December 8, 2017 Private Hospitals Unit Commissioning ... · The medical specialty of anaesthesia is critical to the provision of safe, effective anaesthesia and perioperative care

December 8, 2017

Mr Victor Di Paola Manager, Private Health Services Regulation Private Hospitals Unit Commissioning Performance and Regulation Department of Health and Human Services 50 Lonsdale Street Melbourne VIC 3000 Email: [email protected]

Dear Mr Di Paola

Re: ANZCA submission to Update to Health Services Regulations 2013 discussion paper

Thank you for the opportunity to provide feedback on the Update to Health Services (Private Hospitals

and Day Procedure Centres) Regulations 2013 discussion paper.

The Australian and New Zealand College of Anaesthetists (ANZCA), including the Faculty of Pain

Medicine (FPM), is committed to high standards of clinical practice in the fields of anaesthesia,

perioperative medicine and pain medicine. As the education and training body responsible for the

postgraduate training programs of anaesthesia and pain medicine for Australia, New Zealand and parts

of Asia, ANZCA is committed to ongoing continuous improvement, promoting best practice, and

contributing to a high quality health system.

The medical specialty of anaesthesia is critical to the provision of safe, effective anaesthesia and

perioperative care for patients. Fostering safe and high quality patient care in anaesthesia,

perioperative medicine and pain medicine is ANZCA’s mission, and as such the College supports any

initiative that will serve this aim.

Overall, ANZCA supports the intent of the proposed changes to the Health Services Regulations. Of

particular importance is the requirement that any procedure involving the administration of general

anaesthesia, major regional anaesthetic blocks, intravenous sedation or high doses of local anaesthetic

be undertaken in a registered facility.

While patient safety and quality of care must take precedence over any potential negative outcomes, it

is acknowledged that there is a risk that these proposed changes to the regulations may reduce access

to care for some services if not carefully managed. ANZCA is concerned to ensure that strategies make

certain that patients, particularly those on low incomes, are not unduly disadvantaged by the proposed

changes.

ANZCA broadly supports aligning the governance and data reporting requirements for private hospitals

and day procedure centres with those of public hospitals, acknowledging however that this will not be

without associated costs and some smaller facilities, particularly sole owner operated sites, will require

support to transition.

More detailed feedback on each of the issues raised in the discussion paper is contained in the attached

submission.

Thank you for the opportunity to provide feedback to the department on this important consultation paper

and naturally the College is happy to provide further advice on the issues raised. Should you require any

further information in relation to this submission, please contact Jo‐anne Chapman, General Manager

Policy, Safety and Quality via email [email protected] or telephone (03) 8517 5341.

Yours sincerely

Dr Phillipa Hore

Chair, Safety & Quality Committee

Australian and New Zealand College of Anaesthetists

mailto:[email protected]

Accreditation Submission 2012 A

Department of Health and Human Services (Victoria)Update to Health Services (Private Hospitals and Day Procedure Centres) Regulations 2013: discussion paper

December, 2017

To serve the community by fostering safety and high quality patient care in anaesthesia, perioperative medicine and pain medicine.

Table of contents

About ANZCA 3

About FPM 4

ANZCA response to consultation questions 5

Definition of prescribed services and admission 5

Speciality health services 6

Governance 9

Data 14

Fees 17

Conclusion 18

Contact details 19

Australian and New Zealand College of Anaesthetists - December 2017

Update to Health Services (Private Hospitals and Day Procedure Centres) Regulations 2013: discussion paper Page 3

About ANZCA

The Australian and New Zealand College of Anaesthetists (ANZCA) is the professional organisation for specialist anaesthetists (Fellows) and specialist anaesthetists in training (trainees) in Australia and New Zealand.

This year, ANZCA celebrates its 25th anniversary as a medical college though its history stretches back 65 years to when it was established in 1952 as a faculty of the Royal Australasian College of Surgeons.

ANZCA is now a world-renowned institution in anaesthesia and pain medicine that has taken a leading role in many areas of anaesthesia, pain medicine and intensive care medicine. These include:

Being recognised as a world leader in the treatment of pain by establishing the specialty of pain medicine through its Faculty of Pain Medicine.

Setting high professional standards for patient safety through professional documents and other advocacy activities.

