Private Health Insurance: Proposal for Quality Assurance Requirements for Privately Insured Services

Private Health Insurance: Proposal for Quality Assurance Requirements for Privately Insured Services As you may be aware, the Department of Health and Aging, Private Health Insurance Branch as part of its commitment to improving the value of, announced on 26 April 2006 that a uniform quality and safety regime for all privately insured services will be introduced from 1 July 2008. From this date, insurers will only be permitted to pay private health benefits for privately insured services if the services satisfy quality assurance requirements. Attached is a copy of the Circular for your review. I would like to draw your attention in particular to the Proposed Requirements for Natural Therapies. Quality Assurance Requirements for Privately Insured Services PDF Attachment A. PDF Attachment B. PDF Executive Summary PDF

PRIVATE HEALTH INSURANCE CIRCULAR Acute Care Division Private Health Insurance Branch Mail Drop Point 86 GPO Box 9848 Canberra ACT 2601 PHI 31/07 30 May 2007 QUALITY ASSURANCE REQUIREMENTS FOR PRIVATELY INSURED SERVICES As announced by the Government in April 2006, minimum quality assurance requirements for all privately insured services will be introduced from 1 July 2008. The Department has developed a proposed regulatory approach for the quality assurance requirements based on existing requirements for health care services and the Australian Commission on Safety and Quality in Health Care work on national safety and quality accreditation standards. The paper attached to this circular sets out the proposal. The Department is seeking feedback on the proposal and any further suggestions on how existing requirements may be standardised across privately insured services. This material will be used to inform consultation forums which will be held with individual stakeholder groups during July 2007. Outcomes from the forums will form the basis for the drafting of the Private Health Insurance (Accreditation) Rules for quality assurance requirements for privately insured services. Written submissions from the health care industry on the proposed quality assurance requirements are welcome until close of business on Wednesday, 27 June 2007. They can be sent to privatehealth@health.gov.au or to: Sharon Simons Private Health Insurance Branch, MDP 86 GPO Box 9848 CANBERRA ACT 2601 If you require further information please telephone: (02) 6289 9853/24 hr answering machine or email the enquiry to PrivateHealth@health.gov.au Internet: http://www.health.gov.au/internet/wcms/publishing.nsf/content/health-privatehealthproviders-circulars.htm Changing your e-mail address? longer want circulars? Please notify Private Health Insurance Branch at PrivateHealth@health.gov.au Private Health Insurance Branch

ATTACHMENT A HOSPITALS Is the hospital licensed in the relevant State / Territory? Is the hospital accredited (or actively working towards accreditation) by an appropriate accrediting body? Has the hospital been declared by the Minister under section 121-5(6) of the Private Health Insurance Act 2007? YES 1

ATTACHMENT A HEALTH CARE ORGANISATIONS Does the service require the organisation to be licensed in the State / Territory that the service is provided? Is the organisation providing the service licensed? Is the organisation providing the service accredited (or actively working towards accreditation) by an appropriate accrediting body? YES 2

ATTACHMENT A MEDICAL PRACTITIONERS Does the practitioner hold current registration with the registration board in the State / Territory they are practising? Does the medical practitioner meet the requirements as set out in the Health Insurance Act 1973? Does the service require that the practitioner s premises must be licensed in the relevant State / Territory in which they are practising? Is the practitioner a member of the society or association relevant to their speciality? Is the facility currently licensed in the relevant State / Territory? YES YES 3

ATTACHMENT A NURSES AND MIDWIVES Is the nurse or midwife registered with the registration board in the State / Territory they are practising? Is the nurse or midwife a member of the Royal Australian College of Nursing or the Australian College of Midwives? YES 4

ATTACHMENT A DENTISTS (incl. dental surgeons, hygienists, prosthetists and therapists) Is the dentists registered with the registration board in the State / Territory they are practising? Are the premises required to be licensed in the relevant State / Territory? Does the service require that the dentist s premises must be licensed in the relevant State / Territory in which they are practising? Is the dentist a member of one of the following: - Royal Australasian College of Dental Surgeons; - Australian Dental Association; - Dental Technicians Association of Australia; - Association of Dental Prosthetists; or - Australian Dental and Oral Health Therapists' Association? YES 5

