Regulatory
Case managers keep asking the same question: does a pharmacy review trigger the IME rules? In NSW the answer is no, and the distinction sits in SIRA's own guidelines. Here is how the two frameworks separate.
Current at 14/07/2026. SIRA's 2026 guideline changes continue rolling through to October 2026, and this page will be reviewed and updated as they land.
Why do case managers keep asking this question?
The confusion is understandable. An independent pharmacy review produces a written clinical report from a practitioner who has never treated the injured person. To a case manager trained on independent medical examination procedures, that pattern looks familiar, so the IME checklist gets reached for: written notice to the worker, an offer of provider choice, sign-off from a technical team.
Two recent developments have added to the muddle. Pharmacists now appear within SIRA's provider recognition frameworks, which some teams have read as a signal that pharmacist services carry examiner-style obligations. And the broader 2026 reform program has insurers double-checking every referral pathway. The result is that a service designed to be fast and low-friction sometimes gets wrapped in machinery that was never written for it, and reviews that would have flagged a medication risk early are delayed or never referred at all.
What do the SIRA relevant services guidelines actually say?
The SIRA relevant services guidelines, formally the Guidelines for the Provision of Relevant Services (Health and Related Services), regulate everyone who delivers health and related services in the NSW workers compensation and CTP schemes. They work off the list of relevant services in clause 4A of the State Insurance and Care Governance Regulation 2021, and Table 1 of the guidelines maps each service type to the parts of the guidelines that apply to it.
The two services in question sit in different places on that list.
- Independent medical examinations are a distinct relevant service under clause 4A(1)(za)(i), listed at row 19 of Table 1. In workers compensation, the parts applied include Part 4, which carries the conduct obligations written specifically for independent medical examiners.
- Medication management and review services sit under clause 4A(1)(zc), which covers "medication management and review, including the assessment and analysis of medication use, cost and prescriber behaviour". That is row 22 of Table 1, and in workers compensation the parts applied are Parts 1, 2, 5, 6 and 8. Part 4 is not among them.
In other words, SIRA has already answered the classification question in its own instrument. A pharmacy review and an IME are separate service categories with separate rulebooks. The pharmacist delivering a medication review still carries real obligations, including professional conduct, privacy, record keeping and invoicing requirements, but they are the obligations of a medication management provider, not those of an independent medical examiner.
So are pharmacy reviews subject to IME rules?
The practical differences follow directly from the classification.
| Feature | Independent medical examination | Independent pharmacy review |
|---|---|---|
| Who delivers it | A medical practitioner engaged as an independent medical examiner | A consultant pharmacist with clinical medication review expertise |
| Regulatory head | Clause 4A(1)(za)(i); Table 1, row 19 | Clause 4A(1)(zc); Table 1, row 22 |
| Guideline parts applied (workers compensation) | Parts 4, 5 (in part), 6 and 8 | Parts 1, 2, 5, 6 and 8 |
| Does the worker attend? | Yes, an examination in person or by telehealth | No examination; conducted from the claim file, medication history and dispensing records |
| Written notice to the worker | At least 10 working days under the Workers Compensation Guidelines | No IME notice regime applies |
| Choice of provider | Commonly offered under insurer IME procedures | No such requirement; the referrer chooses the provider |
| Role in disputes | Medico-legal evidence, subject to evidence rules | Claims management advice that informs decisions |
Does the choice of three providers apply to a medication review?
The practice of offering an injured worker a choice of examiners, often three, comes from the IME world. It reflects earlier IME guidance and survives today mostly through insurer internal procedures, which typically require claims staff to nominate a panel before booking an examination.
Whatever form that practice takes inside an individual insurer, it attaches to independent medical examinations. Nothing in Parts 1, 2, 5, 6 or 8 of the relevant services guidelines, the parts that apply to medication management and review services, requires a referrer to offer a choice of three providers before requesting a medication review. A case manager can refer a claim for an independent medication review directly to their chosen provider, the same way they would engage any other claims support service. The safeguards that matter, such as the independence of the reviewing pharmacist from dispensing and prescribing on the claim, come from the provider's own governance rather than from a panel selection step.
