It’s often been said, the Australian My Health Record is not a finished project. It is evolving and has, indeed, lots of potential to improve and streamline patient care. Sadly, the privacy issues that have haunted the project for years still seem to be unresolved. And when it comes to secondary use of patient data, there’s more to come from a different direction.
Back in 2013 I wrote this in a blog post about the My Health Record, then called the Personally Controlled Electronic Health Record or PCEHR:
“The PCEHR Act 2012 states that the data in the PCEHR can be used for law enforcement purposes, indemnity insurance purposes for health care providers, research, public health purposes and ‘other purposes authorised by law’. This is far from reassuring. There are many grey areas and unanswered questions. There are too many agendas. The PCEHR should first be a useful clinical tool to improve patient care.”
Five years later and there are still ambiguities about when, how and for what reason law enforcement agencies and other non-medical parties can access the national My Health Record system. This should have been crystal clear by now. Here’s is what I posted in 2015:
“(…) at the moment the information in the PCEHR may be used by the Government for data mining, law enforcement purposes and ‘other purposes authorised by law’, for up to 130 years, even after a patient or provider has opted out. (…) The legal framework should be reviewed, and any changes must be agreed upon by consumers and clinicians.”
When asked about this issue at yesterday’s Press Club AMA president Dr Tony Bartone indicated that he is prepared to push for legislative amendments to improve the confidence of Australians in the My Health Record.
I was glad to hear this. I’m all for amendments of the My Health Record legislation but at the same time the Department of Health is on a journey to get its hands on GP patient data – and this is unlikely to change.
For example, the Department of Health is preparing a new data extraction scheme, to be introduced in May 2019. To remain eligible for practice incentive payments GP clinics have to agree that de-identified patient data will be extracted from their clinical software by, perhaps, Primary Health Networks. From there the data may flow to, possibly, the Australian Institute of Health and Welfare, the organisation responsible for the secondary use of data in the My Health Record.
If this scheme goes ahead, government organisations will begin to take over data and quality control of general practice. The argument will be that it is in the interest of the health of the nation. Perhaps it’s my well-worn tin foil hat, but I have a sneaking suspicion what I will be blogging about in the years to come.
Patriotism is supporting your country all the time, and your government when it deserves it ~ Mark Twain.
Although federal health bureaucrats seem to think bulk billing rates will increase, about 30% of GPs say they will stop all bulk billing soon. In a previous post I explained why. As a result of government policy to freeze patient Medicare rebates, doctors are faced with three options. They can:
Some will choose option 1, because they don’t want to or cannot charge their patients more, and are also unable to work more. The reality is however that most GPs will not be able to afford this option.
Others will go for option 2: they may, for example, see 7-8 patients per hour instead of 4-5. They may decide to work more days and longer hours. The question is of course: how safe is this?
Can doctors continue to offer good care when they are churning through high patient numbers? It will certainly feed the epidemic of burnout, depression and suicide among doctors and medical students.
What the Medicare rebate freeze is all about
Medicare is shaping up to be a major election topic. Still, the freeze on the patient Medicare rebate is a complex topic for many. It was a lot easier to understand when Medicare was called the Health Insurance Commission, but the principle is still the same: Medicare pays a contribution towards the doctor’s fee on behalf of the patient. Many GPs have accepted this contribution as a full payment, which is called bulk billing.
The ‘indexation freeze’ everybody is talking about means that this Medicare contribution will not be increased annually, in line with the increasing cost of living. The shortfall will have to be made up by patients which means that the out-of-pocket expenses will go up as doctors stop bulk billing. The freeze on the patient Medicare rebate was introduced by the Labour government in 2013, and will continue under a Coalition government until 2020 and possible longer. The rebate has not kept up with costs and inflation for a much longer period.
Then there is option 3: doctors will charge more, which will increase out-of-pocket costs for patients. As RACGP president Dr Frank Jones mentioned in this interview, we may see a 3-tier system in Australia soon:
“Dr Jones warned poorest patients would feel the impact of the freeze hardest, while there was a risk doctors would churn through appointments more quickly.
He predicted it would lead to a three-tier billing system: doctors would bulk bill their most disadvantaged patients, charge other health care cardholders a concessional rate, and private patients would be charged the Australian Medical Association’s recommended fee.”
In 2015 the RACGP surveyed GPs on how they planned to manage the patient rebate freeze. Of the 566 members who responded, the majority (57%) said they would have to increase out-of-pocket costs for patients.
GPs said they would have to do this either because the practice would stop bulk billing and begin charging a gap or co-payment (30%), or the practice would increase out-of-pocket costs for non-concessional cardholders (27%). Only 8% indicated that they would not increase out-of- pocket costs for their patients.
How fees will go up
It is to be expected that many practices will start cost-cutting: staff levels may be minimised and investments in new equipment, training & education, IT or buildings may become a lower priority. This is a risk for the quality of care.
Practices will determine a fair and equitable fee based on their increasing practice costs, professional time and services. The RACGP and AMA support GPs to set fees that accurately reflect the value of the services they offer, such as the recommended fees in the Australian Medical Association’s List of Medical Services and Fees.
Practices will review their patient demographics and billing profile and optimise the utilisation of MBS items. Pensioners and/or health care card holders may be charged an extra fee which will be much higher than the bulk billing incentive of $9.25.
Practices may decide that certain services will attract fees, for example dressings and other consumables, treating doctor’s reports, off-work/off-school certificates, phone/video consultations, data entry or certain surgical procedures.
Updating practice management software to streamline Medicare claims and EFTPOS payments may be required in some cases. Expect notices to go up in surgeries across the country to tell patients about the changes in billing policies. Unfortunately there will also be some practices that will have to close their doors.
Australian doctors are kept on a short leash. I recently renewed my registration with the Australian Health Practitioner Regulation Agency (AHPRA). This annual ritual is always interesting.
Like thousands of other doctors, I first had to fill out an online questionnaire. As usual, AHPRA wanted to know if I had a physical or mental impairment, disability, condition or disorder – including substance abuse or dependence – that would detrimentally affect my capacity to work as a doctor. I was reminded that I’m required by law to declare any impairments.
There were questions about criminal records, compliance with the law, continuous professional development, indemnity insurance, work history and immigration status. I was advised that if I did not give the required information, I could lose my registration.
Finally I dutifully transferred the required $724 into AHPRA’s bank account.
High professional standards
The yearly AHPRA registration procedure symbolises the way doctors are controlled in Australia. Contrary to common belief, doctors allowed little freedom.
Before doctors can prescribe certain medications, they have to call Medicare to get approval. Prescribing habits are monitored. Doctors are audited randomly to make sure billing practices are not out of line with peers. They may be prosecuted if there is a deviation from the average. In most states, doctors have to report colleagues who are not performing optimally.
At the same time, professional medical standards in Australia are high. Take the accreditation standards of the Royal Australian College of General Practitioners, or the CPD requirements. Both quality assurance programs have become more robust over the years and are continuously being reviewed and improved by the College.
QI&CPD programs recognise ongoing education to improve the quality of everyday clinical practice by promoting the development and maintenance of medical skills and lifelong learning.
Is there a problem?
Why is there still talk about revalidation of doctors? Is the public concerned about the quality of Australian doctors?