ATTACHMENT A PODIATRIC SURGEONS Does the practitioner hold current registration with the Podiatric Registration board in the State / Territory they are practising? Is the practitioner licensed in the relevant State / Territory? Has the practitioner been declared by the Minister under section 3AAA of the Health Insurance Act 1973? Is the practitioner a Fellow (or eligible for Fellowship) of the Australasian College of Podiatric Surgeons? YES 6

ALLIED HEALTH PROFESSIONALS ATTACHMENT A Is the provider required to be registered in the State / Territory they are practising? Is the provider eligible for Medicare benefits? Is the provider registered? Is the provider a member or associate member of an organisation that is a member of Allied Health Professions Australia? YES 7

ATTACHMENT A NATURAL THERAPISTS AND HYPTHERAPISTS Is the provider required to be registered in the State / Territory they are practising? Is the provider registered? Is the provider a member of one of the following: Australian Natural Therapists Association Ltd; Australian Natural Acupuncture & Chinese Medicine Association Ltd; or Australian Hypnotherapists Association? YES 8

ATTACHMENT A AIDS / APPLIANCES Is the aid / appliance a medical device as set out in the Therapeutic Goods Act 1989? Is the medical device included on the Australian Register of Therapeutic Goods (ARTG)? Is the aid / appliance a custom made device as set out in the Therapeutic Goods Act 1989? YES Is the aid / appliance manufactured in accordance with Australian Standards? 9

Terminology ATTACHMENT B Accreditation means the granting of recognition for meeting designated health care industry standards for structure, process and outcomes, where outcome is the status of an individual, group of people or population which is wholly attributable to an action, agent or circumstance. The two conditions for accreditation are an explicit definition of quality (i.e. standards) and an independent review process aimed at identifying the level of congruence between practices and quality standards. Accrediting body means a body that is recognised to have authority to assess health services against agreed standards. This authority is gained through external assessment or recognition by an international government endorsed body. te: Although the Commission uses accreditation body, paragraph 121-5(7)(d) of the Act uses appropriate accrediting body and so the Rules must use the same terms. Appropriate accrediting body means an accrediting body that is recognised to have authority to assess health care services against agreed health care industry standards. Chronic disease management program means a program as defined in rule 10(2) of the Private Health Insurance (Health Insurance Business) Rules 2007. Clinical standards mean clinical standards that are generally developed by or in association with a relevant professional body and which are based on best practice and scientific evidence. Domestic assistance means assistance to a privately insured patient during a period of recovery from treatment for a disease, injury or condition. Hospitals means a facility for which a declaration under section 121-5(6) of the Private Health Insurance Act 2007 is in force. Hospital-substitute treatment means general treatment that substitutes for an episode of hospital treatment and is intended to manage a disease, injury or condition, as defined in the in section 69-10 of the Private Health Act 2007. Day hospital facility means premises that were a day hospital facility, within the meaning of the National Health Act 1953, immediately before 1 April 2007. These facilities are now taken to be hospitals for the purposes of the Private Health Insurance Act 2007. Standards means an agreed attribute or process designed to ensure that a health care product, service or method will be performed consistently at a designated level.

Private Health Insurance: Proposal for Quality Assurance Requirements for Privately Insured Services Executive summary As part of its commitment to improving the value of, the Australian Government announced on 26 April 2006 that a uniform quality and safety regime for all privately insured services will be introduced from 1 July 2008. From this date, insurers will only be permitted to pay benefits for privately insured services, if the services satisfy quality assurance requirements. It is envisaged that these quality assurance requirements will restrict the payment of private health benefits to privately insured services that are: provided by suitably qualified service providers; and provided by licensed facilities (as required by State and Territory law). t all services will have to be accredited. It is proposed that this requirement will only apply to the range of services the health care industry already self-regulates through accreditation. These new requirements will increase consumer confidence in and promote best practice throughout the industry. The affect on providers of services is illustrated in the flow charts at Attachment A. This paper outlines the Department of Health and Ageing s proposal for introducing the quality assurance requirements for privately insured services to health care industry providers. Its purpose is to promote discussions through a national stakeholder consultation process. This consultation will inform the development of the Private Health Insurance (Accreditation) Rules. The proposal is based on existing health care industry requirements, and the ongoing national initiatives to address quality assurance in health care, such as the Australian Commission on Safety and Quality in Health Care s work on national safety and quality accreditation standards. In developing this discussion paper, the feasibility of placing the same requirements and mandating accreditation for all providers, facilities and services has been carefully considered. This approach has not been adopted, because of concerns regarding the costs of accreditation, particularly for small and single provider practices, and also because of the limited evidence demonstrating the role that accreditation has in ensuring the delivery of quality health care. The proposal does not seek to impose new requirements or mandate accreditation for the actual providers of privately insured services. As far as possible, the proposal recognises the variety of requirements currently placed on providers, their facilities and their services and seeks to standardise them rationally. The paper proposes the incorporation of different licensing arrangements that apply in different jurisdictions. However, depending on further consultations with State and Territory governments and the industry, another approach may be to adopt a single national standard for licensing through the Rules.

