It’s time to cut the red tape

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.

Knee-jerk reaction

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.

Revalidation of doctors, or how to spot the bad apples

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.

Revalidation screenshot
Screenshot: Example of questions UK doctors have to answer during the 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.”

Red-tape stress

“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.

Revalidation

Why doctors run late: 12 red tape challenges

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, feel free to contact me. Last week members of the GPs Down Under (GPDU) Facebook group posted their red tape bugbears. Melbourne GP Dr Karen Price, who is an admin of the group, suggested to blog about the issues that slow doctors down.

Patients are often understandably frustrated about waiting times. A couple of years ago I blogged about the reasons why I run late, including the daily healthcare bureaucracy doctors have to deal with. I’m sad to say the amount of red tape hasn’t changed.

Australia is not making good use of its medical workforce. Example: An estimated 25,000 patient consultations are lost every month while doctors are making phone calls to the PBS authority script phone line.

Instead of reducing the amount of paperwork for doctors – so they can see their patients quicker – other professionals are asked to take over parts of the clinical job.

There are of course other reasons why doctors run late, but the focus of this post is on healthcare bureaucracy. So here is a summary of the GPDU Facebook discussion on the abundant red tape that slows doctors down, summarised in 12 points.

#1: Sick notes

Medical certificates for all sorts of issues seem to be increasingly popular, and every day thousands of doctors issue tens of thousands of notes.

This is not only a significant cost to Medicare, it also increases waiting times. Doctors have no problem issuing a genuine sick certificate as part of a consultation, but often people come in when they are getting better, just to get a certificate at the request of their employer.

Sometimes medical certificates seem to be used to shift liability when doctors are asked to declare that someone is fit for certain (recreational) activities. And, do we really always need a medical certificate when our children cannot attend daycare or school?

#2: Provider numbers

Medicare provider numbers are a bugbear for doctors and registrars, and have been for years.

One GP said: “Repeated applications for provider numbers through Medicare with the same information are such a waste of time. Surely they have my name, address, e-mail and multiple provider numbers already. An online portal with a ‘click’ application or submission of paperwork for would be amazing.”

Another GP: “For practices employing a new rural doctor there are at least 14 different forms across Commonwealth and State/Territory jurisdictions – some forms online, some scannable, some mailed, yes, with a stamp, some faxed. Software that would streamline at least some of those forms – even going to different destinations but auto-filled – would encourage practices to take more registrars and more prevocational doctors.”

#3: PBS authority phone line

Another major bugbear: Australian doctors have to ring this phone line before they can prescribe common medications. They must ring every time a script runs out, even if the patient has been taking the medicines for many years. The line is often busy and doctors and their patients are kept waiting. A short consultation can easily become a more expensive long consultation as a result of the waiting time.

Removing some medications from this scheme to a streamlined electronic procedure has not changed prescribing habits, which seems to indicate that the phone line doesn’t really serve a purpose. Also, some countries without a script line have lower antibiotic resistance patterns than Australia.

The approval process is bizarre. Doctors are asked the daily dose for an adrenaline emergency auto injector or have to spell the name of the drug as call centre operators have no clue.

Why doctors run late

A GP said: “After 5 minutes of waiting I’ve run out of small talk with the patient. By 6 minutes I’m almost considering to talk my patient out of starting Champix. And by nearly seven minutes waiting my usually cheerful manner with the call centre operator is gone.”

Another GP: “Sitting on the phone waiting for authority – why do I need permission from a bureaucrat to prescribe something?”

#4: Medicare and Centrelink

Medicare and Centrelink take up a lot of valuable time. The MBS criteria for example have been a constant source of confusion and stress for doctors. The endless paperwork is a challenge for doctors and practice managers.

One GP said: “Centrelink manages to outsource a tremendous amount of form filling in. Surely it contributes to green house gasses…”

Another GP: “Medicare forms… Some you can scan and e-mail back, some must be posted, others can be faxed but not emailed.”

#5: Handwriting charts, notes and scripts

Nearly all GP practices are computerised. Still we get requests from organisations to handwrite important documents.

Residential aged care facilities and community nursing teams often require handwritten medication orders, and don’t accept a printed chart generated by GP desktop software.

Some nursing homes and most hospitals ask that doctors, including visiting GPs, handwrite their notes. This also includes shared antenatal care. One GP said: “While I agree that the handheld obstetric records are exceptionally important, doubling up and having to write in them plus your computerised notes is inefficient – or print out your notes and have multiple loose prices of paper floating around each time.”

“I have some intellectually disabled adult patients in a group home and the script situation is tedious,” a doctor said. “Every panadol, every small change to prescribing, has to be documented and faxed to the chemist, and every consultation requires a form to be filled out and the consultation notes to be printed.”

The law requires doctors to handwrite opiate scripts underneath the printed text – and on both copies of the script – to reduce the risk of forgery. This has become obsolete for many practices as an electronic copy of the script can be sent to the pharmacy to avoid fraud. Other innovative developments such as real-time prescription monitoring will further make handwriting scripts unnecessary.

#6: Working with kids, working with elderly, working with vulnerable elderly checks

These new requirements for AHPRA registered doctors seem unnecessary. “I have to get not one single police check, but three checks,” said a GP. “‘Working with kids’, ‘Working with elderly’ and ‘Working with vulnerable adults’ checks before can work in country hospital, all at my expense. I work in an already highly regulated industry, I am trusted with scalpels and mind-altering drugs, and have an annual AHPRA registration renewal, but must do all this foolishness every few years.”

