Can You Write Non-PBS Medications on the Prescriber Bag Order Form (PB052)?

 

This article is intended for AHPRA-registered healthcare professionals in Australia. It provides general informational guidance on the PBS prescriber bag supply order form and does not constitute legal or pharmaceutical advice.

One of the most frequently asked questions about the PBS Doctor's Bag scheme is whether a prescriber can add non-PBS medications to their PB052 supply order form when submitting it to a pharmacy. The answer is no and understanding exactly why reveals an important aspect of how the entire prescriber bag system works.

What the PB052 Form Is and What It Is Not

The Prescriber Bag Supply Order Book (form reference PB052) is official Commonwealth stationery issued by Services Australia to eligible prescribers. It is not a general ordering tool or a clinical requisition form. It is a specific PBS instrument whose sole purpose is to enable prescribers to obtain pharmaceutical benefits listed in the National Health (Prescriber Bag Supplies) Determination 2024 at no cost to the prescriber under the Commonwealth's Pharmaceutical Benefits Scheme.[1]

The PB052 is issued through HPOS (Health Professional Online Services) and contains pre-printed triplicate supply order forms, one for each calendar month. When a prescriber completes a form and submits it to an approved pharmacy, the pharmacist uses it to claim reimbursement from the Commonwealth for the cost of the medicines supplied. This is the mechanism by which the government funds the scheme.[2]

Why Non-PBS Items Cannot Be Written on the PB052

There are three separate legal and administrative reasons why non-PBS medications cannot be added to the PB052 form.

1. The form is legally restricted to PBS prescriber bag items

The National Health (Prescriber Bag Supplies) Determination 2024 and the PBS prescriber bag provisions of the National Health Act 1953 (Cth) govern how prescribers obtain pharmaceutical benefits under the prescriber bag scheme. Only items listed in Schedule 1 of the Determination for the relevant prescriber type can be supplied to the prescriber under this mechanism.[3] If an item is not on the schedule, it cannot be obtained as a pharmaceutical benefit through the PB052 process.

2. The pharmacist has no authority to process non-PBS items on the form

When a pharmacist receives a PB052 form, their authority to supply the listed items free of charge derives from their approval as an authorised supplier of pharmaceutical benefits under the National Health Act 1953 (Cth).[4] The reimbursement system they use is a PBS claiming system that only processes items with valid PBS item codes. A non-PBS item has no item code in this system. The pharmacist cannot process it, and doing so would constitute an improper PBS claim.

3. The broader PBS rule on mixing PBS and non-PBS items

The PBS Explanatory Notes for prescribers state clearly that PBS and non-PBS medicines should not be listed together on the one PBS prescription form.[5] While this rule is stated in the context of regular PBS prescriptions, it reflects a structural principle that runs through the entire PBS framework: PBS instruments are for PBS items, and mixing PBS and non-PBS items on a Commonwealth stationery form is improper. The PB052 is a PBS instrument and the same principle applies.

What Happens if a Prescriber Writes a Non-PBS Item on the PB052?

In practice, an approved pharmacist who receives a PB052 form with a non-PBS item listed would be unable to process that item through the PBS claiming system. The pharmacist would need to either:

  • Decline to supply the non-listed item under the PBS form, and supply only the listed items; or
  • Ask the prescriber to use a separate process (see below) for the non-PBS item

There is no mechanism for a pharmacist to supply a non-PBS item as part of a PBS prescriber bag order, and attempting to do so could expose both the prescriber and the pharmacist to administrative or regulatory consequences under the National Health Act 1953 (Cth).

The Correct Process for Obtaining Non-PBS Bag Items

If a prescriber wants to stock their bag with medications not on the PBS prescriber bag schedule, the correct legal mechanism is a written requisition to a licensed pharmacist or wholesaler. This is entirely legal: the prescriber bears the cost, and different documentation applies. A private prescription is not the right instrument and is addressed below as a common misconception.