Purpose The purpose of this paper is to outline proposed quality assurance requirements for privately insured services. This proposal has been developed based on: the Government s policy objectives; existing Commonwealth, State and Territory laws, professional recognition schemes and industry accreditation arrangements; and the Australian Commission on Safety and Quality in Health Care discussion paper on national safety and quality accreditation standards (vember 2006) and the submissions made in response to the discussion paper 1. This paper is intended to encourage stakeholder input on the preparation of Private Health Insurance (Accreditation) Rules 2 (the Rules) for quality assurance requirements for privately insured services. Industry feedback on this paper, together with national consultation forums to be held in July 2007, will form the basis for the drafting of the Rules. Terminology As the Commission s discussion paper highlighted, quality assurance terminology varies across the health care sector; often with terms such as accreditation and certification being used interchangeably. The Rules will contain definitions for a number of terms and the Commission s second strategy Standardise accreditation language and definitions is relevant to this aspect of the Rules. The definitions used in this paper and detailed in Attachment B will be revised as the work of the Commission on this strategy progresses. In defining terms, the preferred approach has been to avoid, wherever possible, naming individual standards and organisations, but rather describe them. This will ensure that the Rules: are flexible enough to accommodate the development and emergence of new standards and organisations without requiring constant amendment; and do not delay the payment of benefits for privately insured services provided in these circumstances. The proposed definitions have been drawn from the Commission's paper and stakeholder submissions. It is recognised that some the proposed definitions are not supported by organisations such as the Joint Accreditation System of Australia and New Zealand, which adhere to terminology used by the International Organization for Standardization and the 1 Discussion paper: National safety and quality accreditation standards, Australian Commission on Safety and Quality in Health Care, vember 2006 (http://www.safetyandquality.org/internet/ safety/publishing.nsf/content/ accreditation). 2 Division 81 of the Private Health Insurance Act 2007 provides that an policy meets the quality assurance requirements if it prohibits the payment of benefits for a treatment that does not meet the standards in the Private Health Insurance (Accreditation) Rules. The Minister may make Private Health Insurance Rules under section 333-20. 2

International Electrotechnical Commission 3, however they have been adopted by the Commission. The definitions in the Rules will be revised as the work of the Commission progresses. Introduction On 26 April 2006, as part of significant changes to, the Australian Government announced that it would introduce industry-wide safety and quality requirements to ensure that, from 1 July 2008, all privately insured services are provided by accredited and/or suitably qualified providers 4. The introduction of quality assurance requirements for privately insured services is not intended to specifically address any known occurrence of unsafe or poor quality health care delivery, or to set new standards, but rather to: give consumers confidence in the safety and quality of the services being covered by their health ; and promote best practice and quality assurance throughout the industry. There has never been, nor is there currently, a requirement for any privately insured services to meet safety and quality standards, or to be accredited. The only exception is if hospitals want to access second tier benefits, they must be accredited. However, most private hospitals are accredited because health insurers and medical indemnity insurers require it. The extent to which other health care organisations or providers are currently accredited, either because State or Territory licensing laws, health insurers or a relevant professional body requires it, has not been quantified. Quality assurance activities relevant to the development of the Rules There are a number of new and ongoing activities at the national level that address quality assurance in health care which are relevant to the preparation of the Rules. Declaration of hospitals for purposes Transitional arrangements 5 associated with the commencement of the Private Health Insurance Act 2007 (the Act) deemed hospitals and day hospital facilities (hospitals) 6 that were eligible for benefits under the National Health Act 1953 to be hospitals for the purposes of the Act, but only until 1 July 2008. 3 ISO/IEC 17000:2004 Conformity Assessment Vocabulary and general principles. 4 Media Release. Tony Abbott MHR, Minister for Health and Ageing, 9 May 2006 ABB064/06. 5 Section 15 Private Health Insurance (Transitional Provisions and Consequential Amendments) Act 2007. 6 Recognised hospitals (public), private hospitals and day hospital facilities. 3

