Australian Medical Association

The Productivity Commission is conducting an inquiry into Caring for Older Australians.

The AMA submission to the inquiry is based on existing AMA policy and general themes discussed at a consultation convened by the AMA between the Productivity Commission and AMA member geriatricians, old age psychiatrists, general practitioners, and rehabilitation and palliative care specialists on 2 July 2010.

The AMA has provided comments to the Department of Health and Ageing on the Initial Assessment and Quality Framework Appraisal application forms and guidelines and made a submission to the Department's Medical Benefits Review Task Group regarding the MBS Quality Framework discussion paper released on 29 April 2010.

The submissions outline the concerns about the proposed processes for assessment of services for the MBS, and the administrative processes of the MBS Quality Framework.

The AMA has made a submission to the Senate Finance and Public Administration - References Committee Inquiry on the COAG National Health and Hospitals Network Agreement.

The submission outlines the AMA's views on the agreement and its potential impact on Australia's health care system.

The Commonwealth Government plans to introduce this Bill to make amendments to the legislation that underpins the Professional Services Review (PSR) scheme.

The Department of Health and Aging has recently met with the AMA to discuss and explain the current proposed amendments.

The AMA has made a submission to the Department of Health and Ageing on the exposure draft of the Bill.

The AMA is seeking members’ comments to inform and shape the direction of AMA submissions to the Government on the reviews of funding arrangements for diagnostic imaging and pathology services.

The AMA is supportive of evidence-based guidelines for the prevention and control of infection that are appropriate for the level of risk applicable to the various healthcare settings.

A national approach must be sufficiently flexible to accommodate the relative risks. The AMA is not in support of an approach where healthcare providers are required to implement infection control guidelines that are beyond the level of risk that occurs in a particular healthcare setting, are not practical to implement, and/or for which there is no evidence to justify adherence to the guideline.

The AMA supports the introduction of healthcare identifiers as an important e-health building block. The healthcare identifier will uniquely identify individuals and healthcare providers for the purposes of securely accessing and sharing health information.

The AMA has made one submission to the Senate Community Affairs Committee and three submissions to the Department of Health and Ageing on this issue.

AMA Submission to the Community Affairs Legislation Committee on the Healthcare Identifiers Bill 2010 and Healthcare Identifiers (Consequential Amendments) Bill 2010

The AMA considers healthcare identifiers are an essential building block towards the implementation of electronic health records, and we are therefore a strong supporter of their introduction. Healthcare identifiers will facilitate the secure access to, and appropriate sharing of, electronic patient information by healthcare providers.

We support the passage of the Healthcare Identifiers Bill 2010 and the Healthcare Identifiers (Consequential Amendments) Bill 2010.

The Medical Board of Australia, as part of incoming national registration arrangements, will be establishing a register of specialists. This register will include GPs.

The AMA has made a submission to the Medical Board of Australia recommending that when it formulates the criteria for inclusion on the new specialist register, it should put in place transitional arrangements to ensure that vocationally registered GPs are included on the register when it is first established. This would be in addition to Fellows of the relevant College.

On 16 November 2009, the AMA released its Priority Investment Plan for Australia's Health System.

The Plan sets out the initiatives that the AMA believes require immediate implementation to improve productivity in the health system, place a greater focus on people and their health needs, and improve the quality and safety of health care.

The AMA has re-endorsed the Plan for formal submission to the Government as the AMA’s 2010-11 Budget Submission.

The Plan includes a range of high priority initiatives focussing on key areas of the health system.

The Confederation of Postgraduate Medical Education Councils (CPMEC) has prepared a discussion paper on the structure and content of the internship - the year of supervised clinical training completed by graduates of an Australian Medical Council-accredited medical school.

The AMA Council of Doctors-in-Training has written to CPMEC and given broad support to the discussion paper’s recommendations as they align with the AMA’s position on the duration of the intern year, its core terms and the role of placements in community settings.

In November 2008 the Council of Australian Governments' agreed to introduce a nationally-consistent approach to activity-based funding for public hospital services to allow comparisons of efficiency across public hospitals.