For a detailed explanation of the legal frameworks governing PBS prescriber bag items and privately sourced practice stock side by side, see: PBS vs Private Medications in the Doctor's Bag: The Complete Legal Framework.

Written Requisition to a Pharmacist - the Correct Mechanism

Under state and territory drugs and poisons legislation, a registered medical practitioner is broadly authorised to obtain, possess, and use scheduled medicines in the lawful practice of their profession.[6] In Victoria, this authority derives from section 13(1)(a) of the Drugs, Poisons and Controlled Substances Act 1981 (Vic).[7] In WA, it derives from the Medicines and Poisons Act 2014 (WA) and the Medicines and Poisons Regulations 2016 (WA).[8] Equivalent provisions exist in every state and territory.

To exercise this authority, a doctor submits a written requisition to a licensed pharmacist or wholesaler. This is a written order, signed by the medical practitioner, identifying them by name and registration, and specifying the medicines and quantities required. It is submitted to a pharmacy in the professional capacity of a registered practitioner, for medicines needed for clinical use. It is not written for a specific patient.

WA Health guidance confirms that pharmacists may supply scheduled medicines to an authorised health practitioner on receipt of a valid written order, for quantities that are reasonable for legitimate clinical use.[8] Equivalent arrangements apply in other states under their respective drugs and poisons legislation.

A valid written requisition should include, at minimum:[9]

  • A unique order identifier (required under Queensland's purchase order rules; recommended nationally)
  • The date of the order
  • The prescriber's full name and AHPRA registration number
  • The prescriber's practice address
  • The premises where the stock will be kept and used (delivery address)
  • The specific medicine, pharmaceutical form, strength, and quantity required
  • The prescriber's original signature
  • A statement of purpose: "for administration in practice to patients under my care"

The pharmacist will supply the items at commercial cost and will retain records of the supply. For Schedule 8 substances, the pharmacist is required to record the transaction in their controlled drug register and cancel the written order to prevent reuse.[10] In South Australia, pharmacists supplying S8 medicines are also required to forward the cancelled written order to the Drugs of Dependence Unit within a set timeframe prescribed by SA Health. The prescriber pays for the medicines -- there is no government subsidy.

What About Private Prescriptions? (Not the Right Mechanism)

A common misconception is that a doctor can write a prescription — for themselves or anyone else — to obtain medicines for their bag. This is not the correct legal mechanism.

The reason is not primarily about self-prescribing rules. It is about the fundamental legal nature of what a prescription is. A prescription is only valid when written for the treatment of a specific, identified patient. The PBS Explanatory Notes confirm that a PBS prescription must be for the treatment of the person named on the prescription.[5] State and territory drugs and poisons legislation reflects the same principle: prescriptions authorise supply to a patient under the practitioner's care, not to the practitioner themselves for general clinical stock.

NSW Health guidance makes this explicit: urgent-use supply to practitioners should not be dispensed in the prescriber's own name, and pharmacists must not fabricate patient records to process practitioner stock orders.[11] A doctor cannot use a prescription in their own name, or in any other way, simply to acquire clinical supplies. The requisition process is the only correct mechanism for obtaining scheduled medicines for clinical practice use.

A note on self-prescribing: Whether a doctor can self-prescribe for their own personal medical treatment is a separate question governed by jurisdiction-specific rules that vary considerably across states and territories. This is entirely separate from the doctor's bag context. Stocking a bag with medicines for patient use is not self-prescribing, and a prescription is the wrong instrument in either context. Practitioners with questions about self-prescribing rules in their jurisdiction should consult their state or territory health authority or seek independent legal advice.

