Boston, MA — December 18, 2025 — An independent comparative research review released by the International Health Policy Observatory (IHPO) examines how wakefulness-promoting prescription medications are regulated and prescribed across three major healthcare systems: the United States, the United Kingdom, and Australia.
The analysis was conducted as part of an IHPO-led policy research initiative focused on evaluating regulatory frameworks, prescribing authorization standards, and oversight mechanisms governing alertness-regulating pharmaceutical agents used in the management of sleep-wake disorders.
Key Regulatory Differences Identified
According to the research, prescription practices vary significantly by region. In the United States, access is largely guided by physician discretion within federal scheduling rules. A summary of current U.S. prescribing pathways is outlined in this research overview of prescription practices in the United States.
In the United Kingdom, prescriptions are more centralized and typically aligned with National Health Service (NHS) protocols, often requiring specialist oversight. These procedures are described in an analysis of prescription authorization frameworks in the UK.
Australia follows a hybrid regulatory model, combining national drug scheduling with clinical documentation requirements under Therapeutic Goods Administration (TGA) standards. An outline of this structure is provided in an overview of prescription requirements in Australia.
Research Context
The review draws on regulatory guidance published between 2019 and 2025, along with aggregated observational data representing approximately 2,000 anonymized prescribing interactions. Researchers emphasized that the findings reflect regulatory and policy differences, not clinical effectiveness or treatment outcomes.
About the International Health Policy Observatory (IHPO)
The International Health Policy Observatory (IHPO) is an independent research initiative focused on comparative analysis of healthcare regulation, access frameworks, and policy trends across global health systems. The organization publishes illustrative research reviews to support evidence-based public and policy discussions.
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