CHF strongly supports measures that promote continuity of care for patients and helps general practices to better meet their needs and preferences. We have long been proponents of the patient and family-centred medical home model of care and for the necessarily policy changes required to support its implementation, including shifts such as voluntary enrolment and financing reform that would seem additional general payments introduced over and above fee for service arrangements. For this reason, we fully endorse the core features of high quality general practice articulated at pages 5 and 6 of the RACGP's White Paper and only suggest a few enhancements, particularly relating to patient activation, team-based care arrangements and the role that GPs can play to reduce fragmented care and improve system navigation.
CHF Response to the RACGP White Paper: Vision for general practice and a sustainable healthcare system
Response to the Draft National Action Plan for the Health of Children and Young People
Overall CHF supports the recommended priorities and actions and welcomes the commitment to further consultation with children, families and young people as implementation plans are developed and operationalised. We welcome ARACY’s proposed life course approach: it is important that the plan gives attention to both early childhood, adolescent and young adulthood health priorities. We note the recognition of CHF’s Youth Forum as a key platform for engagement.
One of our key concerns is that primary care and prevention have not been adequately addressed, despite existing data on childhood obesity and poor oral and dental health being referenced and despite the general practice and primary care being a key setting for intervention both planned and opportunistic. We know that these conditions are linked to poor health and social outcomes, and are overrepresented in the priority groups identified. As it stands, this is a major deficit in the Plan. CHF suggests an additional Priority Area – Access to primary care and prevention services – incorporating measures that address oral/dental health; prevention of childhood obesity; integrated models of care that benefit to children and young people such as patient and family centred health care homes; and support for young consumers to navigate and access the health system.
CHF Submission to the Tobacco Legislation Review
We are pleased to provide a submission supporting the continuation and strengthening of the Tobacco Control Regulations in Australia. Since the introduction of the Tobacco Control Regulations in the early 1990s, Australia has taken significant steps to reduce smoking and minimise the long-term health risks associated with tobacco. Prevention and cessation of smoking has been a remarkable public health achievement in Australia, which CHF believes is attributed to the regulatory and population based approach of the Tobacco Control Regulations. Despite the progress that has been made, 1 in 8 Australians still smoke daily, over 15,000 Australians die from tobacco-related causes each year, and an estimated 20% of the nation’s cancer deaths each year is caused by smoking. At a minimum, we recommend maintaining current regulations such as mandatory health warnings and would strongly encourage renewed efforts to stop and reduce tobacco smoking and for this review to ensure regulations and compliance processes are future-proofed.
MBS Taskforce Submissions
Response to the Report from the General Practice and Primary Care Clinical Committee: Phase 2
CHF supports the changes that the GPPCCC have been made in their Phase 2 Report and feel that their vision of the health system aligns closely with what we hear from members. We are pleased that our earlier comments have been taken on board but would like to see more detail around patient activation and the role of consumer leadership in the proposed changes to the MBS items. We believe that this element is essential to successful patient and family-centred primary health care in Australia. Beyond the scope of this Committee’s work, we would like to highlight the importance of strong change management to ensure recommendations align with consumer and sector expectations in the design, implementation and evaluation stages.
Response to the MBS Review Taskforce Diagnostic Medicine Clinical Committee
CHF supports the DMCC’s recommendations in principle in order to reduce inappropriate requesting of pathology and Diagnostic Imaging tests. In particular, we feel that Clinical Decision Support is a platform to make quality a focus of requests and an opportunity for consumer education (informed clinical and financial consent). Beyond the scope of the DMCC’s work, we urge the government to implement Clinical Decision Supports quickly and consider the additional support and funding that will help the success of this process.
Read the CHF Response to the MBS Review Taskforce Diagnostic Medicine Clinical Committee
Response to the Report from the Mental Health Reference Group
In March this year CHF undertook a consumer survey on mental health services to hear from people with lived experiences about how the current health service system works for them. In that survey we asked about people’s experience of care, from a system integration and patient centred perspective and asked for ideas about how it could be improved. We used the results of this survey to inform our submission to the Productivity Commission’s Inquiry into mental health services.