Subsequently, the Australian Government asked the Productivity Commission to examine and report on the relative performance of the public and private hospital systems. In June 2009, the Productivity Commission released a paper seeking information and feedback on a range of issues including treatment costs, including out-of-pocket patient expenses and rates of fully-informed financial consent, rates of hospital-acquired infections and other relevant performance indicators.

Below are the two submissions the AMA made to the Productivity Commission on the Performance of public and private hospital systems. The AMA submissions also address the Commission's term of reference on informed financial consent.

Establishment of the Healthcare Identifier Service was agreed to by the Council of Australian Governments in 2006 as part of the national approach towards accelerating work on electronic health records to improve the safety of patients and improve efficiency for healthcare providers.

In July 2009, the Department of Health and Ageing released a discussion paper on legislative proposals to support the establishment and implementation of unique identifiers for healthcare purposes and the privacy of health information.

The AMA submission on the discussion paper is supported by the AMA Position Statement on Unique Healthcare Identifiers in 2008.

The AMA Joint submission highlights the real risk that the new scheme will erode the medical board’s ability to protect patient safety, and addresses four major concerns with the proposed registration arrangements:

1. There is no recognition or guarantee of the continued role of medical colleges in determining specialist qualifications for, and conferring them on, medical practitioners;
2. The scope of practice for the other health professions will be able to be expanded without any obligation for one health profession board to consult with other boards, particularly the medical profession board;
3. The scheme seeks to introduce new onerous continuing competence/CPD requirements, which will effectively create a new scheme for the medical profession, and does not recognise the role of the colleges in continuing competence and professional development for the medical profession;
4. The medical board will be able to register a person who does not meet the requirements for registration in certain circumstances.

The consortium of eleven graduate medical schools is seeking the ACCC’s permission to continue its policies and practices for selecting applicants to graduate medical schools. These include the preference policy where applicants submit a single application to the Graduate Australian Medical Schools Admission Centre, and the one interview policy whereby applicants receive only one offer for an interview.

In its submission the AMA has said that, on balance, the public benefits from authorising the graduate medical school consortium to continue these polices and practices outweighs any potential drawbacks;  however, the AMA has noted that where a graduate medical school uses the interview process to look for certain qualities in an applicant, there is the potential for the applicant to be disadvantaged by the interview process in some circumstances. The AMA has encouraged the ACCC to address these issues in the authorisation process.

AMA response to nurse practitioner and midwife legislation that the Government announced in the 2009/10 Federal Budget.

In the 2009/10 Federal Budget, the Government announced that it would move to allow some nurse practitioners and midwives to provide services funded under the Commonwealth Medicare Benefits Schedule (MBS) and to prescribe medications that are subsidised under the Pharmaceutical Benefits Scheme (PBS).  It also announced that the Commonwealth would subsidise indemnity insurance for midwives, although it decided not to extend this cover to home births.

The Government recently introduced three Bills into the Parliament to implement its Budget announcements. These are the Health Legislation Amendment (Midwives and Nurse Practitioners) Bill 2009, the Midwife Professional Indemnity (Commonwealth Contribution) Scheme Bill 2009 and the Midwife Professional Indemnity (Run-off Cover Support Payment) Bill 2009.

These Bills have been referred to a Senate Community Affairs Legislation Committee Inquiry and the AMA has provided a detailed submission to this Inquiry. The AMA submission highlights that, if implemented carefully, the legislation may help address unmet community health needs - provided it is done in a coordinated way and medical practitioners are still involved in the overall care of the patient. The AMA has warned the Committee that if the legislation is not implemented carefully, it will fragment care, increase the risks of inadvertent patient outcomes, cause duplication and increase costs.

The AMA submission outlines detailed recommendations designed to ensure that the ultimate arrangements work in practice and patient safety is safeguarded.

 

The AMA has also made a Joint Submission on the exposure draft to the Project Implementation Team.

This submission notes that the Ministerial Council has forfeited the power to approve accreditation standards, but has retained a power to give the national board policy directions on accreditation standards. The submission calls for additional provisions to be added to the legislation that:

• Defines the circumstances when the Ministerial Council can issue policy directions on accreditation standards; and
• Provides mechanisms for transparency and accountability of these directions.