The national AMA patient survey indicated that GPs are considered by the public to be trustworthy, knowledgeable and experienced. A large patient satisfaction survey endorsed by the RACGP found there was a very high level of satisfaction with General Practice in Australia.
Another study published in the MJA also showed that patients reported high levels of satisfaction with GP care, and for many years Australian doctors have been in the top three most trusted professions in the annual Roy Morgan research.
Based on numbers from Canada, AHPRA estimates that 1.5 per cent of Australian medical practitioners are performing ‘unsatisfactorily’. I’m not sure Canadian figures can be applied to Australia, but 1.5 per cent of unsatisfactory performers in any group is low. It appears that any potential problem lies with a significantly small minority of doctors.
Carpet-bombing the profession
There are many revalidation models – from strengthening CPD to targeting those at high risk of complaints, to the full- bore version rolled out in the UK. But if the AHPRA tries to identify substandard doctors, carpet-bombing the whole profession is problematic.
Dr Steve Wilson, Chair of the AMA (WA) Council of General Practice, questioned in Medicus magazine whether revalidation would address those who failed to practise to agreed levels. And if it did, he asked, would that be a sign of impairment or does it reflect personal style, or lack of time, training, experience or adequate remuneration?
Competency checks of doctors may sound appealing to the public. I’m sure some politicians will love the rhetoric. But simply copying the UK’s revalidation system would be a mistake.
About 5,000 doctors a year are considering leaving the UK, and many come to Australia. Bureaucracy is one reason they emigrate. The last thing we need in Australia is more regulation, red tape and stressed-out doctors.
Existing quality systems
In recent years, our healthcare system has seen several unsuccessful concepts not supported by evidence. Think for example about the super clinics program and some of the accompanying cost blowouts, delays and disappointing results.
It will be easier and cheaper to build on existing quality assurance systems.
This article has previously been published in Medicus, the AMA(WA) magazine.
The Medical Board of Australia could be about to make a costly mistake. Regular testing of competency being introduced is not a matter of if, but when, said the new boss of the NSW Medical Council, Dr Greg Kesby, in an interview with Australian Doctor magazine.Dr Kesby also said there needed to be a process to instil confidence within the community that all doctors’ knowledge was up-to-date.
On the face of it, competency checks of doctors sounds appealing. I’m sure some politicians will love the rhetoric. But at the same time, alarm bells were going off when I read the interview.
Does Dr Kesby imply that the Australian public has lost confidence in its health practitioners? Are there concerns about the quality of Australian healthcare? There are many other unanswered questions too.
Is there any evidence that the current quality assurance systems, such as accreditation and CPD, are insufficient? Is recertification or revalidation — such as has been implemented in the UK — an efficient way to improve the quality of healthcare? Is it possible to design a system that reliably differentiates between good and bad practitioners? And how do we define competency?
Based on numbers from Canada, AHPRA estimates that 1.5% of Australian medical practitioners are performing ‘unsatisfactorily’. I’m not sure Canadian figures can be applied to Australia, but 1.5% of unsatisfactory performers in any group is low. There are numerous models: from strengthening CPD to targeting those at high risk of complaints, to the full-bore version rolled out in the UK. But if the board tries to identify these substandard doctors, carpet-bombing the whole profession is problematic.
One thing is for sure: UK-style revalidation is expensive. The process takes 1-2 working days per practitioner. Imagine thousands of Australian doctors having to take a couple of days off work to fulfil revalidation requirements.
Imagine the enormous effort it will take to manage this process. Think about the additional cost of the training, time and wages of the appraisers — who, I assume, will be doctors too — and the admin staff, extra regulation, log books, documents, IT etc.
According to the UK’s Pulse magazine, the revalidation of doctors has become a colossal enterprise, costing taxpayers £97 million (about $207 million) a year. This figure does not include revalidation of other health practitioners. Critics of the UK system have said it will not detect poor doctors, as its main purpose is to gain patients’ trust. Others feel it mainly serves to demonstrate what good practice looks like.
Policing the profession
A former UK GP-appraiser, now working in Australia, mentioned on the GPs Down Under Facebook group that appraisals used to be fun, interesting and mainly pastoral. Under revalidation, they became a form of policing the profession, he said.
Professor Kerry Breen, adjunct professor in the department of forensic medicine at Monash University, wrote in the Medical Journal of Australia last year that there was little evidence to support the idea of transposing the UK system to Australia.
He said that despite some local failures of medical regulation and hospital governance, the community had not lost faith either in its doctors or regulatory system. Indeed, it appears the public is largely content with its healthcare practitioners: Australian doctors, nurses and pharmacists have been in the top three most trusted professions for many years in the annual Roy Morgan research.
More recently, Dr Steve Wilson, an AMA WA representative, questioned in the AMA’s magazine whether revalidation would be able to address those who failed to practise to agreed levels. And if it did, he asked, would that be a sign of impairment or does it reflect personal style, or a lack of time, training, experience or adequate remuneration?
Don’t follow the UK
About 5000 doctors a year are considering leaving the UK, and many come to Australia. Bureaucracy is one reason they emigrate. Simply copying the UK’s revalidation system would be a big mistake. The last thing we need in Australia is more regulation, red tape and stressed-out doctors.
In recent years, our healthcare system has seen enough unsuccessful concepts not supported by evidence. Think about the super clinics program or the PCEHR, and the accompanying cost blowouts, delays and disappointing results.
It will be easier and cheaper to build on existing quality assurance systems.
Let’s look, for example, at refining CPD and accreditation. As they say, the main difference between a wise man and a fool is that a fool’s mistakes never teach him anything.
Developing an expensive new system with little or no supportive evidence failed in the case of super clinics and e-health, and it will fail with revalidation too.
This article was originally published in Australian Doctor Magazine.
When I tweeted about the Medicare freeze last week, someone asked “Care to explain other than meaning you get less money?”
I thought it was a really good question as it highlights the complexity of the issue. Most people seem to think that it’s all about doctors’ income – but it isn’t. The Medicare rebate is also about the money patients get back from Medicare.
As we speak, around Australia GP practices are adjusting their fees as a result of the government policy. Our practice increased the fee of a basic consultation with five dollars for people without a concession card. Other practices have decided to charge a once-off $30 payment to previously bulkbilled patients.
I expect that if the freeze is not lifted these amounts will have to go up again soon.
Everything gets more expensive over the years, including the cost of running a medical practice – think for example about rent and employing receptionists and nurses. If GP practices would not up fees, their Medicare rebate income would drop with 7.1% by 2017-2018!
Over the years more and more services will require an out-of pocket payment by patients, including pensioners and healthcare card holders. Rural doctors expect that bulkbilling in the bush will soon be a thing of the past.
But the freeze has also affected urban areas. That’s why the the RACGP and AMA have labelled the government policy a ‘copayment by stealth’.
The freeze is bad policy and should be reversed for five reasons:
1. Many practices will stop bulkbilling. This means higher out-of-pocket costs for patients. As a result fewer people will visit the doctor in the early stages of a disease. This will often make treatment later on more difficult, more stressful and more expensive.
2. The policy disproportionately affects disadvantaged people who cannot afford a copayment. Research shows that increased out-of-pocket costs stop people from going to the doctor.
3. The freeze undermines important Australian values such as equity of access and therefore encourages a two-tier health system.
