Australian Medical Association

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 AMA's submission to the Independent Hospital Pricing Authority on a pricing framework for public hospital services calls for hospital services to be funded on the basis of an 'effective' rather than an 'efficient' price. An effective price is one that provides sustainable and equitable access to high quality hospital services. The submission details the AMA's support for appropriate funding of post-hospital care; investment in teaching, training and research; and small and medium sized hospitals.

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 Chinese Medicine Board:

• asked for registration standards for Chinese medicine practitioners to be at least equal to those for pharmacists, osteopaths and chiropractors;
• opposed registration of practitioners who do not meet English language proficiency requirements; and
• opposed grandfathering of practitioners who do not hold recognised qualifications.

The AMA's submission to the Senate Finance and Public Administration Committee on the National Health Reform Amendment (Independent Hospital Pricing Authority) Bill 2011 highlights the importance of the Pricing Authority, the Australian Commission on Safety and Quality in Health Care, and the National Health Performance Authority collaborating on their roles and responsibilities, for example, on data collection requirements.

It also points out that the Pricing Authority should consider the standards set by the Performance Authority when calculating the national 'efficient' price, that is, it must take into account the performance that must be achieved. In addition, the National Health Reform Agreement allows states to pay hospitals less than the determined efficient price, therefore, we recommend that the actual payments made to hospitals are reported to Parliament so that it is clear when poor performance is linked to insufficient funding.

Overall the Bill before Parliament responds to the AMA's lobbying last year to ensure the Pricing Authority considers the range of variables affecting the actual costs of providing health care services when calculating the national efficient price. However we recommend that the Authority is explicitly required to ensure hospitals can fulfil their teaching and research obligations.

The AMA submission to the Department of Health and Ageing on the draft Performance and Accountability Framework which will be used by the National Health Performance Authority urges the Government to undertake a proper consultation process on the performance indicators proposed in the Framework beyond the State and Territory governments.

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.

Second Submission

The AMA submission to the Department of Health and Ageing position paper on the role and governance of Lead Clinician Groups released on 20 May 2011 emphasises that the Commonwealth Government's attempts to provide doctors with a meaningful role in how local hospitals are run has failed.

First Submission  - 17 February 2011

The AMA submission to the Department of Health and Ageing discussion paper on the role and governance of Lead Clinician Groups released on 25 January 2011 strongly opposes the limited role for doctors proposed. The AMA submission provides a model for Lead Clinician Groups that ensures doctors are involved in decisions made at the local hospital level about resource allocation, service planning and provision, and patient care.

The AMA has made an additional submission to the Department of Health and Ageing to raise concerns identified by AMA member junior doctors. This submission:

• emphasises the need to ensure that time-based targets do not impact on the ability of public hospitals to provide quality clinical education and training;
• calls for ongoing resources to support the ability of emergency departments, the hospital and community providers to fulfil education and training obligations; and
• recommends that the monitoring and evaluation of the impact of targets also includes the impact on education, training and junior doctor experiences.

This submission supplements the submission lodged by the AMA on 25 May 2011.

The AMA made a submission in response to the National Health Reform Amendment (National Health Performance Authority) Bill that was referred to the Senate Community Affairs Legislation Committee for inquiry in May 2011. The AMA has argued for amendments to empower the new Authority to report on, and impose penalties for, data manipulation and to address other issues of concern including adequate consultation with medical practitioners. The Authority will report on the performance of: local hospital networks; public hospitals; private hospitals; primary healthcare organisations; and other bodies or organisations that provide health care services.