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Submissions to government

Submissions to government

RACGP submissions

The RACGP continues to play a pivotal role in advocating on behalf of its members on a range of issues and reforms affecting general practice and the delivery of high-quality and safe patient care.

Relying on the expertise of our specialist membership base, we represent the GP voice by contributing to government and stakeholder consultations and releasing evidence-based position statements and reports.

We also continue to participate in varied government and stakeholder expert and advisory committees and reference groups, and regularly meet with federal and state health ministers, their advisers, federal and state health departments and a range of other key stakeholders.

This vital advocacy work is supported by the RACGP Board, RACGP expert committees, state and national faculty councils and appointed Fellow representatives.

The RACGP has made over 200 submissions to governments and other key stakeholders and continues to promote its public awareness campaign to increase community awareness and understanding of the profession and the crucial role GPs play.

Title 

Submission to the Joint Select Committee on Constitutional Recognition relating to Aboriginal and Torres Strait Islander peoples 2018

Date

11 July 2018

About

The RACGP provided a submission to the Joint Select Committee on Constitutional Recognition, as a long-time supporter of constitutional recognition, to raise issues related to the Close the Gap campaign and in support of Aboriginal and Torres Strait Islander leadership.

Outcome

RACGP endorsed the Uluru Statement from the Heart.

Title 

Submission and witness evidence to the Royal Commission into Aged Care Quality and Safety

Date

February 2019 – ongoing

About

The RACGP was invited by the Royal Commission into Aged Care Quality and Safety to give evidence at hearings held in February 2019. The RACGP was also asked to prepare a statement in advance of the hearings.

Outcome

RACGP President, Dr Harry Nespolon, provided evidence at the hearing on 18 February 2019 in Adelaide. Hearings are currently ongoing, and the RACGP will continue to advocate on the role of general practice and GPs in the care of residents in residential aged care facilities.


Title 

Changes to Medicare Benefits Schedule (MBS) items for GP attendances in residential aged care

Date 

1 March 2019

About 

The RACGP has undertaken significant analysis and advocacy to address changes to MBS items for GP professional attendances at residential aged care facilities. The changes, implemented on 1 March 2019, result in a loss of approximately $12 million in essential funding for the sector.

Outcome 

The RACGP is continuing its advocacy to the government to ensure that the new rebates do not result in a loss of funding for GPs and their patients in residential aged care facilities.


Title

Retention of the Practice Incentives Program General Practitioner Aged Care Access Incentive

Date

2 April 2019

About

In the 2016–17 federal Budget it was announced that several existing Practice Incentives Program (PIP) payments, including the General Practitioner (GP) Aged Care Access Incentive, would be rolled into the new Quality Improvement Incentive. Since this announcement, the RACGP successfully advocated for the retention of the procedural and Indigenous incentives. The RACGP has been continuing to advocate for the retention of the GP Aged Care Access Incentive due to it providing significant and essential support to GPs and their patients in residential aged care facilities.

Outcome

In the 2019–20 federal Budget, the government announced that it will retain the PIP Aged Care Access Incentive instead of rolling it into the Quality Improvement Incentive as planned.

Title

My Health Record

Date  

14 September 2018

About 

My Health Record is Australia’s national electronic health record. In the 2017–18 federal Budget, the Australian Government announced that every person known to Medicare or the Department of Veterans’ Affairs who has not already registered for a My Health Record will automatically have a record created for them unless they choose to opt out. The opt-out model raised concerns for consumer privacy and security within the system. The RACGP advocated for strengthening of My Health Record legislation to address these concerns through ongoing communications with the Minister for Health and a submission to the Senate Community Affairs References Committee inquiry in the My Health Record system.

Outcome 

My Health Record legislation was amended to improve consumer and clinician confidence. Changes included:

  • an extension to the opt-out period to ensure consumers were aware of the changes
  • increased funding for further consumer awareness
  • changes to s. 70 of the My Health Records Act 2012, requiring a court order for the release of any identifiable information from an individual’s My Health Record
  • permanent deletion of health information stored by the system operator where an individual cancels their registration with My Health Record
  • increased penalties for unauthorised access of a consumer’s record
  • removal of default parental/guardian access to a minor’s My Health Record from the age of 14 years.

Title 

National Primary Health Care Data Asset

Date

28 June 2019

About

The Australian Institute of Health and Welfare (AIHW) received funding in the May 2018 federal Budget to develop an enduring National Primary Health Care Data Asset. The RACGP made a submission to the consultation advocating for strong general practice representation in the development and implementation of the data asset and outlined recommendations and concerns.

Outcome

The RACGP continues to advocate for the appropriate use of data generated by general practice.

 

Title

Submission to the Productivity Commission Inquiry into Mental Health

Date 

10 April 2019

About 

The Australian Government released the terms of reference and an issues paper for the Productivity Commission’s Inquiry into Mental Health. The RACGP submission highlighted the important role of general practice and GPs in mental health care, and examined ways in which supporting general practice for the prevention, diagnosis and management of issues related to mental health can provide significant cost effectiveness.

Outcome

The Productivity Commission is drafting a report in response to this inquiry, with a final report to the government scheduled for 23 May 2020.


Title 

Response to the Australian Mental Health Outcomes and Classification Network on National mental health and suicide prevention information priorities, 3rd edition

Date

15 May 2019

About

The third edition of National mental health and suicide prevention information priorities from the Mental Health Information Strategy Standing Committee provides strategic priorities for information development in Australian Government–funded mental health care and support services over the next decade. Revising these priorities is an action of the Fifth National Mental Health and Suicide Prevention Plan. The RACGP’s response covered the important role of GPs in mental health care and recommendations on data to be collected.

