Stakeholder submissions

The ‘Medicare-funded diagnostic imaging services consultation’, Regulation Impact Statement (RIS) was released for comment between 14 May 2015 and 25 June 2015. Through it the Department of Health invited comment regarding:

• the likely regulatory impacts and costs, on consumers and businesses, of government proposals
• matters relevant to the implementation of the proposals
• additional suggestions not included in the RIS.

The table below lists the individuals/organisations that have provided comments on the RIS, and includes links to the PDF and word versions.

No.	Individual or organisation	PDF version	Word version
1	A/Prof Nick Stephenson	Version (PDF 255 KB)	Version (Word 474 KB)
2	Australian Institute of Radiography	Version (PDF 148 KB)	Version (Word 47 KB)
3	Australasian Society for Ultrasound in Medicine	Version (PDF 321 KB)	Version (Word 556 KB)
4	M4 Healthcare Pty	Version (PDF 148 KB)	Version (Word 49 KB)
5	Australasian Sonographers Association	Version (PDF 243 KB)	Version (Word 103 KB)
6	Alpenglow Australia Pty Ltd	Version (PDF 339 KB)	Version (Word 478 KB)
7	X-Ray & Imaging Pty Ltd	Version (PDF 140 KB)	Version (Word 28 KB)
8	Radiology Support, Health Support Queensland	Version (PDF 148 KB)	Version (Word 37 KB)
9	Chiropractic Australia Ltd	Version (PDF 223 KB)	Version (Word 53 KB)
10	HDAA Australia Pty Ltd	Version (PDF 131 KB)	Version (Word 40 KB)
11	Confidentiality requested	Version (PDF 131 KB)	Version (Word 42 KB)
12	Quality Innovation Performance (QIP)	Withheld at respondents request	Withheld at respondents request
13	Australian and New Zealand Society for Vascular Surgery (ANZSVS)	Version (PDF 95 KB)	Version (Word 22 KB)
14	The Cardiac Society of Australia & New Zealand	Version (PDF 153 KB)	Version (Word 47 KB)
15	Royal Australian and New Zealand College of Obstetricians and Gynaecologists	Version (PDF 143 KB)	Version (Word 53 KB)
16	Australian Diagnostic Imaging Association	Version (PDF 112 KB)	Version (Word 57 KB)
17	National Association of Testing Authorities Australia (NATA)	Withheld at respondents request	Withheld at respondents request
18	Australian Orthopaedic Association	Version (PDF 246 KB)	Version (Word 124 KB)
19	Royal Australian College of General Practitioners	Version (PDF 165 KB)	Version (Word 243 KB)
20	Australasian College of Physical Scientists and Engineers in Medicine (ACPSEM)	Version (PDF 155 KB)	Version (Word 57 KB)
21	Royal Australian and New Zealand College of Radiologists (RANZCR)	Version (PDF 195 KB)	Version (Word 123 KB)
22	Confidentiality requested	Withheld at respondents request	Withheld at respondents request
23	Confidentiality requested	Version (PDF 140 KB)	Version (Word 50 KB)
24	Chiropractors' Association of Australia	Version (PDF 3739 KB)	Version (Word 303 KB)
25	Confidentiality requested	Withheld at respondents request	Withheld at respondents request
26	WA Country Health Service	Version (PDF 135 KB)	Version (Word 29 KB)

Next steps

1. The Department of Health (the Department) will consider the consultation comments that have been received and assess the impact of potential change, including the potential impact on rural and remote areas.
2. Further consultation via stakeholder meetings is expected to clarify the feedback received in formal submissions and will be used to revise the potential costs and benefits associated with the proposed options. In addition, the Department may undertake further, targeted consultation with key industry stakeholder groups.
3. The Department will provide the Australian Government with options for consideration.
4. The intention is that should changes be agreed, there will be sufficient time for diagnostic imaging practices, requesters and consumers of diagnostic imaging services to incorporate any changes into their working arrangements.

Background

Over time, stakeholders have expressed a desire for greater clarity regarding the level of supervision required while diagnostic imaging services are being performed. This Regulation Impact Statement (RIS) was developed (by the Department) specifically to enable this problem to be described and potential solutions sought.

This RIS was designed to encourage stakeholders to:

• review the current Medicare requirements for the provision of diagnostic imaging services
• explore options for enhancing quality, reducing waste and minimising the harm caused by inappropriate, unnecessary and sub-optimal diagnostic imaging services.

The consultation process was designed to draw public comment that informed Australian Government decision-making regarding how to improve the quality and safety of Medicare-funded diagnostic imaging services through changes to the regulatory environment.

To do this, the consultation RIS:

• described the existing regulatory framework
• documented problems associated with the existing regulatory framework
• outlined the objectives of reform
• suggested proposals for reform
• invited comment on the likely impact of implementation of the suggested proposals.

Respondents were asked to address any, or all of the options posed and/or to identify other issues (as per departmental submission template). In As such, comments were sought in relation to:

• the appropriateness and feasibility of the proposals
• whether the proposed changes would address current concerns held by the diagnostic imaging sector
• potential cost impacts
• potential workforce impacts
• patient access to appropriate imaging including rural and remote access
• the time required to implement the proposed changes
• the impact on small and large diagnostic imaging practices
• any other relevant comments, questions or concerns.

The Consultation RIS is attached below:

Regulation impact statement (RIS) Improving the quality and safety of Medicare funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements (PDF 1341 KB)
Regulation impact statement (RIS) Improving the quality and safety of Medicare funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements (Word 128 KB)

The dedicated RIS templates, used for seeking input are attached below:

Consultation Regulation Impact Statement: Improving the quality and safety of Medicare funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements - Consultation submission (PDF 169 KB)
Consultation Regulation Impact Statement: Improving the quality and safety of Medicare funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements - Consultation submission (Word 518 KB)

For further information please email the Diagnostic Imaging Team.