Some argue that a copayment would cut unnecessary use of medical services. But higher out-of-pocket-costs will not weed out unnecessary visits. Many of my colleagues know that often their sickest patients will not seek medical care if it becomes more expensive.
4. Research indicates that areas with poor access to GP services have higher hospital costs. It is likely that more people will visit places where healthcare is free, such as already overloaded public hospitals and emergency departments. Dr Google will become more popular too!
5. Practices continuing to bulkbill will have to change their business model: doctors need to see more patients per hour, or practices will have to hire less staff which will affect service. Some practices will close their doors – such as Dr Adrian Jones, a Redfern GP who decided to close his practice as the margins were getting too small.
Is the freeze a necessary policy?
Medicare is not unsustainable. This is a false argument by the government. In fact, Federal Health Minister Susan Ley admitted at the national AMA conference: “The Government is not claiming we’re in a healthcare funding crisis.”
Australian healthcare performs well in comparison to other countries. The increase in health expenditure in general practice has been slow, and in line with overall economic growth and GDP.
Freezing the patient Medicare rebate will not make healthcare more efficient or reduce waste in the system.
Historically, campaigns against bad government health policies have been predominantly doctor-centric. And the usual government response is to divide doctors and patient organisations.
Many politicians have mastered playing the ‘greedy doctor’ card, which is an effective way of making doctors’ objections seem less trustworthy.
A while back, I interviewed the influential patient advocate Jen Morris for my blog. Ms Morris is a researcher in healthcare quality and safety at the University of Melbourne.
We spoke about the untapped power of the patient–doctor alliance. She strongly feels that we can achieve so much more in Canberra if patients and doctors joined forces more often.
“At a strategic level, it’s a numbers game,” she said. “There are approximately 26,000 GPs in Australia, and about 82,000 registered medical practitioners. But there are over 23 million patients. That is an enormous bloc of voters and lobbyists to leave untapped.”
The RACGP’s ‘You’ve been targeted’ campaign earlier this year against the co-pay plan was an example of what happens if patients stand united with GPs to protect primary care. The Consumers Health Forum of Australia (CHF) issued a joint press release with the RACGP and the Australasian College for Emergency Medicine to reject the co-payment scheme. The RACGP’s change.org online petition had obtained 44,800 signatures within a week.
Other organisations including the AMA followed suit. The broad approach seemed to have an impact, first in the media and eventually in the corridors of power, and GP co-payment and extended level A consultations were dropped.
More recently, the RACGP, the Royal Australasian College of Physicians, and the CHF partnered in a joint submission to the Federal Health Minister regarding the deregulation of pharmacy locations and ownership.
Although these are great developments, there are also concerns. What if our goals are in opposition?
Take for example the PCEHR. Patient organisations want full control of the data, which makes it less useful as a clinical tool for doctors.
Understandably, there is scepticism from both sides. Patient organisations may be wary of working with powerful medical organisations setting the agenda. Patients may feel that doctors are not genuinely interested in their opinions. Doctors on the other hand may be concerned about increasing demands and consumerism.
Morris: “It is important to remember that disagreement doesn’t only pose an obstacle in ‘patients and providers’ scenarios. Neither patients nor providers are homogeneous groups, and we do well to remember that. It is worth asking how providers approach the problem when they disagree on an issue or project, and source lessons from that.”
So, the answer lies in building trusting relationships. GPs are good at this on an individual level. It is one of the strengths of general practice. We should be doing the same at an organisational level. Working closely with patient organisations will improve the mutual understanding of our values and beliefs.
According to Ms Morris, we should be looking for common ground. More often than we acknowledge, patients and doctors are really advocating for the same outcomes. But too often, she added, we don’t take the time to really analyse where the crux of disagreement actually lies. Morris: “(…) if we find that the aims of doctors and patient organisations are so distinct as to be deemed incompatible, we should be re-evaluating those aims urgently.”
‘Them and us’
Of course, the ‘them and us’ thinking also occurs between providers. This can be confusing for patients and third parties including government organisations. For that reason, I’m a great believer in the power of United General Practice Australia. It is made up of the main GP groups, including the colleges, the rural groups, the AMA, registrars and supervisors and the divisions network. These organisations have shown a desire to collaborate and put aside their differences.
A similar structural working relationship should be developed between doctors and patient organisations. This alliance should exist not just to respond to new developments, but also to proactively set out a future course and lobby governments accordingly. It would make primary care less vulnerable to the rapidly changing preferences and priorities of the government of the day.
It is good to see the willingness from both sides to work together, and I hope it is the beginning of a fruitful collaboration in years to come. We must harness the potential power of the patient–doctor alliance to protect what’s good and, where needed, improve the care for our patients.
This article was originally published in Australian Doctor Magazine.
As frequent readers of this blog may know, I am very unimpressed with the recent pharmacy agreement negotiated by the Pharmacy Guild of Australia. We need more teamwork and integration of health services, not fragmentation, and therefore it’s a real shame the Health Minister has signed off on this deal with the pharmacy owners union.
A better proposal has come from the Pharmaceutical Society of Australia (PSA) and the Australian Medical Association. For those who don’t know: The PSA represents Australia’s 28,000 pharmacists working in all sectors and across all locations. The new model encourages close collaboration between pharmacists and GPs.
The PSA and AMA recommend integration of non-dispensing pharmacists in general practice, to improve medication management. The idea is not new. Doctors and pharmacists have argued for this model in the past. There is enough evidence to support collaboration as a way to improve patient care.
Here are the aims of the cooperative model:
Medication management reviews conducted in the practice, an Aboriginal Health Service, the home or a Residential Aged Care Facility
Patient medication advice to facilitate increased medication compliance and medication optimisation
Supporting GP prescribing
Liaising with outreach services and hospitals when patients with complex medication regimes are discharged from hospital
Updating GPs on new drugs
Quality or medication safety audits
Developing and managing drug safety monitoring systems.
Medication reviews by a pharmacists in the hospital do not appear to reduce mortality or hospital readmissions, although they seem to reduce emergency department contacts. Similarly, medication reviews for nursing home residents do not to reduce mortality or hospitalisation – which is disappointing.
However, in these studies pharmacists and doctors are not working closely together as suggested by the PSA and AMA. This matters because studies have shown that doctors are more likely to change their medication management when there is a close collaboration with a pharmacist. This is not surprising as the basic requirements for effective teams are mutual trust, good communication and shared ideas.
A systematic review of pharmacists working in collaboration with GPs showed significant improvements in blood pressure, diabetes control, cholesterol levels and cardiovascular risk. Another review suggested similar benefits as well as a positive impact on drug-related problems.
A recent trial confirmed that pharmacists working in primary health clinics are succesful in identifying and resolving medication related problems and improving medication adherance. The PINCER trial concluded that pharmacist feedback, educational outreach and dedicated support in a general practice setting was cost-effective and reduced medication errors.
Whether the pharmacist-doctor partnership reduces hospital admissions is less clear-cut. An independent analysis by Deloitte Access Economics (commissioned by the AMA) suggests that every $1 invested in the PSA-AMA model would generate $1.56 in savings to the health system, delivering a net saving of $544.8 million over four years.