Answering key questions in medical research by recruiting more than 30,000 patients to help with $A25 million worth of studies for the ANZCA Clinical Trials Network and other research through the ANZCA Research Foundation, which in 2017 alone is funding research worth $1.7 million.

Training highly skilled future Fellows in anaesthesia and pain medicine.

Hosting more than 30 medical education events annually including the College’s flagship event, the ANZCA Annual Scientific Meeting.

Supporting anaesthesia in developing nations such as Papua New Guinea with clinical and educational visits, and the seeding of the Essential Pain Management program now being taught in 47 countries.

Establishing intensive care medicine as a specialty by instituting training and accreditation programs through a joint Faculty of Intensive Care, and then by helping found the College of Intensive Care Medicine of Australia and New Zealand.

ANZCA, including FPM, is committed to high standards of clinical practice in the fields of anaesthesia, perioperative medicine and pain medicine. As the education and training body responsible for the postgraduate training programs of anaesthesia and pain medicine for Australia, New Zealand and parts of Asia, the College believes in ongoing continuous improvement and strives to ensure that its programs represent best practice and contribute to a high quality health system.

ANZCA's mission is to serve the community by fostering safety and high quality patient care in anaesthesia, perioperative medicine and pain medicine. From this mission flows three major objectives:

To promote professional standards and patient safety in anaesthesia, perioperative medicine and pain medicine.

To promote training and education in anaesthesia, perioperative medicine and pain management.

To advance the science and practice of anaesthesia, perioperative medicine and pain management.

ANZCA Fellows and trainees

There are 1245 ANZCA Fellows and 303 trainees located in Victoria. Australia-wide there are 4541 active and 669 retired Fellows and 1248 trainees, whilst there are 783 Fellows (of whom 83 are retired) and 252 trainees in New Zealand (figures as at June 30, 2017).



About FPM

The Faculty of Pain Medicine (FPM) is the professional organisation for specialist pain medicine physicians (Fellows) and specialist pain medicine physicians in training (trainees).

The Faculty is responsible for the training, examination and specialist accreditation of specialist pain medicine physicians and for the standards of clinical practice for pain medicine in Australia and New Zealand. Formed in 1998, the Faculty is the first multidisciplinary medical academy in the world to be devoted to education and training in pain medicine. Although part of ANZCA, the Faculty's fellowship and representation remains multidisciplinary at all levels. It arose out of collaboration between five participating bodies – ANZCA, the Royal Australasian College of Physicians (RACP), the Royal Australasian College of Surgeons (RACS), the Royal Australian and New Zealand College of Psychiatrists (RANZCP) and the Australasian Faculty of Rehabilitation Medicine (AFRM) of the RACP.

In 2005, the discipline was recognised in Australia as a medical specialty in its own right and was accredited as a scope of practice in New Zealand in 2012. This recognises the importance of the problem of unrelieved pain in the community and the need for a comprehensive medical response through education, training and practice.

The field of pain medicine recognises that the management of severe pain problems requires the skills of more than one medical craft group. Such problems include:

Acute pain (post-operative, post-trauma, acute episodes of pain in "medical conditions").

Cancer pain (pain directly due to tumour invasion or compression, pain related to diagnostic or therapeutic procedures, pain due to cancer treatment).

Persistent (chronic) pain (including over 200 conditions described in the International Association for the Study of Pain (IASP) Taxonomy of Chronic Pain 2nd Edition, such as phantom limb pain, post-herpetic neuralgia, mechanical low back pain). Chronic pain affects one in five Australians.

In Australia and New Zealand, a career in pain medicine is generally obtained by qualifying as a Fellow of the Faculty of Pain Medicine, Australian and New Zealand College of Anaesthetists (FFPMANZCA). Pain specialist training is also open to vocationally registered general practitioners and other specialists.

Fellows of FPM have a wide knowledge of the clinical, sociopsychobiomedical and humanitarian aspects of pain and are well placed to follow a developing and challenging career path.

Last year, world recognition for the Faculty was achieved through the awarding of the 2017 American Academy of Pain Medicine’s (AAPM) Robert G. Addison, MD Award given in recognition of outstanding efforts to foster international co-operation and collaboration on behalf of the specialty of pain medicine. The European Pain Federation is now also using FPM’s revised curriculum as the basis for its diploma.

