MOGA Input to the Pharmaceutical Benefits Scheme (PBS) 24-Month Review of the Minimum Stockholding Requirements

2 May 2025 

Dr Jennifer Soon developed MOGA’s input to the Department of Health and Aged Care 24-month review of the PBS Minimum Stockholding Requirements (MSR, Pricing and PBS Policy Team), providing the following feedback on the profession’s experience with the MSR to support policy review and the operation of the MSR: 

 • Rather than the MSR/PBS, clinicians rely more heavily on stock information from our pharmacists who provide us with directly relevant information on local access, timeframes, and strategies to get around shortages. However, the quality of this information is variable depending on the pharmacy department. 

• Despite the MSR, the system has experienced drug shortages, i.e. capecitabine, cisplatin. 

• Medicines subject to MSR should be cross-checked with the WHO list of essential medicines (eg. cyclophosphamide omitted, lots of haematological omissions). 

• Where medicines only have 1 or 2 stockists, minimal holding requirements should be greater, with the holding amount considering turnover rate of stock. 

• MSR compliance should be publicly available, as this may help anticipate and strategize around shortages.