I spoke to Dr Steve Wilson, Chairman of the AMA (WA) Council of General Practice and senior Lecturer at the School of Medicine, University of Notre Dame.
“We recognised the need for, and the advantage of, having pharmacists within the practice team,” says Wilson. “We have looked at both sides of the coin, the good and the bad, advantages and risks. We have explored the various financial models, for example whether pharmacists should be employed directly, or contracted, and whether to follow the Practice Nurse incentive Payment model or the Mental Health Nurse model.”
Dr Wilson said the strengths of the proposal are:
Quality use of medications as over-arching principle
In-house reviews as opposed to out-of-house
Medication interaction checking
Reviewing the currency of medications, for example deleting old antibiotics still on the list
Screening for adverse medication events or omissions such as whether medications can be reduced or stopped, or whether certain checks have been performed
Checking currency of tests, for example renal function for those on diuretics
Explaining medications to people, for example what side effects to look for
Working with those from culturally and linguistically diverse people or a non-English speaking background, people more than five medications, people with early cognitive impairment etc
Quality Use of Medications meetings within the practice, attracting CPD points
The Pharmacist in General Practice Incentive (PIGPI) system would be structured in the same way as the existing incentive payments provided for nurses working in general practice.
Dr Wilson: “The risk of the program is low, it’s voluntary, doctors and patients don’t have to participate. It’s up to the GP practice to make it work and customise it to their circumstances. There are financial incentives for rural practices. Also practices can share a pharmacist, particularly when closely located to one another.”
“The evidence will build over time. The evaluation component will require input from hospitals and there may be a role for the Primary Health Networks and Local Hospital Networks.”
The proposal has been welcomed by the Consumers Health Forum (they’re requesting feedback here). Although there are clear benefits for patients, evidence-based medicine purists may argue that the evidence for cost-savings through a cooperative model is thin. However, the alternative may be no change at all.
Health Minister Sussan Ley said at the annual AMA conference in Brisbane that the Government is not claiming we’re in a healthcare funding crisis.
At the same time dark clouds are gathering as the frustration about the patient Medicare rebate freeze rises.
The Medicare rebate is the amount patients get back from Medicare after they visit their doctor. This amount is supposed to go up every year to compensate for inflation and higher costs. The government has frozen the annual indexation for four years.
The Consumers Health Forum said in its analysis of the latest Budget: “The retention of the $1.67 billion freeze in Medicare payments to doctors may mean many patients are likely to face higher medical bills.”
The Guardian reported: “The AMA president, Brian Owler, used his opening address on Friday to call for both sides of politics to lift the ‘damaging’ freeze which could force GPs to start passing costs on to their patients, amounting to a so-called co-payment by stealth.”
And: “The federal government could face another fierce campaign from one of the nation’s most powerful lobby groups if it does not lift its freeze on doctors’ rebates before the next election.”
The RACGP has also indicated that it would consider a new campaign. It looks like we’re going to get some fireworks again.
It had taken a year to organise the required paperwork to make the move from the Netherlands, and finally I was here, about to start my job in a remote hospital.
However, the manager on the other side of the desk had other ideas. She looked at me over her glasses and shook her head. I wasn’t allowed to work, she said, because my Medicare provider number would take another month to come through.
Of course, this was just the beginning. After a few years working in the bush, I was thrilled to qualify for a permanent Australian residence visa. But first I had to pass the international English language test — again.
“G’day mate, do you really need me to come to the big smoke?” I asked a clerk at some department over the phone. “I’m flat out looking after this mob in the back of Bourke. I passed that exam ages ago, before I came to the Lucky Country. Surely me Strine hasn’t got worse since I’ve been here. Crikey, the rellies back home reckon I have a dinky-di Aussie accent.”
Needless to say, I had to sit the English test again.
Red tape bugbears
This was a decade ago, but things haven’t got any better. The GPs Down Under (GPDU) Facebook group, a new, quickly growing online community of Australian GPs and registrars, listed their ‘red tape bugbears‘ earlier this month.
The amount of time and energy GPs waste filling out forms and jumping through bureaucratic hoops is gobsmacking.
One GP recently posted on the GPDU Facebook page: “For practices employing a new rural doctor, there are at least 14 different forms across Commonwealth and State jurisdictions. Some have to be completed online, some need to be scanned, some mailed — yes, with a stamp. And some faxed.”
Hospital bureaucracy is also a big bugbear for many GPs. For example, in Queensland the public hospitals have an extensive referral ‘criteria’ for each department. GP referrals that don’t tick their boxes – often checked by non-medical staff – are simply refused.
One orthopaedic outpatient department doesn’t accept a referral until GPs have faxed a completed three-page ‘hip and knee questionnaire’.
Other health professionals can also add to the GPs’ burden when they selectively take over parts of our job under the notion of helping to reduce our workload.
But it doesn’t always work out that way as one GP on the GPDU site recently highlighted when she told of how her local pharmacy happily manages her patients’ warfarin doses, but only as long as the INR is within a safe range.
“Apparently this service is more ‘convenient’ as well as lucrative for the pharmacist. Until the INR level is more than 2.5. Then, late Friday afternoon, the pharmacy demands I manage the warfarin dose. So then it’s suddenly my problem,” she posted.
Red tape is often a knee-jerk reaction to a problem and not usually the best solution.
An estimated 25,000 patient consultations are lost every month while doctors are waiting for PBS Authority call centre operators to answer the phone. Meanwhile, our Medicare-funded sick certificate ceremony is estimated to cost the Australian economy $3 billion a year.
It’s time we did something about it.
Collaboration with other professions and organisations is more important than ever. If we help hospitals solve some of their outpatient department problems, our workflow will improve too. GPs need to negotiate innovative solutions that are mutually beneficial and acceptable. Building relationships, communicating and networking are the key to success.
We are in an ideal position to show leadership. This means we have to organise ourselves better, learn to be good followers, and support those who are trying to build bridges, including our peak organisations. No doubt we will occasionally have to compromise and, in some instances, lift our game.
I realise this is not easy in the current climate of cuts and freezes, but if we fail to do this, others will continue to take control of primary care. I love Australian general practice – it’s a great profession and the reason why I came to Australia. But we must protect what’s good and make it future-proof.
My call to action to colleagues, the colleges and the AMA is simple: please help and make things easier.
This article was originally published in Australian Doctor Magazine.
Wouldn’t it be great if we could spot the bad apples before we consume them? Or even better: before they become bad? In recent years medical regulators around the world have been exploring ways to identify doctors who are performing poorly.
In the UK all apples are tested once a year via a process called revalidation. But some have said it will not detect poor doctors; its main purpose is to gain patients’ trust. Others say it is meant to demonstrate what good apples look like. But one thing is for sure: Revalidation is labour-intensive and expensive.
“There is indeed an additional time cost,” said GP Dr Paresh Dawda in Australian Family Physican. “The appraisal meeting was usually 3 hours in length, and on average it took another 5 or 6 hours to collate the evidence and complete the forms, which is in keeping with an average of 9 hours found in the revalidation pilots.”
Then there are the training, time and wages of the appraisers, usually doctors too, the administrative staff, extra regulation, log books, documents, IT… Revalidation has become an enormous enterprise, costing £97M ($186M) a year, mainly because of added pressures on doctors’ time.