FPM Fellows and trainees

There are 71 FPM Fellows and 17 trainees in located in Victoria. Australia-wide there are 317 active and 23 retired FPM Fellows and 63 trainees, whilst there are 38 Fellows (of whom 7 are retired) and 11 trainees in New Zealand (figures as at June 30, 2017).

http://www.racp.edu.au/

http://www.surgeons.org/

http://www.ranzcp.org/

http://www.ranzcp.org/

http://www.racp.edu.au/about/racps-structure/australasian-faculty-of-rehabilitation-medicine

http://www.racp.edu.au/about/racps-structure/australasian-faculty-of-rehabilitation-medicine



ANZCA response to consultation questions

Definition of prescribed services and admission

1. What are the merits and disadvantages of the proposed definitions of medical health services, surgical health services, or speciality health services?

The proposed definitions of medical health services, surgical health services and speciality health services appear sound. Including the use of general anaesthesia, major regional blocks, intravenous sedation or high doses of local anaesthesia in the definition of medical and surgical health services should capture all current and future procedures that carry a moderate to severe risk. The proposed definitions will not impact on access to low risk or minor procedures.

With regards to requiring the post-operative observation of patients by nursing staff in the definition of surgical health services, a potential disadvantage is that this important practice may be avoided in order to circumvent regulation.

2. What are the merits and disadvantages of the Queensland definition of diagnostic, surgical or other procedures?

The Queensland definition of diagnostic, surgical or other procedures is considered too broad and subjective. Judging the level of risk that a given procedure may require resuscitation in certain patients with complications is not straightforward. This definition may inadvertently capture minor procedures in high risk patients, and on the other hand may lead to ‘moderate risk’ procedures being performed in unregistered facilities. Furthermore, there are many adverse events with the potential to have a significant impact on the patient but fall short of requiring resuscitation.

3. Does this definition adequately define emergency stabilisation treatment?

The proposed definition of emergency stabilisation treatment is adequate. While emergency stabilisation is not a surgical procedure as such, emergency treatment will occasionally involve the use of anaesthesia.

4. What is a suitable definition for admission?

ANZCA concurs that admission of patients should be removed as a criterion for registration as a private hospital or day procedure centre however ANZCA is unable to comment on the minimum requirements of a definition for admission in the Regulations.



Speciality health services

5. Are these proposed changes the correct ones? Are there services that should not be removed, or services not listed that should be added to the list of prescribed services?

The proposed list of speciality health services and removals and additions to the lists appear reasonable. As noted in the discussion paper, the actual or perceived levels of risk associated with procedures can change over time and consideration should be given to a regular review of the list.

6. Does a change in the list of prescribed services create access to care issues? If so, how should these be addressed?

While it is likely there will be some changes in access to care as a result of the proposed changes to the list of prescribed services, these amendments will improve the safety and quality of care provided. The department may consider the development of clear, easy-to-understand patient education materials explaining the changes and the rationale (i.e. safer and higher quality care) which can be made available to relevant facilities such as general practitioners’ surgeries and day procedure centres.

The department should also monitor access to care following the transition period and ensure that patients, particularly those on low incomes, are not disadvantaged by these changes.

7. Are the proposed definitions for any of the services (currently prescribed or proposed) accurate? If not, how should they be amended?

ANZCA does not have any suggestions for amendments to the proposed definitions of prescribed speciality health services.

8. Should paediatrics be added to the list of prescribed services?

ANZCA concurs that it would be appropriate to add paediatric services to the list of prescribed speciality health services, however notes that defining an upper age band has, and continues to be, a source of debate.

9. What would be the impacts on businesses currently providing alcohol and other drug withdrawal (detoxification) services?

Patients at high risk during the acute phase of withdrawal from alcohol or other drugs often present in hospital emergency departments (and hence are treated in a registered facility) or else present to other services as an emergency case requiring emergency stabilisation treatment. ANZCA is unable to comment on the impact of including detoxification services to businesses providing these services.

10. Would regulating alcohol and other drug withdrawal (detoxification) services cause any issues with access to care?

As per the response to Q.6, these changes are likely to lead to some changes in access to care however this must be considered in the context of improvements to patient care. Patients withdrawing from alcohol and other drugs can potentially be a risk to themselves or bystanders and should be treated in appropriately staffed and resourced facilities.