These hospitals will need to be declared by the Minister for Health and Ageing (the Minister) under the Act 7 prior to 1 July 2008 to continue to be eligible for benefits. In declaring hospitals, the Minister will have regard to, amongst other things, whether accreditation requirements of an appropriate accrediting body 8 have been met. These accreditation requirements will be set out in the Rules. Australian Commission on Safety and Quality in Health Care The Commission is developing a national strategic framework and work program to improve safety and quality across the health care system i.e. in the public and private sectors. To that end, the Commission is reviewing accreditation arrangements and will recommend a national model for accreditation of health services across Australia. In vember 2006, the Commission released a discussion paper presenting an alternative model of accreditation in Australia. The discussion paper proposes 11 reform strategies to streamline and harmonise existing accreditation processes, five of which are directly relevant to the Rules (and which are discussed with the proposed quality assurance requirements later in this paper). The Commission will develop draft recommendations for consideration by Health Ministers in June 2007 and will report by December 2007. Council of Australian Governments (COAG) national registration scheme On 13 April 2007, COAG agreed to arrangements for a new national system (the Scheme) for registration of health professionals and the accreditation of their training and education programs for implementation by 1 July 2008. The Scheme will initially cover nine health professions: medical practitioners; nurses and midwives; pharmacists; physiotherapists; psychologists; osteopaths; chiropractors; optometrists and dentists (including dental hygienists, dental prosthetists and dental therapists). Once established, the registration and accreditation requirements specified under the Scheme can be incorporated in the Rules. Until then the Rules will draw on existing State and Territory registration requirements. Quality assurance requirements for access to Medicare benefits The Health Insurance Act 1973 and regulations impose quality assurance requirements on providers for their services to be eligible for Medicare benefits. These requirements centre on professional: training; recognition; association/membership; and registration. Additional requirements apply to their practices, either to attract higher rebates or additional payments for quality care. Pathology laboratories must be industry accredited to be eligible for Medicare benefits. The payment of Medicare rebates for providers of magnetic resonance imaging services is subject to industry accreditation against measures of professional expertise and eligible equipment. Benefits for nuclear medicine imaging services are also subject to industry 7 Section 121-5(6) 8 Appropriate accrediting body is defined in the terminology section at Attachment B. 4

accreditation against measures of professional expertise to ensure that specialists are appropriately trained, licensed, provide appropriate personal supervision of procedures and are involved in continuing medical education. From 1 July 2008, practices providing radiology services will need to be accredited or registered, to be eligible for Medicare benefits. It will not be necessary to duplicate all of these requirements in the Rules as the legislative framework already establishes clear links between the payment of Medicare benefits and private health benefits. However, it may be appropriate to mirror them for services for which a Medicare rebate is not payable, but are eligible to be covered by. Proposed quality assurance requirements for privately insured services In formulating the proposal for the Rules, the feasibility of placing exactly the same level of requirements on all providers, facilities and services was considered. The submissions to the Commission s discussion paper highlighted wide ranging views across the health care industry on the extent to which quality assurance requirements should apply equally to providers, facilities and the services themselves. In its discussion paper, the Commission proposes system wide accreditation of all health care services against safety and quality standards 9. This is supported by the private hospital sector, where accreditation is par for the course 10. However the Commission s proposal is opposed by other sectors who already comply with numerous State and Territory laws that, in their view, adequately protect public health and safety 11. Professional groups are concerned about the cost of accreditation, especially for smaller practices 12 and its use in the absence of clinically specific standards 13. They question the economic benefit of mandating accreditation beyond acute care settings where patients may be at risk of serious adverse outcomes, particularly in the absence of evidence that demonstrates that accreditation is better at achieving quality improvement than other lower level quality assurance activities 14. There was, however, consensus that the wider regulatory quality assurance environment is inefficient and wasteful because it contains duplication and there are many overlaps, both of 9 10 11 12 13 14 Strategy 5 in the Commission s discussion paper refers. Submission to the Australian Commission on Safety and Quality in Health Care's Discussion paper National Safety and Quality Accreditation Standards, Australian Private Hospitals Association. Submission to the Australian Commission on Safety and Quality in Health Care's Discussion paper National Safety and Quality Accreditation Standards, Australian Dental Association. Submission to the Australian Commission on Safety and Quality in Health Care's Discussion paper National Safety and Quality Accreditation Standards, Australian Association for Exercise and Sports Science Submission to the Australian Commission on Safety and Quality in Health Care's Discussion paper National Safety and Quality Accreditation Standards, Palliative Care Australia. Submission to the Australian Commission on Safety and Quality in Health Care's Discussion paper National Safety and Quality Accreditation Standards, Australian Medical Association. 5