It seems logical that, before a country embarks on an operation like this, the problem it is trying to solve has been defined and the solution is effective.
So what’s the problem?
According to the Medical Board of Australia, evidence from Canada shows that 1.5% of doctors are not good enough. The Board has translated this figure to Australia, and thinks that over 1,350 doctors could be performing unsatisfactorily. Other research indicates that just 3% of doctors are the source of 49% of complaints.
“Where is the evidence that further regulation is needed?
Several safety mechanisms are already in place: At the moment Australian doctors must meet the Medical Board’s mandatory registration standards, including for recency of practice and continuing professional development. Doctors can be subjected to random compliance audits.
Although a majority of Australian doctors seems to support competence checks, there are serious questions about the UK-style revalidation process.
AMA(WA)’s GP Dr Steve Wilson in this blog post: “Where is the evidence that further regulation is needed, which will be preventative and ultimately beneficial to the profession and the community?”
“Will it address those who fail to practise to agreed levels, and is that a sign of ‘impairment’ or more about personal style, lack of time, adequate remuneration, or lack of care, training, experience, sheer demand and workforce numbers?”
At a conference in 2013 Medical Board of Australia Chair, Dr Flynn admitted that ‘the problem that a revalidation-style system would help solve was not yet defined’.
But Dr Flynn questioned the current continuous professional education system: “Can you assure me that everyone who has done your CPD program is actually competent and practising at a reasonable standard? (…) My sense is that, for most CPD programs, they don’t do that, or at least, not to a high enough level of certainty.”
After meeting Dr Flynn in 2013, the RACGP stated in Australian Doctor magazine: “The meeting provided an opportunity for the college to discuss the strength of our current QI & CPD program, and the necessity of adding yet another mechanism to identify underperforming doctors, when processes are already in place – such as the medical boards, health quality and complaints boards and indemnity insurers.”
What’s the Medical Board up to?
“We started a conversation about revalidation in Australia in 2012,” said Dr Joanna Flynn in last week’s media release, “as part of our commitment to making sure doctors in Australia maintain the skills to provide safe and ethical care to patients throughout their working lives.”
The board has asked the University of Plymouth to answer some questions on revalidation. At first glance this seems a sensible approach.
Dr Flynn: “We have commissioned this research to find out what is working well internationally, what is in place in comparable health care systems, and what principles the Board should consider in developing revalidation in Australia. (…) this research will help make sure that the decisions the Board makes in future about revalidation are effective, evidence-based and practical.”
The aim of the project is to:
establish the existing evidence base for the validity of revalidation or similar in countries comparable to Australia
identify best practice and any gaps in knowledge for revalidation processes
establish the validity evidence for revalidation’s effectiveness in supporting safe practice
develop a range of models for the Australian context for the Board to consider.
It seems to me the research questions are broad and several steps are taken at once. For example: ‘Establishing the evidence for revalidation’ and ‘developing a range of revalidation models’ are entirely separate processes.
It appears the Medical Board has already made up its mind. The research findings will be considered by the Board in the second half of 2015. I am certainly looking forward to the results and conclusions, as well details about cost and setup of the study.
The Camera revalidation research website of the University of Plymouth doesn’t give any answers away: “The research team is currently undertaking an ambitious programme of research involving three interlinking studies to explore and understand revalidation in all its complexity.”
Putting the cart before the horse
The question is of course: Is revalidation the right solution? Are there other options? One could argue that this should have been considered before spending tax dollars on an overseas research project.
Professor Breen, from the Department of Forensic Medicine at the Monash University in Melbourne, said in the Medical Journal of Australia: “There is little to support the idea of simply transposing the UK system to Australia. Despite some local failures of medical regulation and hospital governance, there has been no widespread loss of faith of the community either in its doctors or in the regulatory system.”
“Is there a problem with medical registration in Australia that needs attention, and, if so, what should be done to fix the problem?
“The Medical Board of Australia would be wiser to start afresh by asking and answering two questions — namely, is there a problem with medical registration in Australia that needs attention, and, if so, what should be done to fix the problem?
“The medical profession in the UK appears to have accepted revalidation, albeit reluctantly, as representing the price to be paid for maintaining the existence of the GMC and for regaining public trust after a series of regulatory failures.”
“It has been claimed that revalidation will not reliably detect poorly performing doctors, and many commentators have pointed out that revalidation would not have identified Dr Harold Shipman.”
Immediate past president of the AMA, GP Dr Steve Hambleton had second thoughts too. In MJA Insight he said: “We need to make sure we maintain our currency and continue to improve health outcomes, but in terms of value for money, making everybody go through a 5-yearly process of 360-degree evaluation is not needed in the Australian health system.”
Both Professor Breen and Dr Hambleton suggested there are better ways to deal with the bad apples. Database analysis could be one solution. Other options are targeted revalidation and a revamp of the existing CPD program and accreditation. Some have argued that the focus should be on the workplace, not just on health professionals.
Journalist Paul Smith from Australian Doctor magazine was, as usual, spot on when he wrote: “(Doctors) may argue that targeted revalidation has greater merit than what they may see as carpet-bombing the entire profession.”
“Recently I cried at work,” posted Dr Adrienne Garner on the BMA blog. “Why? Because the evening before I’d been notified that my appraisal, submitted after hours of work, had been unsubmitted by my appraiser as it was ‘not sufficient for revalidation.”
“I was gutted. My mind churned with a mixture of thoughts ranging from anger to fear, through frustration and disappointment. Sleep had been impossible.”
“Under revalidation appraisals became a form of policing the profession.
Many studies show that doctors are more likely to experience psychological distress and suicidal thoughts than the general community, and there is a high rate of burnout. Pastoral care and self-reflection are important. But when they are part of a policed regulatory framework, they become a stressor in itself – which defeats the purpose.
Former Coventry GP Dr Gaurev Tewary, now working in Australia, posted on a social media platform: “I was an appraiser in the UK. My overall impression is this: Appraisals used to be fun and interesting and mainly pastoral. You did them to help people and I enjoyed supporting the profession. Under revalidation it became a form of policing the profession.”
About 5,000 doctors a year are considering to leave the UK, and many come to Australia. Bureaucracy is one of the reasons they emigrate. We must become better at dealing with bad apples, but healthcare is already a highly regulated industry and the last thing we need here in Australia is more regulation, red tape and stressed-out doctors.
I hope the Medical Board will work with the colleges and the AMA to explore better options.
In the ‘Blogging on Demand’ series you get to choose the topic. If you have a great idea you want the world to know about, send an email, contact me via social media or leave a comment below. Dr Kellie West suggested the topic of this post. She tweeted: “Love to see you tackle the social justice responsibility of doctors [and], health care worker’s responsibility to refugees and asylum seekers.”
I arrived in Australia by plane. My introduction in Australian medicine took place in an empty emergency department and lasted for one hour. The compulsory 4WD course took about eight hours. Afterwards I was flown to a remote hospital, and the next day I found myself on the ward treating patients.
Some people refer to me as an IMG (international medical graduate), others call me an OTD (overseas trained doctor), but according to the government I’m a skilled migrant.
I’m grateful to have been given the opportunity to live and work in Australia. I feel welcome here and I see Australia as an example of a tolerant, multicultural immigration country. In the past ten years I have treated thousands of people, mostly in rural areas where many Australian doctors don’t go.