Outcome 

Currently awaiting update. This submission can be further used to advocate for the role on GPs in mental health care.


Title

Advocating for a new MBS item number to support GPs and their patients for 40 minutes or more

Date

Throughout 2018–19

About

In both its election statement and its pre-budget submission, the RACGP called for a new MBS item to support general practice mental health consultations for 40 minutes or more for GPs to discuss mental health with their patients.

Outcome

The RACGP is continuing discussions with the Minister for Health regarding the introduction of the new MBS item number.

Title 

Advocating for better approaches to Medicare compliance – Opioid prescribing

Date 

Throughout 2018–19

About

The RACGP raised concerns on behalf of members in relation to the Department of Health’s compliance campaign targeting opioid prescribing, specifically in regard to GPs who received letters warning them about their high level of opioid prescribing despite working with a population of patients where the prescribing levels would be considered appropriate (eg in palliative care).

Outcome 

The Department of Health and the Chief Medical Advisor have since publically acknowledged the stress caused by the campaign and noted that the campaign did target compliant GPs. The Chief Medical Advisor has emphasised that GPs working with patients in palliative care should be supported to continue to prescribe appropriate opioids as required.

Title

Submissions to the MBS Review Taskforce committees and reference groups

Date

Throughout 2018–19

About

The RACGP made submissions to more than 20 committees and reference groups of the MBS Review Taskforce this financial year, most notably to the General Practice and Primary Care Clinical Committee, the Mental Health Reference Group, and the Nurse Practitioners Reference Group.

Outcome

The Chair of the MBS Review Taskforce, Professor Bruce Robinson, has engaged closely with the RACGP regarding its responses to the review, arranging several meetings to discuss submissions in more detail. Many recommendations made in the RACGP’s responses have been welcomed formally in MBS Review Taskforce final reports or informally in discussions with Professor Robinson.

The MBS Review Taskforce has also recognised the RACGP’s advocacy efforts of previous years. For example, the RACGP recently provided a submission to the Specialist and Consultant Physician Clinical Committee, which had recommended introducing time-tiered attendances for non-GP specialists. This recommendation echoed ongoing RACGP advocacy calling for time-tiered attendances for non-GP specialists to help address current value disparities between professions within the MBS, and resolve issues GPs experience with non-GP specialists’ dishonouring of referral validity.

Title

Submission to the Therapeutic Goods Administration on ‘Proposed Criteria for Appendix M of the Poisons Standard to support rescheduling of substances from Schedule 4 (Prescription only) to Schedule 3 (Pharmacist only)’

Date

10 April 2019

About

The Therapeutic Goods Administration (TGA) proposed a framework for the use of Appendix M of the Poisons Standard. Appendix M is intended to include substances that have formerly been scheduled as Schedule 4 and have required a prescription by a medical practitioner, but if rescheduled to Schedule 3 could be dispensed by a pharmacist with specific controls in place that help ensure appropriate use.

The RACGP emphasises that it is critical to ensure that consumers are not harmed by the resulting fragmentation of care that is likely to arise through this proposed down-scheduling – including conflicts of interest that may arise when pharmacies both advise and supply medicines – and that there is strong pharmaceutical industry influence within pharmacies. The RACGP has strongly recommended that the TGA reconsider a number of its proposed criteria.

Outcome

According to the TGA, a final framework for Appendix M will be developed based on feedback received and agreed upon with key stakeholders. Guidance for applicants will be updated accordingly on the TGA website and any identified changes to process implemented by mid-2019. There has been no update as yet.


Title

Submission to Pharmacy Board of Australia regarding pharmacy prescribing

Date

15 April 2019

About

The RACGP made a submission to the Pharmacy Board of Australia opposing the three pharmacy prescribing models put forward for stakeholder consideration, noting that none of the models proposed are appropriate in primary care.

Outcome

The Pharmacy Board of Australia is yet to comment on the submission. The submission is being used by the RACGP to continue advocacy regarding the inappropriateness of expanding pharmacy prescribing in primary care in Australia.


Title 

Submission to the Nursing and Midwifery Board of Australia regarding nurses prescribing in partnership

Date 

21 September 2018

About 

As part of its advocacy against non-medical prescribing, the RACGP submitted to the Nursing and Midwifery Board of Australia opposing its model for nurses prescribing in partnership, which could result in nurses prescribing with no GP oversight.

Outcome 

The RACGP has since been invited to attend further discussions on the proposed prescribing model. The RACGP continues to advocate against the model and more generally against increased prescribing rights for non-medical prescribers where there is no link to a patient’s GP.

Title

Position statements on the topic of pharmacy

Date

April 2019

About

The RACGP released two position statements on the topic of pharmacy, one identifying issues with the retail model of pharmacy and the other supporting the trial of general practice-based pharmacist models in Australia.

Outcome

The position statements have provided a strong foundation for RACGP members to continue to advocate against provision of medical services in the retail pharmacy setting, or in support of alternative models of pharmacy that promote high-quality patient care.

Title

Obesity prevention and management position statement

Date

February 2019

About

The RACGP developed a position statement to highlight the significant role of GPs in the prevention and management of obesity. The statement strengthened calls from the RACGP for increased government support of evidence-based services and treatment to tackle this significant health issue.

Outcome

Following the launch of the position statement, the RACGP was invited to present at the Department of Health’s National Obesity Summit in Canberra in February 2019.

Submissions to government
Pre-budget submission
Aboriginal health