which need to be reduced. The Rules do not aim to resolve these issues; this will be addressed as part of the work of the Commission. Instead, the Rules would be drafted to provide a flexible framework that reflects existing quality assurance requirements while recognising ongoing initiatives and being able to adapt to a dynamic environment where quality assurance is always improving. Further, the Rules will recognise existing requirements on providers, their facilities and services while concurrently aiming to standardise them. To do otherwise would impact on the industry in several ways: decrease the range of health care providers and services covered by this would not be in the public interest and would devalue the product at a time when the Government has implemented measures to expand the services that can be covered; place undue pressure on professional bodies and independent standards development bodies to quickly develop standards for providers and services where they do not already exist this may result in standards for standards sake and therefore not actually promote best practice in the long term; and place undue pressure on accrediting bodies to rapidly increase their conformity assessment activities. Further, while it is widely accepted that accreditation is an important factor in ensuring that appropriate systems are in place to deliver quality health care, sufficient evidence is not available to suggest that all providers should be accredited, as opposed to registered and/or licensed. Accreditation should be appropriate to the service being provided e.g. physiotherapists should not have to obtain the same accreditation as hospitals. The work of the Commission is the best avenue for addressing this. In particular, five of the Commission s proposed reform strategies seek to address these issues: 1. Register of accrediting bodies; 2. Standardise accreditation language and definitions; 5. System wide accreditation against safety and quality standards; 8. Registration of sets of health care standards; and 9. Harmonisation of health service standards. The Rules can be amended in the future to reflect the outcome of these strategies. Strategy 8 is of particular relevance to the Rules because it will enable clear delineation of which standards apply to which health services. 6

Aspects of the requirements Quality assurance in the health care sector can generally be attached to providers, the facilities in which services are provided and, in some cases, the services themselves. All three are variously regulated by Commonwealth and State/Territory laws (legal requirements): some may be assessed against industry accreditations standards (accreditation requirements) or managed by non-regulatory professional organisations (professional requirements). The Rules seek to standardise the requirements applicable to each of these three aspects: Providers The Rules need to ensure that privately insured services are provided by trained professionals who continue their education in the field in which they practice and who provide services according to best practice set by their peers. Existing State and Territory laws that require providers to be registered will be supplemented in the Rules. In addition, Commonwealth requirements that apply to providers eligible for Medicare benefits, will be extended to apply to professional services not covered by Medicare. Membership of professional peer groups is essential for providers in terms of continuing their professional development and ensuring their clinical practice is current and evidence based. Many of these professional groups develop standards that providers can either voluntarily observe, or be assessed against by the peer group or an accrediting body. Facilities The Rules need to ensure that privately insured services are provided in appropriate facilities using equipment that is safe and effective, taking account that the point of delivery for some services can be in locations that are not always used for health care delivery, such as in hotels or a person s home. State and Territory laws that restrict services to licensed facilities will continue to operate. It is recognised that State and Territory licensing requirements may be supported by comprehensive and enforceable codes developed to minimise the public health risks associated with the operation and management of facilities that provide prescribed medical and dental procedures. Under these codes, the licensee of a facility may be required to develop and maintain systems of continuous quality improvement and assurance; make specified annual reporting publicly available; establish and maintain critical systems in the event of primary equipment failure; meet specified information management systems; disclose specified incidents; and develop and maintain emergency procedures. As is the case in the ACT, licensing fees may vary depending on accreditation in recognition that licensing non-accredited facilities involves the cost of auditing the facility and fully administering the code 15. The Rules will not override these requirements but may supplement them. Where no such requirement exists, the Rules may set a requirement for accreditation. 15 ACT Health Care Facilities Code of Practice 2001, ACT Department of Health, Housing and Community Care. 7

