Thank you to the Australian Medical Association Queensland (AMAQ) for providing valuable feedback on the immunisation aspects of the proposed amendments to the Medicines and Poisons (Medicines) Regulation 2021.
We greatly appreciate AMAQ members taking the time to share their considered comments, which will be carefully reviewed as part of the consultation process.
Queensland Health recognises the vital role general practitioners play in the delivery of whole of life immunisation services and broader health care. The proposed amendments are intended to improve accessibility to immunisation services for all Queenslanders by strengthening the immunisation workforce, enabling providers to work safely to their full scope of practice, and harmonising relevant workforce authorisations. Ahpra registered health professionals must continue to practise within their individual scope of practice, as defined by their professional registration, qualifications, education, training, and clinical competence. This requirement ensures that all immunisation activities are performed safely, effectively, and in accordance with relevant professional standards, guidelines, and legislation.
If the proposed amendment is approved, Queensland Health will develop a supporting clinical guidance document to address frequently asked questions and outline best practice clinical guidance and reporting.
As you are aware, under the Australian Immunisation Register Act 2015 (the Act), immunisation providers are mandated to report most vaccinations to the Australian Immunisation Register, including all National Immunisation Program, COVID-19, influenza and Japanese encephalitis vaccines administered. It is also strongly encouraged that providers report non-mandated vaccinations to support best practice and ensure that patients’ immunisation histories are complete and up to date. This will also be included in supporting resources, as required.
Vaccine administration errors (VAEs) and adverse events following immunisation (AEFIs) will continue to be reported in accordance with current requirements. Under the Public Health Act 2005, AEFIs are a notifiable condition and must be reported to Queensland Health. All reported AEFIs and VAEs are monitored through Queensland’s public health surveillance systems and shared with the Therapeutic Goods Administration for national monitoring. Reports are reviewed and, where required, followed up with both the immunisation provider and the affected individual to ensure appropriate clinical management and accurate reporting. This coordinated approach supports ongoing vaccine safety monitoring and public confidence in Australia’s immunisation programs.
Queensland Health acknowledges the importance of maintaining appropriate clinical governance to ensure immunisation is delivered safely and within providers’ scope of practice. A range of existing national and state frameworks continue to apply, ensuring certain immunisations remain accessible to appropriately trained and authorised providers. For example, access to and administration of the yellow fever vaccine is limited to approved Yellow Fever Vaccination Centres where specific providers have completed specific Commonwealth accredited training. Any possible future high complexity immunisation medicines will continue to be managed through existing clinical governance and regulatory mechanisms. Where additional conditions, exclusions, or credentialing are required, Queensland Health will implement these through updates to authorisation frameworks, clinical guidance, and training requirements in consultation with relevant professional and regulatory bodies.
Finally, the intent of the proposed amendment is to align midwives’ immunisation authority with their clinical training and individual scope of practice, primarily supporting immunisation within the context of pregnancy, postpartum, and early childhood care.
Thank you again for the considered feedback and ongoing engagement on the proposed amendments.
Kind regards
Queensland Health Immunisation Program