11. Is it appropriate to require liposuction (200 ml or more of lipoaspirate) to only be carried out in registered facilities?

Liposuction involving 200 ml or more of lipoaspirate should only be carried out in registered facilities. This is strengthened and may also be captured in the local anaesthetic dosage limitations.

12. Is the 200 ml threshold appropriate to manage patient safety risks or should another level be set?

The key issue is the volume of lipids that can be aspirated tolerably using only low dose local anaesthesia. This will vary between individuals however a 200 ml lipoaspirate threshold is reasonable. A more stringent threshold for consideration would be that any facilities performing liposuction must be registered unless performing procedures removing less than 200 ml of lipoaspirate from the head or neck areas only. As per the response to Q.11, local anaesthetic dosage limitations may also strengthen the thresholds surrounding this procedure.

13. Is it reasonable to require that births take place in a registered facility (with the exception of those taking place in the home of the mother or a relative) to ensure patient safety? Would this cause any issues with access to care?

It is reasonable to require that births take place in a registered facility with the exception of births in the home of the mother or a relative. Any negative impact on access to care as a result of this requirement is likely to be minimal and should be considered in the context of improved patient care.

14. Should laser eye surgery be regulated? If not, what is the safety risk to patient care?

ANZCA is unable to comment on the proposal to remove laser eye surgery from the speciality services list.

15. Should general medical practitioners and dental practices specifically be excluded in the Regulations if they are undertaking minor procedures with local anaesthesia?

ANZCA concurs with the proposal to specifically exclude general medical practitioners and dental practices in the Regulations if they are undertaking minor procedures with low dose local anaesthesia. The Regulations should specify that this exclusion only applies to minor procedures utilising low dose local anaesthesia.

16. Will the proposed Regulations diminish patients’ access to care?

As has been noted, it is possible that the proposed changes will lead to some diminished access to care. Mitigating this however it is noted that:

the proposed changes will lead to overall safer and higher quality patient care;

the department has indicated that there will be an appropriate transition period for compliance with the new regulations; and

appropriate patient educational materials and resources for facilities should be developed to support the introduction of the revised regulations.



17. Is the proposal to regulate anaesthesia and sedation as described above targeted at the right level to ensure patient safety without impeding procedures that can safely be done in practices?

ANZCA believes that the proposal to regulate anaesthesia and sedation as outlined in the discussion paper represents an appropriate balance between ensuring patient safety without impeding procedures that can be safely performed in practices. The overarching principle must be that the same safeguards apply to a patient having any procedure under intravenous sedation or any type of anaesthesia (excluding low dose local anaesthesia).

18. What are the types of mobile services likely to emerge and what are the minimum patient safety and quality of care measures that should be stipulated for these mobile businesses?

ANZCA is unable to comment on the types of mobile services that may emerge in the future although agrees that mobile chemotherapy services are likely. Minimum patient safety and quality of care measures that such businesses must adhere to must be comparable to those of any registered facility.

19. What is the likely impact as a result in regulation both in terms of cost to the patient, change of access to services by patients and impact on existing businesses not currently regulated by the department (for example, dental clinics, interventional radiology clinics)?

Regulation of both mobile services and currently unregistered businesses is likely to result in some increased costs to these businesses and, depending on the particular business or sector, these costs may or may not be passed on to patients. There may also be, as has been noted in response to other questions above, a reduction in access to some services and this may also impact some businesses’ revenue and costs. Patient safety and quality of care however must outweigh these potential negative outcomes of the proposed changes to the regulations.



Governance

Facility governance

20. Does the definition of by-laws correctly characterize their purpose?

ANZCA has no comments in relation to the definition of by-laws as outlined in the discussion paper.

21. Is this approach to tasking the highest level of governance with regulatory responsibility reasonable?

The approach of tasking the highest level of governance with regulatory responsibility is reasonable. This requirement, and the need for such a governance membership to contain at least one independent clinician, is however likely to prove onerous for smaller facilities, particularly those that are single owner operated. While not suggesting that such facilities should be excluded from these governance requirements, strategies to support their compliance should be considered.

22. What would be an appropriate meeting frequency for the highest level of governance in small facilities and large facilities?