Services To some extent the combination of trained professionals providing services in accredited facilities ensures a quality service. However, in some cases, e.g. telephonic support programs, the site of delivery is irrelevant and the way the service is delivered is important. Accreditation of the service is paramount because quality assurance through the combination of provider/facility quality assurance cannot be achieved. The proposed requirements It is proposed that quality assurance requirements in the Rules be specified by provider, and to categorise the providers as follows: hospitals (including day hospital facilities); health care organisations; medical practitioners; nurses and midwives; dentists; allied health professionals and natural therapists. Quality assurance requirements are also proposed for aids and appliances. Flow charts for each of the providers have been developed, primarily to illustrate the three aspects of quality requirements that may apply to each provider (i.e. legal, accreditation and professional) (Attachment A). Hospitals For hospitals, the Rules will require: premises are licensed in the State or Territory that the service is provided, if required*; accreditation (or the hospital to be actively working towards accreditation) with an appropriate accrediting body; and they are declared a hospital by the Minister. *It is unclear if jurisdictional licensing requirements apply to all hospitals. Industry advice is requested to clarify this. Due to the current requirements which health insurers place on hospitals, most private hospitals will already be eligible to apply to the Minister to be declared a hospital for the purposes of benefits. This includes services provided outside the hospital and chronic disease management programs. Health care organisations The quality assurance requirements for health care organisations detail the requirements applicable to organisations that coordinate and manage the provision of hospital-substitute treatment, chronic disease management programs for people with diagnosed chronic disease and prevention programs for those at risk of developing chronic disease, and domestic assistance 16. For health care organisations, the Rules will require: premises are licensed in the State or Territory that the service is provided, if required; and accreditation (or the organisation to be actively working towards accreditation) with an appropriate accrediting body. 16 Domestic assistance is defined in the terminology section at Attachment B. 8

Mandating accreditation of health care organisations ensures that services provided as hospitalsubstitute treatment and chronic disease management programs, will be subject to the same quality assurance requirements that they would be if provided by a hospital. Medical practitioners The Rules for medical practitioners will detail the requirements applicable to individual practitioners providing privately insured services. For medical practitioners, the Rules will require: registration with the medical board in the State or Territory in which they are practicing; they meet the requirements as set out in the Health Insurance Act 1973; premises are licensed in the State or Territory that the service is provided, if required; and membership of the national society or association relevant to their specialty*. It is recognised that, depending on the State or Territory in which they practice, medical practitioner s premises may not be subject to any existing licensing requirements. This issue will be further considered throughout the national stakeholder consultation process to develop the Rules. * Advice is requested from industry about those national societies or associations that should be included in the Rules. Nurses and midwives Nurses and midwives will be considered together in line with the professional groups specified under COAG s national registration scheme. For nurses and midwives, the Rules will require: registration with the relevant registration board in the State or Territory in which they are practicing; and membership of the Royal Australian College of Nursing or the Australian College of Midwives*. * Advice is requested from industry about those additional national societies or associations that should be included in the Rules. Dentists (including dental surgeons, hygienists, prosthetists and therapists) Requirements for dentists will be set with reference to dental hygienists, dental prosthetists and dental therapists in line with the professional groups specified under the COAG National Registration Scheme. For dentists, the Rules will require: registration with the Dental Board in the State or Territory in which they are practicing; premises are licensed in the State or Territory that the service is provided, if required; and membership of the: o Royal Australasian College of Dental Surgeons; o Australian Dental Association; 9