Read the CHF Response to the Report from the Mental Health Reference Group
Response to the Report from the Allied Health Reference Group
Thirty years following the creation of Medicare Benefits Scheme (MBS), a review is long overdue. CHF members believe that this review and a commitment to the regular evaluation of Medicare items is an essential to maintaining a world class health system and ensuring that funding is available for high value care. CHF supports most of the recommendations made by this Reference Group to position AHPs to take on a greater role in keeping Australians healthy. The Main Themes that the Group has outlined address the challenges that consumers face in accessing allied health services as part of an MBS funded plan or otherwise.
Read the CHF Response to the Report from the Allied Health Reference Group
CHF Response to the Report from the Nurse Practitioner Reference Group
CHF supports all the recommendations in the report. We agree with the conclusions in the Consumer Impact statement of the report, particularly around the importance of these measure in improving patient choice and access to primary health care that is ”timely, uncomplicated, culturally safe and affordable”. We believe that the package of measures, if fully implemented would achieve that and would do make a significant contribution to modernising our primary health care system.
Read the CHF Response to the Report from the Nurse Practitioner Reference Group
Consultation: proposal to introduce a Unique Device Identification (UDI) system for medical devices in Australia
CHF appreciates the opportunity to provide a comment to the Therapeutic Goods Administration (TGA) proposal to introduce a Unique Device Identification (UDI) system for medical devices in Australia.
At the heart of CHF’s policy agenda is patient-centred care. Our responses to the TGA’s consultation questions have been formed with a patient-centred approach in mind.
Response to Proposed Standard for Informed Financial Consent
Consumers Health Forum of Australia (CHF) appreciates the opportunity to provide feedback in response to the proposed Standard for Informed Financial Consent (the Standard), developed by the Cancer Council, Breast Cancer Network Australia, CanTeen and Prostate Cancer Foundation.
CHF support the development of a nationally consistent guide or standard for informed financial consent. We believe informed financial consent is a necessary component of informed consent and forms an important part of consumers’ decision-making process about proposed treatments. There are many benefits for improving informed financial consent including strengthening the ability of consumers to make informed choices about their health care options. Consultations previously undertaken by CHF only reinforces the importance of developing a nationally consistent standard for informed financial:
- Many consumers report being unsatisfied with their personal experiences of informed
financial consent when seeking and / or receiving care; and
- In general consumers reported that information financial consent involved the provision
of information about costs of their treatments before they accept it, in the form of
written, itemised quote outlining what costs are, and are not, covered.
Today, there continues to be a difference between what doctors and health professionals constitute informed financial consent and what consumers experience.
Submission to Remaking Therapeutic Goods Order No. 78 consultation
The CHF supports the reintroduction of pills into the scope of the remade Order. The omission of these from the current Order is an unfortunate regulatory oversight. Consumers implicitly trust the regulatory system to ensure any product made available to them undergoes rigorous assessment of quality, safety and efficacy. Currently that trust is being abused.
Submission to Potential reclassification of active medical devices for diagnosis and patient therapy consultation
We expect the primary impact of the reclassification for consumers will be a greater level of quality for Active Medical Devices in terms of reliability, safety and effectiveness. By putting these medical devices into a higher class they will undergo more rigorous assessment prior to becoming available to consumers, decreasing the risk to consumer health of the devices not functioning as intended.
The CHF acknowledges that there is potential for a delay in accessibility for critical medical devices should certain devices be reclassified into a higher Class. However we believe that it is crucial that any such critical devices be rigorously assessed for safety, efficacy and quality before being made available to ensure faulty or ineffective devices are not given to consumers. Additionally we believe the proposed transitional arrangements should give manufacturers and sponsors sufficient time to ensure their devices are assessed appropriately and are able to be made available to consumers when the new classification applies.
Submission to medical device cyber security consultation
At the heart of CHF’s policy agenda is patient-centred care. Our responses to the TGA’s consultation has been formed with a patient-centred approach in mind.
CHF notes that this consultation’s scope is limited to the regulatory guidance in line with existing regulatory requirements, and not changes to those regulatory requirements. However, as other consultations are currently open to change regulations for Software as a Medical Device (SaMD) it would be remiss for CHF to not include some forward-looking advice on out of scope but related matters.