Quarterly meetings would be an appropriate frequency for the highest level of governance, more frequently as required in larger facilities.

23. Are the requirements listed above sufficient to maintain adequate governance with the view to ensuring patient safety across the sector?

In addition to ensuring the highest level of governance membership contains at least one independent clinician, membership requirement should also address any conflicts of interest.

24. Could the interests of the patient be ensured through the proposed highest level of governance, without an independent member? In the case of small facilities, particularly single owner operators, is it too onerous to ask for an independent member to be included as part of the highest level of governance? If so, how could the integrity of the decisions of the highest level of governance be ensured? For example, could a small facility partner with a larger facility for governance matters? Is it practical for small facilities to establish a peer group where mutual support could be provided?

As noted in the response to Q.21, the requirement for an independent member to be included as part of the highest level of governance is likely to be challenging for some smaller facilities, particularly those that are single owner operated. However there does need to be a mechanism for independent oversight of all facilities.

Partnering with a larger facility for governance matters is one option available to small facilities, however this can prove challenging in practice for competitive reasons. In time, it is possible that private businesses will evolve to provide facility governance services in much the same way as accreditation and safety and quality services are currently offered.

More broadly in relation to facility governance matters, ANZCA believes that consideration should be given to establishing the governance standard rather than prescribing how each facility should implement governance.



Clinical governance

25. Should the Director of Nursing have at least five years of clinical practice and at least 12 months’ experience in nursing management? If not, how much experience is necessary and why?

A minimum of five years of clinical practice and 12 months experience in nursing management is appropriate for Directors of Nursing as significant experience is required to understand the complex interactions of governance, communication, leadership and clinical exposure.

26. What other options would offer assurance that Directors of Nursing have sufficient experience to oversee appropriate clinical management of patient care?

In the longer term, evidence of relevant training, experience and competency-based certification would represent an appropriate goal.

27. Should proprietors be responsible for ensuring a senior clinical nurse with suitable training and competence in the procedures being undertaken is designated as responsible for clinical oversight whenever a list is run, and while stage one post-operative patient care is provided?

ANZCA agrees that proprietors should be responsible for ensuring that a suitably trained and competent senior clinical nurse is designated as responsible for clinical oversight whenever a list is run, and while stage one post-operative patient care is provided. This is absolutely essential in those facilities where there may be no on-site medical practitioner in attendance.

28. Should the highest level of governance of each registered facility in Victoria have oversight and responsibility for the facility’s credentialing and scope of practice policy or by-laws for medical practitioners who provide services at the facility?

ANZCA agrees that the highest level of governance of each registered facility should have oversight and responsibility for the facility’s credentialing and scope of practice policy or by-laws for medical practitioners who provide services at the facility.

29. If the highest level of governance is not the appropriate level, which level of governance would be appropriate to carry this responsibility (bearing in mind that the requirement will need to apply from sole practitioner operated facilities up to large hospitals and national/international organisations)?

Not applicable in light of response to Q28. Where Boards or CEOs are responsible for multiple sites, it may be appropriate to delegate oversight to the highest level of governance at each separate facility.

30. Is the proposed ongoing process for credentialing medical practitioners, and defining their scope of practice useful/necessary to maintain patient safety?

The proposed processes in the discussion paper for credentialing medical practitioners and defining their scope of practice are reasonable and appropriate.



31. Should by-laws govern the actions of all credentialed medical practitioners while on site at a private hospital or day procedure centre? Should this be the responsibility of the proprietor of the facility to ensure? Please suggest alternative mechanisms.

ANZCA supports the intent of governing the actions of credentialed medical practitioners while on site at a private hospital or day procedure centre through by-laws. However in practice, having different sets of by-laws at different facilities will place a burden on practitioners to remain informed and up to date of the by-laws at multiple facilities. Consideration should be given to developing a core set of by-laws that have a direct impact on patient safety and quality of care.

32. How should a hospital or day procedure centre ensure admission staff and theatre staff are informed of a medical practitioner’s scope of practice and are able to use that information to ensure the practitioner operates within their defined scope?

