Australian Competition and Consumer Commission - Submission … submission... · AssOCiation, Australian and New Zealand College of Perfusionists, Chiropractor's Association of Australia,

AHPA ALLIED HEALTH PR OFESSI ONS AUSTRALIA ABN 60 083 141 664

The Peak Body Representing Allied Health in Australia Incorporating AHPARR ( Rural & Remote)

Bruce Cooper Intelligence, Infocentre and Policy Liaison Branch Australian Competition and Consumer Commission GPO Box 3131 CANBERRA ACT 2601 or ph i [email protected]

Tuesday 25th September 2012

Re: ACCC Report to Senate on Private Health Insurance

Allied Health Professions Australia (AHPA) welcomes the ACCC's inquiry into the perceived lack of recognition of certain allied health care providers by health funds and its invitation for submissions from the allied health professions.

AHPA is the peak body for the allied health professions in Australia with 15 national associations as Member Organisations. Collectively, these organisations with their members in public, private, rural and regional services across Australia, work together to provide an effective voice for over 55 000 allied health professionals in

. Australia. AHPA role is to represent and advocate for the role of allied health professionals in Australia, providing unified and effective advice to government and key stake holders to improve th~ health and wellbeing of all Australians.

A number of the national allied health associations have made very detailed submissions to the ACCC. Thus in this submission AHPA has limited its comments to 'an overview of the concerns of allied health professionals about the unacceptable discrepancies by Private Health Insurers (PHI) in the services and providers they recognize and the impact this has on consumers as well as on the affected allied health providers.

1. Allied health providers offering same/similar services as others but not recognized by PHI

Detailed information has been submitted which highlights the discrepancies! discrimination experienced by various allied health professions, where the first mentioned profession below is not rebated:

Members: Audiological Society of Australia, Australasian Pod iatry CounCil, Austra lian Association of Social Workers, Austral ian Orthotic Prosthetic Association, Australian Osteopathic Association , Australian Psychologica l Society, Austra lian Sonographers AssOCiation, Australian and New Zea land College of Perfusion ists, Chiropractor's Association of Austral ia, Dietitians Association of Australia, Exercise and Sports Science Austral ia, Occupational Therapy Australia, Orthoptics Aust ralia, Society of Hospita l Pharmacists of Austra lia, Speech Pathology Australia . Associates: Australian Diabetes Educators Associati.on, Austra lian Association of Practice Managers .

PO Box 38, Flinde rs Lane VIC 8009 • Ph: + 61 3 866 2 6620 • Fa x : +6 1 3 9663 6177 Email: off [email protected] • Webs ite : www .ahpa.com.au

• In the provision of the same/similar clinical services: o Clinical perfusionists managing cardiopulmonary bypass same as

medical perfusionists; o Orthotist/prosthetists assessing and providing clinical interventions

same as Podiatrists, Physiotherapists, Occupational Therapists; o Clinical psychologists recognized over other psychologists providing

significant clinical services such as neuropsychology, counselling. • In the provision of same/similar custom made appliances:

o Orthotist/prosthetists provision of various orthotic devices and clinical services in the same manner as podiatrists

o Occupational therapists provision of customized hand splints.

2. Reasons given for lack of recognition .

Most PHis specify the requirement that a practitioner is registered as a Medicare provider. A major anomaly exists for Orthotist/Prosthetists who are the only health care providers who can assess, prescribe and supply orthotic devices for the entire body. As the profession has yet to gain recognition through Medicare, people requiring orthotic/prosthetic services are financially impacted through out of pocket expenses. The AOPA submission provides detailed information on the inequities where orthoses can be provided by other non-Medicare recognized practitioners, such as Pedorthists.

AHPA would ask the ACCC in its review of the reasons for lack of recognition of providers by various PHI, to ensure that registration under the National Registration and Accreditation Scheme is not inappropriately specified as a requirement for recognition. This may unintentionally discriminate against those evidence based allied health ' professions who self regulate their professions (Audiology, Clinical Perfusion, Dietetics, Exercise Physiology, Social Work, Sonography, Speech Pathology, Orthotics and Prosthetics). Regulation under the National Registration and Accreditation Scheme is related to the level of risk to the public and consumer and is concerned with consumer protection. It does not define professionalism, competencies or qualifications and should have no bearing on the recognition of a profession's services by private health insurers.

3. Competitive disadvantage

Competitive disadvantage occurs across a number of professions where one provider is rebated and another equally qualified and skilled provider is not for the same clinical service or appliance. This has a significant impact on the business aspects of the discriminated provider's practice and the profession as a whole. The detail surrounding this disadvantage has been outlined by a number of the allied health submissions.

4. Impact on consumers

The lack of recognition of an allied . health provider for the provision of service or an appliance either distributes the full financial burden to the individual consumer or denies them access to the required treatment and intervention: This is of concern to

many allied health professionals and their consumers and includes situations where PHis do not cover:

• non-PBS medicines or professional pharmacy services in private hospitals • home based occupational therapy interventions • consultation with parents in regards to their developmentally delayed child • psychology services which are not under a mental health plan, but address

important issues such as obesity • assistive devices such as hoists, wheelchairs, bathing aids • Orthoses for the entire body to support function, mobility, and independence.

AHPA is aware of and supports the submissions made by its Member Organisations being, the Australian and New Zealand College of Perfusionists, Australian Orthotic Prosthetic Association, Australian Psychological Society, Occupational Therapy Australia and the Society of Hospital Pharmacists of Australia . .

AHPA looks forward to the ACCC's Report and the Senate's response to the issues raised, which may lead to fairer treatment of allied health providers and their consumers by the private health insurers.

Yours sincerely,

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