#7: Proof of AHPRA-registration

Doctors often have to provide a copy of their AHPRA registration, but registration details including the expiry date can be easily looked up by anyone on the APHRA website

#8: Travel cost assistance 

A GP said: “Filling out Patient Assisted Travel Scheme forms for rural patients is getting more tedious: We now have to write a letter stating exactly why our patients need an escort. Ticking the box isn’t enough.”

#9: Pharmacies

Pharmacies can add value in many ways, but when it comes to collaboration there is room for improvement.

One GP said that a pharmacy happily managed her patient’s blood thinners, but when the INR results were outside the normal range they referred back to the GP. “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. They get paid lots of money for a service I do for free.”

A common bugbear of GPs is the ‘owing scripts to pharmacy’ problem. Some pharmacies provide ongoing medications even if the script has run out. As a result patients miss their check-ups with the doctor and request an ‘owing’ script from their GP at a later stage.

In defence of the pharmacy: doctors are not always on time with sending scripts to the pharmacy.

#10: Accreditation

One GP expressed concerns about the never-ending accreditation requirements: “Not the principle, but the realities. Broadly speaking: Individual clinicians need to be accredited multiple times, not just by AHPRA, but by government (working with children checks etc), local hospitals, regional training providers (to be supervisors) etc.”

“Practices need multiple accreditations – separate ones to be training practices for example – and all very painful. Regional training organisations need to go through hoop jumping accreditation processes by the colleges, the colleges by the Australian Medical Council. Never-ending and so much time wasted.”

#11: Care plans, EPCs and mental health care plans

The rules designed by Medicare to manage chronic care in general practice have been the topic of heated debates. For example: Patients with a chronic illness cannot claim their Medicare rebate when the GP does a care plan and treats an acute problem on the same day. This means that many patients have to come back on another day, further increasing waiting times.

“Care plans and mental health plans interrupt my patient contact and workflow,” one GP said. “If a GP was rewarded more this templated rubbish would be done anyway as part of usual care by the good doctors.”

Another doctor said: “Did you know that people used to actually pay to see allied health professionals prior to GP care plans? Now it seems all allied health contact is required to be limited to five free visits per year.”

#12: Hospital bureaucracy

Making an appointment for a patient can be challenging sometimes. One GP said: “The hospital ‘outpatients direct’ won’t let me help organise an appointment for a patient without them being with me at the time, because of confidentiality. But I wrote the referral and need to know the date of the appointment to arrange transport or they won’t get there.”

Many hospitals have referral criteria and they’re not aways flexible: “Queensland public hospitals have extensive referral criteria. They don’t accept GP referrals that don’t tick their boxes – often checked by non-medical staff.”

Hospitals can really slow GPs down with extra paperwork requirements: “The orthopaedic outpatient department doesn’t accept a GP referral until we have provided them with a completed 3-page ‘hip & knee questionnaire’.”

Sometimes hospital doctors send a patient back to the GP for a referral to another hospital doctor. Many GPs feel that in some (especially urgent) cases an internal referral with a copy to the GP would be much more efficient.

Rural GPs often work in hospitals and emergency wards. Transferring sick patients to a bigger hospital is a challenge in some states: “Western Australia has a long way to go: I first have to call the RFDS, then the hospital and speak to the accepting team – if lucky one call, if unlucky several calls. Then I need to call the ED to inform them about the expected patient. I have to call the RFDS for an update. Then the registrar calls back after speaking to their boss. Then the hospital bed manager calls and lets me know there are no beds available, so I need to go to another tertiary hospital etc. I hardly have time to look after the patient and talk to their next of kin.”

One GP said about requesting investigations: “To organise a CT-scan at the hospital from a rural ED, I have to make phone calls to the radiologist, the CT tech, the ED consultant, the specialty registrar (if applicable), and the bed manager. If one of those phone calls is missed… hoo boy, you’d think that I’d killed Santa Claus.”

We need ongoing conversations with each other, managers and decision makers to avoid unnecessary red tape and improve the patient journey across various parts of the health system.

Thanks to Dr Karen Price for the topic suggestion.

The receptionist will call the wheelchair taxi for you now

Wheelchair
Image: Pixabay.com

“Doctor can I talk to you about something else?”

“No.”

“…what do you mean?”

“It’s not allowed. We have just finished your care plan. The government does not want me to see you for something else on the same day. They call it double dipping. Please come back tomorrow. The receptionist will call the wheelchair taxi for you now.”

Further reading: Budget 2013-14: Medicare Benefits Scheme – removing double billing

How do you put up with this, doc? Red tape in medical practice

“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.

I was very pleased to see the Australian Medical Association submission to the National Commision of Audit earlier this month. The AMA states in the introduction:

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:

  1. PBS phone authorisations.
  2. Medicare provider numbers
  3. Medicare payments
  4. Personally Controlled Electronic Health Records (PCEHR) registration for medical practices
  5. Centrelink and Department of Veterans’ Affairs documentation requirements
  6. Chronic Disease Management items under the MBS

Although there are lots of other areas that need improvement, this seems like a good start.