Information about medical practitioners’ scopes of practice should be available to relevant staff and the clinical governance team in an easily accessible format such as an electronic record. Any queries or concerns of admission or theatre staff regarding a practitioner’s scope of practice should be directed to management. Management must ensure that admission and theatre staff are aware of the appropriate processes and procedures should they have any concerns regarding a practitioner’s scope of practice.

33. Should the Regulations require that every admission be cross checked against the medical practitioner’s scope of practice?

Requiring that every admission is cross checked against the medical practitioner’s scope of practice is likely to prove too onerous and time-consuming to become a standard admissions procedure. A practical compromise would be to require a cross check when the medical practitioner is new to the facility or an existing practitioner is performing a new procedure.

34. What options are there for addressing the issue of theatre nurses being informed of the scope of practice of medical practitioners and for reporting those practitioners who operate beyond their defined scope?

As per the response to Q.32, information about medical practitioners’ scopes of practice should be available to relevant staff in an easily accessible format such as an electronic record. Any queries or concerns of admission or theatre staff regarding a practitioner’s scope of practice should be directed to management. Theatre nurses need to be able to easily access practitioner scope of practice information and there must be support available for nursing staff to do this prior to a procedure, as well as clear processes for timely reporting of concerns around scope of practice compliance.

35. Would a requirement for registered hospitals and day procedure centres to maintain a drugs register in operating theatres and procedure rooms create any issues for facilities?

All facilities should comply with the standards of dangerous drug regulation. A register of Schedule 8 drugs should be maintained in operating theatres and procedure rooms. If the intention is for all registered facilities’ operating and procedure rooms to maintain a register of Schedule 8 drugs dispensed then this requirement should be upheld and compliance achievable.

Recording discard of all drugs administered intraoperatively (i.e. other than Schedule 8 and some Schedule 4 drugs) is not practical and of uncertain purpose. It is suggested that the focus for fulfilling the intent of this



requirement is placed on the accurate recording of drug administration on the anaesthesia chart which could be audited as part of a standard governance process.

36. Should open disclosure be regulated across all registered health care facilities in Victoria, as a process of open dialogue in the provision of information to a patient?

ANZCA supports the regulation of open disclosure across all registered health facilities. As noted in the discussion paper however, there is anecdotal evidence that there is significant room for improvement in the practice of open disclosure in Victorian healthcare facilities. In addition to those listed in the discussion paper, other potential barriers to the practice of open disclosure may include practitioner concerns about workplace or employment ramifications and a perceived heavy administrative burden. Consideration should be given to addressing these potential barriers to address better compliance with open disclosure standards.

37. Is it practical to propose a requirement that all facilities have received, reviewed and documented each patient’s clinical risk assessment prior to admission?

In general, a requirement that facilities have received, reviewed and documented patients’ clinical risk assessments prior to admission is supported. It should be noted however that:

Pre-admission processes involve more than clinical risk assessment.

A requirement that risk assessments be completed a week prior to a procedure is likely to be impractical as it is not uncommon for a patient to be added to a list one or two days prior to scheduled admission (often to accommodate patient preferences).

38. Should the Regulations require that upon discharge from a private health facility, patients should be provided with a clear explanation, in writing, of any recommendations and arrangements that have been made for follow-up care?

ANZCA supports the proposed requirement that private health facilities provide patients with clear recommendations and explanations of arrangements for follow-up care upon discharge.

39. How can post discharge follow-up and patient care be improved, and should there be a minimum regulated requirement?

As noted in the discussion paper, most facilities already have a nursing staff member contact patients by telephone one or two days post-procedure. Addressing the issues raised in the discussion paper – that patients may not be able to adequately self-assess their condition or possess the assertiveness to advocate for themselves – requires a more thorough post-discharge follow-up. Undertaking such follow-up with all patients is likely to be prohibitively costly and impractical.

A suggested approach would be to conduct more targeted telephone follow-up of higher risk patients or patients who have undergone higher risk procedures. Such follow-up would need to be undertaken by a medical practitioner or facility nursing or other staff member with appropriate training in the specific questions to ask and issues to be cognisant of (e.g. how long the patient takes to answer a question and other cues as to their post-operative wellbeing).

In the future it is hoped that other passive means of post-discharge follow-up of patients, such as wearable healthcare technologies, will provide practitioners with more comprehensive, real-time postoperative patient wellbeing data.