Forms at a Glance: Which Form for What Purpose

Form Purpose Can include non-PBS items?
PB052 - Prescriber Bag Supply Order Book Obtaining PBS-listed prescriber bag items free of charge from an approved pharmacist No
PBS prescription (PB021p/PB023) Prescribing PBS-listed medicines for a named patient No - PBS and non-PBS items must not be listed together on the same PBS prescription form
Written requisition Obtaining scheduled medicines from a pharmacist for clinical practice use, outside the PBS Yes - this is the correct mechanism for non-PBS bag items
Private prescription Prescribing non-PBS medicines for a named, identified patient Yes - but only valid for a specific patient's treatment; not appropriate for stocking clinical supplies

Common Scenario: When the Required Medicine Is Not on the Schedule

The PBS Prescriber Bag schedule does not cover every medicine a GP might reasonably want available in an emergency. There are well-recognised gaps that have been the subject of advocacy submissions to the PBAC, including from peak bodies such as the AMA, on the basis that broader schedule coverage would reduce hospital emergency presentations for certain conditions.

Where a prescriber needs to carry an item that is not on the current schedule, the PB052 form cannot be used to obtain it. The correct mechanism is a written requisition to a licensed pharmacist under state and territory drugs and poisons legislation, as set out earlier in this article. The schedule is periodically amended following PBAC review, and items that were previously outside the scheme may be added over time. [1]

The AMA has publicly advocated for ondansetron's inclusion in the PBS Prescriber Bag schedule, on the basis that ready access to it in the bag would reduce hospital emergency presentations for severe nausea and vomiting, particularly in children. As of the time of writing, ondansetron remains absent from the schedule and the PBAC review process for prescriber bag items is ongoing.

Key Takeaways

  • The PB052 Prescriber Bag Supply Order Book is a Commonwealth PBS instrument and can only be used for items listed on the PBS Prescriber Bag schedule.
  • Writing non-PBS items on the PB052 is not permitted. Pharmacists cannot process them through the PBS claiming system, and there is no legal basis for doing so.
  • For non-PBS medications, the correct mechanism is a written requisition (or, in Queensland, a compliant purchase order) to a licensed pharmacist under state and territory drugs and poisons legislation.
  • A prescription cannot be used to obtain bag medications. A prescription is only valid when written for a named patient's treatment. The requisition process is the correct mechanism for clinical supply.
  • PBS bag items are free to the prescriber and must be supplied to patients free of charge.
  • Non-PBS bag items are purchased at commercial cost by the prescriber and may be charged to patients.

PBS Prescriber Bag supplies you can obtain via the PB052 form may be obtained from any approved pharmacy under the scheme, including community pharmacies, hospital pharmacies, and pharmacy-operated online ordering services.

