AMA Submission on the Exposure Draft Subordinate Legislation Private Health Insurance (Reforms) Amendment Rules 2018

30 Aug 2018

The AMA has provided a submission to the Commonwealth Department of Health on the exposure draft of the Private Health Insurance (Reforms) Amendment Rules 2018 (the Rules). The Rules will give effect to the private health insurance reform legislation and provide the detailed framework for the private health insurance reforms announced by the Minister in 2017.

The proposed Rules contain some positives initiatives that the AMA welcomes:

  • That the Rules bring clarity about what medical conditions are covered in each tier of benefits;
  • That the Rules provide full mandatory cover for the medical conditions in each tier; partial cover is not permitted (except in Basic cover and for Psychiatry, Rehabilitation, and Palliative Care – except in Gold cover where there are no exclusions);
  • The inclusion of gynaecology, breast surgery, cancer treatment, and breast reconstruction in bronze tier products;
  • The use of standard clinical categories across all private health policies;
  • That a clinical category covers the entire episode of hospital care for the investigation or treatment; and
  • That an episode of hospital treatment covers the miscellaneous services allied to the primary service.

The AMA believes these steps will go a long way to making private health insurance a simpler and fairer system.

However, the AMA is deeply disappointed that after two years of hard work the Government allowed less than three weeks to look at the details of this new system. Additionally, the AMA was unable to find any evidence of demonstrated consultation with the Medicare Benefits Schedule Review Taskforce in order to transfer this knowledge into the private health insurance clinical definitions design. Adequate time and good modelling are critical to ensure that usual clinical pathways have been adequately addressed in the reforms and that essential elements for a condition have not been overlooked. The AMA believes the consultation on the Rules has been entirely inadequate and has significantly increased the risk of failures in the new system. 

Click on the link below to access the full submission.