o Dental Technicians Association of Australia; o Association of Dental Prosthetists; or o Australian Dental and Oral Health Therapists' Association*. * Advice is requested from industry about those additional national societies or associations that should be included in the Rules. Podiatric surgeons The Rules for podiatric surgeons reflect the current requirements applicable to practitioners under the Private Health Insurance (Prostheses) Rules 2007 and the Health Insurance (Accreditation of Podiatric Surgeons) Guidelines under the Health Insurance Act 1973. For podiatric surgeons, the Rules will require: registration with the Podiatry Registration board in the State or Territory in which they are practicing, if required by law; or premises are licensed in the State or Territory that the service is provided, if required; they are declared by the Minister; and Fellowship (or be eligible for Fellowship) with the Australasian College of Podiatric Surgeons. Allied health professionals For allied health professionals, the Rules will require: registration with the appropriate board in the State or Territory in which they are practicing, if required by law; and they are an eligible provider as set out in the Health Insurance Act 1973; or membership of an organisation that is a member or associate member of Allied Health Professions Australia (AHPA)*. * Advice is requested from industry about those additional national societies or associations that should be included in the Rules. The Rules reflect the wide range of allied health services that are currently available to privately insured patients. This covers allied health professionals recognised by Medicare under the Health Insurance Act 1973 17 as well as those providers whose professional society or organisation is a member or associate member of the AHPA 18. Natural therapists (including acupuncturists and hypnotherapists) Hypnotherapists will be considered together with natural therapists, including acupuncturists. For natural therapists, the Rules will require: registration with the appropriate board in the State or Territory in which they are practicing, if required by law; and membership of the of the: 17 18 Rule 10(2) of the Private Health Insurance (Health Insurance Business) Rules 2007 lists those providers recognised as allied health services for the purposes of Medicare. A list of members and associate members of the AHPA are found at: http://www.ahpa.com.au/links.htm 10

o Australian Therapists Association Ltd; o Australian Acupuncture & Chinese Medicine Association Ltd; or o Australian Hypnotherapists Association*. * Advice is requested from industry about those additional national societies or associations that should be included in the Rules. It is unclear if any jurisdictional licensing requirements apply to the premises from which natural therapists provide services. Industry advice is requested to clarify this. Aids and appliances For aids and appliances, the Rules will require: where the aid or appliance is a medical device as defined in section 41 BD of the Therapeutic Goods Act 1989, it must be included on the Australian Register of Therapeutic Goods; or where the aid or appliance is not a medical device, it meets the definition of custom made as set out in the Therapeutic Goods Act 1989; or where the aid or appliance is not a medical device or custom made as defined in the Therapeutic Goods Act 1989, it is manufactured in accordance with Australian Standards 19. The timeline for consultation and making the Rules The Department is seeking constructive feedback on any shortcomings of the proposal and specific suggestions for addressing them, and other ways of improving the proposed arrangements, bearing in mind the proposal is intending to capture existing arrangements. June 2007 Written submissions in response to the proposal will be accepted until close of business 27 June 2007. The Australian Commission on Safety and Quality in Health Care is scheduled to submit draft recommendations to Health Ministers in June 2007. The Department will meet with State and Territory health authorities to discuss the impact of the proposal relevant to their respective jurisdictions. July 2007 The Department will hold industry consultation forums in Perth, Adelaide, Brisbane, Sydney and Melbourne during July. The dates will be confirmed in the coming weeks. August/September 2007 Draft rules will be prepared taking account of written submissions and industry consultation. The draft will be circulated to industry for comment at the end of September. 19 Standards Australia 11

October 2007 Written comments from industry on the draft rules are to be submitted by mid October. vember 2007 The Rules will be finalised and submitted to the Minister in early vember. December 2007 The Rules will be made. The Commission will submit its final report to Health Ministers. 1 July 2008 The Private Health Insurance (Accreditation) Rules 2008 will commence. Submissions Written submissions from the health care industry on the proposed quality assurance requirements will be accepted until close of business Wednesday 27 June 2007. Submissions can be sent to privatehealth@health.gov.au or to: Sharon Simons Private Health Insurance Branch, MDP 86 GPO Box 9848 CANBERRA ACT 2601 12