What is the AHP register actually for?
SIRA's allied health practitioner approval framework, often shortened to the AHP register, exists so that practitioners delivering treatment in the workers compensation scheme are approved, hold a SIRA approval number, and invoice under the correct requirements. It is a recognition and billing framework for treating practitioners. It was never designed as an examiner panel, and appearing on it does not import IME obligations onto a practitioner or their services.
IMM led the work to have pharmacists included on the register, because recognition matters: it gives scheme participants a clear, regulated pathway to pharmacist expertise. But inclusion on an approval register answers the question "who may provide and bill for this service", not "which referral procedure applies". A pharmacist on the register conducting a medication review is still delivering a clause 4A(1)(zc) service, with the rules of row 22 attached.
How does this play out in CTP claims?
The same guidelines cover the motor accident scheme, and the same two-lane structure holds. At row 22 of Table 1, medication management and review services under the motor accident legislation attract Parts 1, 2 and 8, while independent medical examinations remain a separate service category with their own obligations under the Motor Accident Guidelines.
CTP adds one further distinction worth understanding. Section 7.52 of the Motor Accident Injuries Act 2017 restricts which health practitioners may give evidence on medical assessment matters, such as the degree of permanent impairment, in court and dispute resolution proceedings. That restriction governs medico-legal evidence. A pharmacy review is claims management advice: it helps an insurer understand medication use, cost, risk and prescriber behaviour on a claim, and it informs decisions rather than deciding disputed medical matters. On our reading, the section 7.52 evidence lane and the medication review lane are different lanes. Where a dispute requires formal evidence on a medical assessment matter, that is a separate pathway with its own rules, and insurers should take their own advice on it.
Key Takeaways
- SIRA classifies pharmacy reviews as medication management and review services under clause 4A(1)(zc), not as independent medical examinations under clause 4A(1)(za)(i).
- Rows 19 and 22 of Table 1 in the relevant services guidelines apply different parts to each service, and the IME conduct rules in Part 4 do not apply to medication reviews.
- IME procedures such as the 10 working day notice period and the choice of three providers attach to examinations, not to medication review referrals.
- The AHP register is a recognition and billing framework for treating practitioners; it does not turn a reviewing pharmacist into an independent medical examiner.
- In CTP, the evidence restriction in section 7.52 governs medico-legal evidence, which is a different lane from claims management advice.
- This page reflects IMM's reading of the framework as at 14/07/2026 and will be reviewed as the 2026 guideline changes take effect.
Frequently Asked Questions
Do insurers need to offer three providers for a medication review?
No. The choice of provider practice belongs to IME referrals. SIRA classifies a medication review as a medication management and review service, not an IME, so a case manager can refer directly to their chosen provider.
Is an independent pharmacy review an independent medical examination?
No. An IME is delivered by a medical examiner under clause 4A(1)(za)(i) and row 19 of Table 1 in SIRA's relevant services guidelines. A pharmacy review sits under clause 4A(1)(zc) at row 22, with different obligations attached.
Does the injured worker have to attend a pharmacy review?
No. There is no examination. The pharmacist works from the claim file, medication history and dispensing records, and speaks with the worker by phone only where counselling is part of the referral.
Does the 10 working day IME notice period apply to medication reviews?
No. The notice period in the Workers Compensation Guidelines attaches to independent medical examinations. A medication review can be arranged as soon as the referral is made.
This article sets out Independent Med Management's reading of the regulatory framework as at 14/07/2026. It is general regulatory interpretation, not legal advice, and insurers should seek their own advice on individual claims and disputes.
Primary source: State Insurance Regulatory Authority (SIRA), Guidelines for the Provision of Relevant Services (Health and Related Services), 2023.