Australia shares in the benefits of global trade, including skilled migration. Annually about 130,000 skilled migrants enter the country. Australia has not paid for my expensive education, which is fair enough. The skilled migrant program is designed to address specific skill shortages and enhance the skill level of the Australian labour force.
Asylum seekers, on the other hand, are a different kettle of fish.
Who’s afraid of boat people?
In nearly forty years, about 70,000 asylum seekers have arrived by boat; an average of 1,750 per year. Compare this to the 130,000 skilled migrants arriving every year, and I can’t help but wonder how a political party can win an election over such a relative minor issue.
It appears strangers in boats change something in the usually tolerant ozzies. Journalist Christos Tsiolkas writes:
We’ll lock up asylum seekers in offshore detention centres, we’ll stand idly by as they slowly go crazy or harm themselves, we’ll refuse journalists the right to speak to them or to name them, we’ll redefine our borders to not let them in, we’ll farm them off to our impoverished, under-developed neighbours rather than construct a humane and efficient system to process their claims for asylum.
Tsiolkas feels that Australians are not convinced about the benefits of globalisation.
Yet, healthcare in rural areas is predominantly delivered by overseas trained doctors like me. Yet, a quarter of the Australian population has been born overseas. Yet, the Australian economy depends on international trade, and millions of Australians travel to Asia, Africa, and other destinations for leisure and business purposes.
Many people have preconceived ideas about asylum seekers. The risk is that prejudice leads to acceptance of a questionable approach to asylum seekers.
Are they economic migrants instead of refugees? Depending on the source you read, between 70-92 percent of arrivals is ‘genuine’, meaning they are not coming for economic reasons but because they are being persecuted.
Are boat people queue jumping? The queue refers to resettlement: The assisted movement of refugees who are unable to return home to safe third countries. Unfortunately these queues do not exist (it’s more like a lottery) and resettlement is only available for the ‘lucky’ one percent of the world’s refugees.
Somehow we have forgotten that seeking asylum is a correct and legal procedure; asylum seekers are not ‘illegal’ and cannot not be penalised for arriving without travel documents.
Australia is one of 147 signatory countries to the UN Refugees Convention, which means we are obliged to protect refugees. But is Australia taking its responsibilities? Paul Power, CEO of the refugee council of Australia says:
“The view from Indonesia is of a very wealthy, largely unpopulated country pushing unwanted people back to a much poorer, overpopulated neighbour.
The question is: How sustainable is Australia’s solution? The boats have stopped, but global humanitarian crises haven’t. Power: “I can’t see the international pressures which result in refugee movements and desperation migration decreasing in years to come.”
Australia has been heavily criticised by the UN and other countries for its treatment of asylum seekers and refugees. Power recommends a major review of Australia’s treatment of asylum seekers. We must make sure, he says, that they have the following:
Access to refugee status determination, with access to information, interpretation, funded legal advice and review
Freedom from detention, using existing detention alternatives in all but the most exceptional of circumstances and develop detention alternatives in Nauru and PNG
Giving all asylum seekers the right to work – even if work is hard to find, not robbing them of the hope associated with looking for work
Ensuring all asylum seekers have access to basic services, including adequate shelter, physical and mental health care and education
Access to durable solutions – providing prompt decisions and outcomes and living conditions which are sustainable for recognised refugees
The option to explore alternative entry options for people at risk.
The deaths of asylum-seekers Reza Berati and Hamid Kehazaei were preventable according to many. The Australian Medical Association feels strongly that asylum seekers and refugees should have access to proper healthcare. The AMA’s 2013 pre-election position statement:
The AMA wants humanity restored to an otherwise inhumane approach to asylum seekers
The next Government must establish a truly independent medical panel to oversee, and report regularly on, the health services that are available to asylum seekers in immigration detention facilities, both onshore and offshore
The Panel would inspect the available health services, and detainee access to them, and report quarterly to the Parliament, the Prime Minister, and relevant Ministers.
As far as I can see, these recommendations have not been implemented.
In fact, a recently leaked draft consultant report obtained by the ABC revealed that the government feels that medical staff contracted to take care of asylum seekers were advocating too strongly for refugees.
Don’t cross the line
The AMA’s code of conduct dictates that doctors should refrain from denying treatment to patients because of a judgement based on discrimination.
It also stipulates that, regardless of society’s attitudes, doctors do not support ‘cruel, inhumane, or degrading procedures, whatever the offence of which the victim of such procedures is suspected, accused or convicted.’ This is in line with the Declaration of Geneva and doctors have to uphold this – no matter what the government says or does.
Immediate past president of the AMA Dr Steve Hambleton once said at the National Press Club:
“Let’s stay out of where they are from and why they’re here and all the other stuff. Once we are in control or once we take responsibility for people, we should be providing them with first-rate health care.
Thanks to Dr Kellie West for the topic suggestion.
In the ‘Blogging on Demand’ series you get to choose the topic. If you have a great idea you want the world to know about, send an email, contact me via social media or leave a comment below. Karin Calford suggested the topic of this post. She sent an email asking: “With the imminent defunding of GPET*, what happens to GP registrar teaching from this point on? Wondering if you would be willing to blog about this.”
I am so pleased that people ask these questions. Karen wrote that, as a patient, she is concerned about the delivery of effective, patient-centred care in the future. As an example she mentioned the importance of teaching communication skills: “How will this sort of valuable non-clinical registrar training occur in the future?”
The responsibility for the training has been in the hands of GPET since 2001. The organisation was launched as a result of government concerns about the training program from the Royal Australian College of General Practitioners (RACGP). GPET was to give a range of groups a voice in the national GP training program. At the time it made an end to the RACGP’s monopoly as training provider.
From 1 January 2015 GPET is no longer. The Department of Health takes over its responsibilities to achieve administrative efficiencies. Australian Doctor magazine reported: “The Abbott government predicts it will save $115.4 million over four years by a package of cuts that includes abolishing GPET, slashing regional training providers and scrapping the Prevocational General Practice Placements Scheme.”
The current situation can be summarised in one word: Chaos.
The power vacuum
Former chair of GPET Professor Simon Willcock predicted a while back that the axing of the organisation would create a ‘power vacuum at the heart of GP training’. The responsibility for the training program now lies with the Department of Health, but the question remains how well things have been thought through.
It appears GP registrars wanted to get rid of GPET. Shortly after the election of the current government they made suggestions to replace GPET in a ‘draft’ sent to a government policy advisor. Australian Doctor magazine obtained a leaked copy, which “(…) warned of escalating costs facing the government in dealing with the expanding number of options for GP training.”
GP supervisors are now concerned that big corporates will take over the training program, because they “(…) operate with an efficiency that concentrates on urban training to maximise patient throughput, rather than the development of quality general practitioners.”
“Abolishing GPET takes away professional control and leadership of GP training. And we believe that the Department of Health does not have the necessary experience to run GP training. The Budget reforms will dismantle the existing GP training infrastructure that has taken many years to put in place.
In the meantime the two GP colleges, RACGP and their rural counterpart ACRRM, have proposed a new framework for the training program. The AMA was not happy about the fact that the colleges kept their plans behind closed doors, but supports a college-led training program as this would be consistent with other medical specialist training programs.
