 8 medicine beyond eight weeks by one or more practitioners, a daily morphine equivalent dose above 100 mg, and a prescribing frequency indicating possible drug dependence. That is the point an assessor or investigator returns to. The information was available, in the prescriber's own software, and was not looked at.

Common mistakes

• Treating registration as compliance. The doctor in the Victorian case was a registered SafeScript user throughout. The offence was not looking.
• Checking once per patient rather than once per occasion. The duty attaches to each prescribing event, which is why a single patient generated 12 separate charges.
• Assuming it only covers Schedule 8. Benzodiazepines, z-drugs, quetiapine, gabapentinoids, tramadol and codeine are monitored in some jurisdictions. Check your own state's list rather than reasoning from the schedule.
• Applying one state's rules across borders. A practice with clinicians working in more than one state, or prescribing by telehealth to patients interstate, is dealing with more than one regime.
• Not onboarding new prescribers. Locums and registrars are the most common gap. RTPM access belongs in the credentialling and orientation checklist, not in the first week's to-do list.
• Recording nothing. Where the check prompts a change in management, the reasoning belongs in the clinical record. A file that shows the alert was seen and considered is a very different document from one that is silent.
• Reading an alert as an instruction to stop. The systems are decision support. Abrupt cessation of long-term high-risk medicines carries its own risk, and the regulator says so.

Frequently asked questions

Is checking SafeScript or QScript actually mandatory?

In most jurisdictions, yes. In Victoria it has been mandatory since 1 April 2020 to take all reasonable steps to check SafeScript on each occasion before prescribing or supplying a monitored medicine, subject to limited exceptions. In Queensland a relevant practitioner must check QScript before prescribing a monitored medicine unless a regulated exemption applies. The specific duty, the medicine list and the exemptions are set by each state or territory.

Which medicines are monitored?

All Schedule 8 medicines in every jurisdiction, plus a list of Schedule 4 medicines that varies by state. Queensland's list adds all benzodiazepines, codeine, gabapentin, pregabalin, quetiapine, tramadol, zolpidem and zopiclone. Victoria monitors strong opioids, benzodiazepines, zolpidem and zopiclone, ADHD and narcolepsy stimulants, and other high-risk medicines including ketamine and esketamine.

What is the penalty for not checking?

It is a criminal offence under state drugs and poisons law, charged per prescribing occasion. In the published Victorian case a general practitioner faced 24 charges arising from 12 prescribing occasions across four months, was convicted, and was fined $20,000 with $8,500 costs. The Magistrate indicated the fine would have been $50,000 without a guilty plea.

Does RTPM stop me prescribing a medicine?

No. Victorian guidance is explicit that the system assists clinicians to identify high-risk circumstances but does not prevent them prescribing or dispensing a medicine they believe is clinically necessary. It is decision support, and the clinical decision remains the prescriber's. Equally, an alert is not a reason to stop a long-term medicine abruptly.

Do practice managers have any obligation here?

The legal duty sits with the individual prescriber or pharmacist. The practice controls the conditions that make compliance possible: software integration, RTPM registration for every prescriber including locums and registrars, and orientation that names the obligation. A practice that has not set those up has made a per-occasion criminal offence easy to commit.

How does RTPM relate to AHPRA obligations?

They are separate systems that can be triggered by the same conduct. RTPM duties come from state drugs and poisons legislation and are enforced by the state health department through the courts. Prescribing that departs significantly from accepted professional standards can also give rise to a mandatory notification to AHPRA and to conditions on registration. One course of prescribing can produce a prosecution, a notification and a coronial inquiry.

Last reviewed 25 July 2026