The submission also outlines a range of other important functional operational and administrative issues with the scheme that need to be clarified and reflected, where necessary, in revisions to the Bill.

The AMA submission to the Senate Community Affairs Committee inquiry into the Health Insurance Amendment (Extended Medicare Safety Net) Bill 2009 highlighted:

• the Bill provides a framework for the Government to systematically withdraw its funding of the Extended Medicare Safety Net (EMSN);
• the shortcomings of the Centre for Health Economics Research and Evaluation Extended Medicare safety net review report 2009 upon which the Government’s decisions to cap certain services were based;
• the absence of Government consultation with the medical profession to determine the real impact on patients.

The AMA called for the Bill to be amended to include the following requirements:

• that the Minister be required to consult with the relevant medical groups about their fee structures and any proposal to introduce and/or change a EMSN cap before making future determinations to impose EMSN caps on particular medical services;
• that the Government be required to commission an independent evaluation of the impact of this measure and the associated determination containing the 2009-10 Budget caps by 1 January 2012, and for the evaluation to be tabled in Parliament as soon as it is completed.

The Federal Parliament's Senate Community Affairs Committee is conducting an Inquiry into the Health Workforce Australia Bill 2009 (the "Bill"). The Commonwealth agreed to establish a new health workforce agency at the November 2008 Council of Australian Governments (COAG) meeting and this Bill seeks to implement that commitment.

The AMA has provided a submission to the Senate Inquiry.

The AMA has made a submission to the Department of Health and Ageing in response to the report released by DoHA on the outcomes of the Point of Care Testing (PoCT) trial in general practice.

The Australian Medical Council (AMC) is developing a national code of professional conduct for doctors entitled Good Medical Practice: A Code of Conduct for Doctors in Australia (previously entitled Good Medical Practice: A Draft Code of Professional Conduct). The Code is intended to supersede existing State and Territory medical board professional conduct codes. The AMC intends to recommend that it be adopted by the new national medical board. The AMC's Final Consultation Draft of April 2009 reflects the feedback they received in response to the previous public consultation draft of August 2008.

The AMA's submission is attached.

Whilst the AMA considers the Final Consultation Draft to be a major improvement on the earlier version, the AMA has highlighted a few sections that require further amendment, including the sections on conscientious objection and on conflicts of interest. The AMA has also emphasised the need for the release of the Code to be accompanied by relevant public and profession based education campaigns and to be subject to a regular 3-5 year review cycle.

The AMA Submission to the Senate Community Affairs Committee inquiry into the national registration and accreditation scheme encapuslates the major concerns set out in our previous submissions to government on the proposed scheme.  The submission also sets out the AMA's proposal for a simple, cost effective alternative arrangement for a national system for medical practitioner registration that:

1. maintains the nationally consistent accreditation of medical education and training through an independent medical accreditation body with specific medical expertise;
2. implements mutual recognition of registration arrangements for medical practitioners across all states and create a ‘virtual’ national register; and
3. establishes a formal process for ongoing harmonisation of registration standards.

 

The Increased MBS Compliance Audits Initiative announced in the 2008-09 Federal Budget contains measures to further protect the integrity of Medicare by:

•    increasing the number of audits conducted from 500 to 2,500 per year (at a cost of $76.9m);
•    expanding the audit program to allied health providers and to better cover specialists;
•    accessing medical records to administratively verify Medicare billing; and
•    introducing additional financial penalties for incorrect billing for incorrect claims exceeding $2,500.

The AMA submission to the inquiry highlights the AMA's fundamental concerns about how the government’s proposal will compromise the central ethic in medical practice which preserves the privacy of the doctor-patient relationship. The submission also raises concerns about the unnecessary additional red tape burden that the audits and the requirement to produce information impose on doctors.  It highlights the lack of procedural fairness in the application of the proposed financial penalty regime

The AMA provided feedback on the National Health and Hospital Reform Commission’s interim report in April 2009

The feedback is set out in the table below. The AMA President also attended a one-on-one briefing session with the Chair of the Commission in April 2009 to more fully outline the AMA's views on the Commission's interim report.