The soap continues: The two colleges were to meet federal health minister Peter Dutton last week, but the get-together was cancelled at the last minute. This promted RACGP president Dr Frank Jones to express his disappointment:
“(The colleges) are extremely disappointed that a meeting scheduled to discuss general practice training with the Federal Minister for Health, The Hon. Peter Dutton MP, was cancelled yesterday. On behalf of the RACGP, I have stressed the critical and urgent need for reassurance regarding the future governance of a general practice training program and will endeavour to reschedule this meeting before Christmas.
It is unknown if Peter had to cancel because of the flu. If that’s the case I hope he has an empathetic doctor – and he’d better ask for a sick note too.
Here’s to hoping that regardless of the government’s administrative ‘efficiencies’, the quality of the Australian GP training will remain world-class.
In 1976 two researchers, James Pennebaker and Deborah Sanders, published and interesting study. They placed two kinds of signs in university toilets, one reading: “Do not write on these walls under any circumstances,” and the other: “Please don’t write on these walls.” Result: the amount of graffiti on the walls with the first, more authoritative sign was significantly more.
This phenomenon is called reactance: when something or someone threatens to restrict our freedom, our intuitive response is to undo this – even if our response may have negative consequences.
Reactance can occur on a massive scale as, for example, in the case of Japanese whaling. The consumption of whale meat in Japan is decreasing – it is considered traditional food and younger generations are not interested in it. Yet, Japanese people respond furiously to the actions of the Sea Shepherd activists against their whaling fleet. Travel writer Sam Vincent, who wrote a book about this topic, concludes: “Japan isn’t pro-whaling. It’s anti-anti-whaling.”
AMA response to the ‘skin spot check’
This week a new pharmacy initiative was in the news: ‘Skin spot checks’. For $35 people can have a single skin lesion of their choice examined at certain pharmacies. The response from the Australian Medical Association was as expected. Dermatologist and president of the NSW branch of the AMA said: “It is irresponsible and inappropriate for pharmacies to offer in-store skin checks.”
Although the AMA has a point, the response can be: “If the AMA doesn’t agree, it should be approved.” Reactance in action! This may be followed by: “The AMA is probably protecting their members’ interests, so let’s give these entrepreneurial chemists a fair-go!”
If the AMA had said: “Look, doctors are busy and fed up with all these people worried about their freckles, so please go away and visit the pharmacy,” the response would probably be the opposite. I’m not arguing that they should have said this, but the point is that most doctors care about their patients’ wellbeing and this is unfortunately not always taken into account in the media and comments.
The following scenario happens often in my practice: a patient asks my opinion about a pigmented but benign skin lesion, and is not aware of the (more common) non-pigmented malignant or pre-malignant lesion elsewhere on the skin. These spots will likely be missed at the ‘skin spot check’ in the chemist store.
A one-size-fits-all approach doesn’t work in my job. There are always plenty of valid reasons why a particular approach or treatment works for one person but not for another.
One-size-fits-all healthcare is bad medicine. Bulk billing everyone doesn’t make sense. It’s not necessary and doesn’t cover the costs. In the same way, charging a co-payment across the board doesn’t make sense either.
There are people out there doing it tough, such as Melbourne mother Kaye Stirland who wrote treasurer Joe Hockey a letter that went viral on social media. Kaye represents a group of people who cannot afford to pay $7 to see their GP.
The co-payment also puts healthcare providers in a difficult position. RACGP president Liz Marles said in Medical observer: “There will be times with patients we all see – mentally ill patients, young people, homeless people, people just doing it really tough – where GPs will have to waive that money. That will mean that GPs will not only lose that $5 but if they are a concession card holder you’re also losing the $6 bulk-billing incentive.”
I believe there’s nothing wrong with co-payments in general. In the end bulk billing is not sustainable if Medicare rebates don’t keep up with inflation and business costs (see this video).
AMA president Steve Hambleton was quoted by MO saying this: “If the minister says he thinks people should pay a co-payment if they can afford to do so, the AMA has no problem with that. (…) But we believe there are people who can’t afford to… We need to know what we’re going to do about low-income earners.”
Some vulnerable groups should be excluded from paying co-payments when they visit their healthcare providers. Co-payments are not always appropriate.
Social media is here to stay. A lot of registrars and young doctors have one or more social media accounts, and I have yet to meet a medical student who is not on Facebook. Patients are already sharing online (health) information via Facebook, Twitter and other social media accounts – so sooner or later health professionals will need to decide whether or not to participate.
Social media is increasingly used for medical education, and sharing knowledge and information such as tips, resources, literature and links. It’s also useful to build an online community. Clinics can share health information and other practical information.
Social media is more interactive than a website and you can reach a wider audience in real-time. Another benefit is the value of health promotion and lifting the profile of a medical practice or organisation. I’d like to mention the use of blogs, pictures and videos. I find they are a great way to communicate a message, and I use my social media accounts to let my followers know when I’ve posted something new.
Make the most of social media
Organisations need to be prepared to put aside time to manage their online presence, and there is no easy way out here. It takes time to post useful material and interact with others. Social media is a two-way street and not just another promotional channel. If you use social media for branding or promotional purposes only, you may lose followers.
Your online presence should have a consistent approach. Too many organisations set up a Facebook account without first developing a clearly defined strategy. It is recommended to take some time to plan and figure out the purpose of the social media campaign, which medium to focus on, and how to keep it sustainable and current. This usually requires a motivated person within the organisation.
Preparation is key, and implementing a social media policy should be part of the preparation. Some things to include in the policy are, for example, how to respond to negative feedback and/or complaints received via social media; and how to comply with AHPRA regulations.
The AMA has a useful document that outlines the risks. I also felt that the social media workshops organised by MDA National are an excellent way to become familiar with the common pitfalls.
Is social media for you?
Due to the time commitment, and the effort it takes to set up and maintain social media accounts, it may not be ideal for everyone.
For those who want to contribute to online health promotion or interact and share health information with their patients or other health professionals, social media is not without risks, but it can be an effective tool if used wisely.
This article appeared in MDA’s Defence Update in April 2014. Original title: ‘Social media in modern medicine’.
“How do you put up with this, doc?” She looked at me while I was on the phone. We were waiting for almost ten minutes.
Every time she comes in we go through the same ritual: I ring the PBS Authority hotline, we wait, sometimes for a couple of minutes, and sometimes longer – like today. I always get approval, and then print off the script for her. In the meantime other patients are waiting in the waiting room or trying to get an appointment.
According to the AMA thirty per cent of medical practitioners reported spending ten minutes a day or longer waiting for calls to be answered. So here we are: we have a shortage of doctors and we make them jump through bureaucratic hoops instead of seeing patients.
An estimated 25,000 patient consultations are lost every month while doctors are making phone calls to the PBS Authority hotline. At the same time various reviews have shown that this procedure is unnecessary and does not lead to any savings.
Though there has been some recent progress in reducing regulatory burdens in a few areas of medical practice, the amount of regulatory burden and red tape remains excessively high without any real justification. Internal AMA research shows that a large number of GPs spend up to nine hours or more each week meeting their red tape obligations. Every hour a GP spends doing paperwork equates to around four patients who are denied access to their doctor.
The submission focuses on six areas:
PBS phone authorisations.