Order Your PBS Prescriber Bag Online with DocPouch →

References

  1. Australian Government Department of Health and Aged Care. National Health (Prescriber Bag Supplies) Determination 2024. Federal Register of Legislation. https://www.legislation.gov.au/F2024L00414/latest/text
  2. Services Australia. PBS and RPBS Official Stationery. https://www.servicesaustralia.gov.au/pbs-and-rpbs-official-stationery?context=20. See also: DocPouch internal reference. PBS and RPBS Stationery Ordering (Australia) -- Doctor-Focused Operational Guide (confirming triplicate form format).
  3. Australian Government Department of Health and Aged Care. Prescriber Bag (Doctor's Bag) -- Supply Rules, Order Form Requirements, Quantity Limits. PBS.gov.au. https://www.pbs.gov.au/info/browse/doctors-bag
  4. Australian Government. National Health Act 1953 (Cth), Part VII (pharmaceutical benefits); approved pharmacist provisions. https://www.legislation.gov.au/C2004A07384/latest/text
  5. Pharmaceutical Benefits Scheme. PBS Explanatory Notes -- Supplying Medicines: What Pharmacists Need to Know. Section 1.3. https://www.pbs.gov.au/info/healthpro/explanatory-notes/section1/Section-1-3-Explanatory-Notes
  6. Therapeutic Goods Administration. Poisons Standard (SUSMP) -- Legislative Instrument Status and Current Edition. https://www.tga.gov.au/products/regulations-all-products/legislation-and-legislative-instruments/poisons-standard-susmp
  7. Victorian Department of Health. Medical Practitioners and Lawful Treatment. https://www.health.vic.gov.au/drugs-and-poisons/medical-practitioners-and-lawful-treatment. See also: Drugs, Poisons and Controlled Substances Act 1981 (Vic) s 13(1)(a). AustLII: https://classic.austlii.edu.au/au/legis/vic/consol_act/dpacsa1981422/s13.html
  8. Western Australia Department of Health. Requirements of the Medicines and Poisons Legislation -- WA. https://www.health.wa.gov.au/~/media/Corp/Policy-Frameworks/Public-Health/Medicines-Handling-Policy/Supporting/Requirements-of-the-Medicines-and-Poisons-Legislation.pdf. See also: Medicines and Poisons Regulations 2016 (WA). WA Legislation. And: WA Health. Administration and Record-Keeping Guideline for S4 Restricted and S8 Medicines. https://healthywa.wa.gov.au
  9. Queensland Health. Purchase Order Template -- Medicines and Poisons Act 2019. https://www.health.qld.gov.au/__data/assets/pdf_file/0014/1110821/tpl-purchase-order.pdf. See also: Medicines and Poisons (Medicines) Regulation 2021 (Qld). Queensland Legislation. And: State-by-State Legal and Operational Guide for Australian Doctors Holding and Using Non-PBS Clinic Stock Medicines (April 2026) -- national minimum requisition content baseline.
  10. NSW Health (Pharmaceutical Services). Management of Schedule 8 Medicines -- Ordering, Receipting, Storage, Registers, Destruction. https://www.health.nsw.gov.au/pharmaceutical/Pages/schedule-8-medicines.aspx. See also: Victoria. Drugs, Poisons and Controlled Substances Regulations 2017 (Authorised Version incorporating amendments to Nov 2025). https://content.legislation.vic.gov.au/sites/default/files/2025-11/17-29sra020-authorised.pdf
  11. NSW Health. Supply of Prescription Medicines -- Urgent-Use Supply on Written Order; Legal and Unprofessional Patterns. https://www.health.nsw.gov.au/pharmaceutical/Pages/legal-form-prescription.aspx
  12. SA Health. Drugs of Dependence Unit -- Forms and Resources. https://www.sahealth.sa.gov.au/wps/wcm/connect/public+content/sa+health+internet/clinical+resources/clinical+programs+and+practice+guidelines/medicines+and+drugs/drugs+of+dependence/forms+and+resources+for+the+drugs+of+dependence+unit

Further Resources

Disclaimer: This article is intended for AHPRA-registered healthcare professionals in Australia and summarises publicly available information about the PBS Prescriber Bag Supply Order Book (PB052) and related legislative frameworks. It does not constitute legal, medical, pharmaceutical, compliance, or regulatory advice, and is not intended as advertising of any therapeutic good under the Therapeutic Goods Act 1989 (Cth). No specific medicines, brands, strengths, or dosages are referenced. The supply of pharmaceutical benefits under the PBS Prescriber Bag scheme is governed by the National Health Act 1953 (Cth) and the National Health (Prescriber Bag Supplies) Determination 2024. The authority of practitioners to obtain scheduled medicines outside the scheme is governed by state and territory drugs and poisons legislation, which varies between jurisdictions and takes precedence over any general guidance. Legislative provisions referenced are accurate as at the date of publication but are subject to amendment. Practitioners are responsible for verifying current requirements with their jurisdiction's health authority and for complying with all applicable Commonwealth, state, and territory legislation. Independent legal advice should be obtained where required. PBS Prescriber Bag supplies may be obtained from any approved pharmacy under the scheme, including community pharmacies, hospital pharmacies, and pharmacy-operated online ordering services. Sources: see references listed above. DocPouch (www.docpouch.com.au) is an ordering platform and does not provide legal advice. Last reviewed: April 2026.