Australian Medical Association

The AMA submission on the exposure draft of the Personally Controlled Electronic Health Records Bill 2011 highlights that the safety objects of the legislation will be undermined by the opt-in design of the system and the ability of patients to to effectively remove clinical documents from their PCEHR. The submission also makes several suggestions to improve the transparency of the governance arrangements for the PCEHR and to clarify the operation of the civil penalty provisions.

The AMA submission to the Department of Health and Ageing on the Personally Controlled Electronic Health Record System: Legislation Issues Paper should be read in conjunction with the concerns expressed in our submission on the PCEHR Draft Concept of Operations.

The AMA submission on the proposed PCEHR expresses concerns that the proposed form of the PCEHR will provide only limited safety benefits and these are significantly outweighed by its inherent clinical and medico-legal risks for medical practitioners and the administrative burden it will impose on medical practices.

Pathology services in Australia are amongst the highest quality and the most accessible in the world. However, Government funding cuts to pathology services have had an impact on the quality, accessibility, affordability and safety of pathology services. Government funding changes can also have a significant impact on the sustainability of the pathology sector including the ability to support ongoing training, research and development.

The AMA supports the development of an electronic system to record and monitor controlled drugs that can be used to help address abuse and misuse of schedule 8 drugs. A project to develop an electronic system is being funded as one of several programs under the Fifth Pharmacy Agreement. The AMA has made a submission to the Department of Health and Ageing in response to a consultation paper released as part of the development phase of the project. The submission notes that any system designed for medical practitioners must be simple, easy to operate and avoid duplication of effort.

The AMA submission on Medicare funding for online consultations calls for funding not to be limited to video consultations only, but include telephone calls, emails and other non-video online consultations that are necessary for providing care to patients who are remote to the specialist caring for them.  The submission also says that the MBS items should be drafted broadly to enable treating doctors to use their clinical judgment to determine when an online consultation is clinically relevant for their patient and the clinically appropriate technology to use to provide the service.

The AMA Council of Doctors-in-Training has made a submission to the National e-Health Transition Authority on electronic discharge summaries. The paper examines, from the junior medical officer perspective, impediments to creating high-quality discharge summaries and presents solutions to the barriers identified.

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.

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.