Medicare provider numbers
Personally Controlled Electronic Health Records (PCEHR) registration for medical practices
Centrelink and Department of Veterans’ Affairs documentation requirements
Chronic Disease Management items under the MBS
Although there are lots of other areas that need improvement, this seems like a good start.
My patients often ask: “Doctor, do you bulk bill?” and “Why do I have to pay a gap?”
Although there are certainly circumstances where I bulk bill, it has many risks. Lowering the quality of Australian Family Doctor services is one them. In this video I have tried to explain how it all works.
I can confirm that the Government is not going to build a massive data repository. We don’t believe it would deliver any additional benefits to clinicians or patients – and it creates unnecessary risks (~Nicola Roxon)
I’ve studied the PCEHR but I’m still not sure what the government has built and for what purposes. I was always under the impression that the PCEHR was designed to assist clinicians to improve patient care through better data flow. But this may not be the case.
The recent resignation of NEHTA’s top National Clinical Leads is an ominous sign. If the Department of Health does not start sharing ownership of the PCEHR soon and improve governance of the system, the PCEHR will fail. Here’s a quick rundown of the issues and how to move forward.
A first glance at the PCEHR Act 2012 seems to confirm that the PCEHR is built with clinicians in mind, as its four purposes are clinical in nature:
To help overcome fragmentation of health information
To improve the availability and quality of health information
To reduce the occurrence of adverse medical events and the duplication of treatment
To improve the coordination and quality of healthcare provided to consumers by different healthcare providers
So far so good. But the Act is 93 pages long and I could find at least five other ‘non-official’ purposes of the PCEHR spread out throughout the Act:
Law enforcement purposes
Health provider indemnity insurance cover purposes
Public health purposes
Other purposes authorised by law
And this is where the concerns begin. These ‘non-official’ purposes are not directly related to the care doctors provide to their patients. In general, one would say that patients and clinicians have to give informed consent before their health information can be used for research or other purposes. It seems informed consent is missing here.
Combine this with certain clauses in the one-sided PCEHR participation agreement and you’ll forgive me for thinking that the government, contrary to Roxon’s reassuring words, has built a massive data repository: Once clinicians sign the agreement, they grant the Department of Health and Ageing a perpetual, irrevocable, royalty-free and license-fee free, worldwide, non-exclusive license (including a right to sub-license) to use all material they have uploaded to the PCEHR.
Those who think that you can always opt out are mistaken. Even if health care organisations or practices cancel the participation agreement, seven of the fourteen clauses survive termination, including clauses regarding liability. It is good to know that the government will continue to use the information after cancellation by a clinician or consumer for up to 130 years.
Another concern is the fact that the Minister may make or change PCEHR rules without legislation, and the Department of Health can change the participation agreement at any time without the need for input from clinicians. We thought the After-Hours and PIP contracts by Medicare Locals were a disaster, but this agreement is possibly worse.
By now it is obvious that Clinical Leads and professional organisations have not been involved in many important decisions. There is a range of other issues, which I won’t discuss here in detail, including technical software glitches and the absence of MBS item numbers. Under the PCEHR Act 2012, all clinicians are appear to be seen as employees, which could be a problem as many doctors may be employed as contractors for various reasons.
If the PCEHR can be used for data mining, legal purposes, insurance purposes etc, then that is fine, but, I would strongly advise the profession to stay clear from it. If however we agree, that the PCEHR is a clinical tool, then clinicians must be involved.
What we need first of all is an open, well-informed discussion about the purposes of the PCEHR. What are consumers and clinicians exactly saying yes to when they sign up? A proper, transparent, independent governance structure with specific executive authority should be formed. This PCEHR Board should include members from professional and consumer organisations and act as a watchdog over the PCEHR. Any changes to the rules require a consultative process with professional bodies including AMA and RACGP before the Board can sign off. The current PCEHR Advisory Committee and Council are not fulfilling these criteria at the moment.
Consumers should know exactly what happens with their data after they have visited a health care professional and who has access to their information. The purposes of the PCEHR must be clear and agreed upon by all stakeholders. Clinicians own the rights of the data they create and upload, there is no need to grant the government a perpetual irrevocable license to use this data.
The PCEHR Act 2012 and the participation contract must both be reviewed and made 100% acceptable to clinicians and 100% opt-out must be possible for clinicians and consumers at all times.
This will take time, but if we don’t start now there is no hope for the PCEHR.
This article has been published in Medicus, the journal of the AMA(WA)
My email inbox was overflowing, there were text messages wishing me good luck, journos calling and a press photographer was rocking up at the practice. On Twitter NEHTA’s visit had been dubbed ‘Khrushchev vs Kennedy’, others said that Geraldton was like the little Astrix & Obelix village, resisting the mighty Roman legions of Julius Caesar with the druid Getafix’s magic potions. But the analogies turned out to be wrong (in a good way)…
Dr Mukesh Haikerwal and Dr Nathan Pinskier, the two prominent clinical leads working with NEHTA to get the PCEHR off the ground, had decided it was time to visit us in the west. Also present at the Meeting was AMA(WA) rep Michael Prendergast, one of our practice partners Dr Elly Slootmans, our CEO Richard Sykes and our operations manager Louise – who has spent about 100 hours earlier this year to get the practice PCEHR-ready before we realised that the risks of signing up would be too high at this stage for the business and the doctors.
Mukesh, or ‘Mr eHealth’ as some are calling him, gave a persuasive presentation about the PCEHR, including the challenges ahead. His team is working on an interesting program called CUP (Clinical Utilities Program) to iron out the problems clinicians are facing when getting started or working with the national eHealth record system.
Mukesh and Nathan made a strong case for the PCEHR, including potential benefits such as electronic referrals, discharge summaries, ePrescribing, encrypted messaging etc. They seemed very aware of the issues and are putting in a lot of effort to fix them so the PCEHR eventually becomes a tool that makes our lives easier.
After the presentation we had a good debate about some concerns, such as the legal framework of the PCEHR and the governance issues. Interestingly, many of the concerns are not technological but, as our CEO Richard explained, if we don’t resolve them, practices will find it difficult to sign up no matter how good the PCEHR software will be.
We talked long and hard about the PCEHR participation agreement and why this document is the reason many health care organisations will not sign up. Michael Prendergast explained the pitfalls of signing these kinds of contracts without legal advice.
Other topics we discussed were the (harsh) civil penalties related to the PCEHR, the IP data rights problem, and secondary use of data in the system.
We know about the benefits of the PCEHR for patient care, and indeed there are many, but what has been missing is a proper debate about the other ways the data could be used; the PCEHR Act 2012 mentions eg ‘law enforcement purposes’, ‘other purposes authorised by law’, and research.
The way forward
I was very pleased to see that Mukesh and Nathan acknowledged these problems and understood that we – and many other clinicans – cannot go ahead before this has been sorted out. Michael was very helpful and will take the issues back to the AMA.
It was a pleasure to talk to these tech heads and it once again became clear to me that this is a journey that will take many years. For the first time I saw some light at the end of the tunnel. Khrushchev vs Kennedy wasn’t the right analogy because our interests are not opposed, but I’d settle for ‘Roosevelt & Churchill’. Modesty is my best quality (~ Jack Benny). Mukesh and Nathan, thanks for listening.