40. How would regulation of discharge processes from private hospitals and day procedure centres improve patient-centred standard clinical pathways?

Effective regulation of discharge processes will be challenging given the significant variance in need according to patients, types of procedures and facilities.

41. Would a requirement for hospitals to provide clinical handover to transport crews create any issues or unintended consequences?

Clinical handover to patient transport crews is essential and the proposed requirement for this through regulation is supported.

42. Will this requirement create any issues for facilities and if so, why?

It is a basic safety requirement that facilities have in place a written and current evacuation plan for all patients and staff, and that staff are familiar with and trained in the use of this plan. The proposal to require this through regulation is supported and should not create any issues for facilities.



Data

43. Is it reasonable to request that private hospitals and day procedure centres report sentinel events in the same way that public facilities are required to?

ANZCA supports the proposed requirement for private hospitals and day procedure centres to report sentinel events to Safer Care Victoria. All such data has the potential to be valuable and improve patient safety and quality of care provided that the data is appropriately analysed and actioned. Where data are collected and there are no visible outputs from the process, there is the risk of the collection being seen as a purely administrative burden with a consequent negative impact on compliance.

44. Is it reasonable to request that private hospitals and day procedure centres report ECT data to the department? What are the potential barriers to reporting this data?

ANZCA supports the proposed requirement that private hospital and day procedure centres report ECT data to the department.

45. Is it reasonable to request that private hospitals that have an emergency department report VEMD data in the same way that public facilities are required to? What are the potential barriers to reporting this data?

ANZCA supports the proposed requirement that private hospitals that have emergency departments report Victorian Emergency Minimum Dataset data to the department.

46. Is it reasonable to request that private hospitals and day procedure centres report VICNISS data in the same way that public facilities are required to? What are the potential barriers to reporting this data?

ANZCA supports the proposed requirement that private hospitals and day procedure centres report data on healthcare associated infections to the Victorian Healthcare Associated Infection Surveillance System.

47. Should the Regulations require that patient experience data be reported to the hospital? If not, why?

ANZCA supports the principle of requiring the reporting of patient experience data based on a core set of questions, however is unable to provide further comment in the absence of sighting the proposed questions.

48. What are the barriers to reporting patient experience data to the department? How could they be remedied?

Potential barriers to reporting patient experience data to the department may be dependent on what the department considers an acceptable target response rate. Not all patients will agree to complete patient experience surveys. It will also be impractical to make surveys available in all languages and some patients due to age, illness or disability will be incapable of completing such surveys. Privacy and confidentiality concerns may also present as a barrier.



49. Should private hospitals and day procedure centres report patient experience data to the department or should they collect the data for internal review and make it available during inspections?

It is suggested that private hospitals and day procedure centres collect patient experience data and make it available when required, consistent with the process for accreditation inspections.

50. Should the Regulations require that the same patient experience data be collected or not specify how or what to collect?

As noted in the discussion paper and the response to Q.47, a core set of questions for measuring patient experience could be utilised, such as those being developed by the Australian Commission for Safety and Quality in Health Care. This would allow valid comparisons between facilities.

51. Have the right questions for capturing staff safety culture been identified?

Without sighting the eight questions evaluating staff views on quality safety reporting culture from the department’s People Matter Survey it is difficult to comment on their appropriateness. However, if the department has found these to be of value in public sector facilities, it would be reasonable to assume they would also be useful in private sector hospitals and day procedure centres.

52. Should the regulations require that staff safety culture data be reported to the hospital? If not, why?

ANZCA supports the proposed requirement for staff safety culture data to be reported to the hospitals.

53. What are the barriers to reporting staff safety culture data to the department? How could they be remedied?

Potential barriers to reporting staff safety culture data to the department include:

additional paperwork and administrative burden;

lack of perceived value of the data collection exercise (see response to Q.43); and

concerns about workplace or employment repercussions, especially in centres where there are small numbers of staff.

The reporting of this data must be embedded in routine governance processes. It must be made clear to staff that the data are collected solely to improve patient safety and there should be reassurances regarding potential repercussions from raising valid safety culture issues. Demonstrable benefits and improvements from collecting this data must, over time, be visible to staff.

54. Should private hospitals and day procedure centres report staff safety culture data to the department or should they collect the data for internal review and make it available during inspections?

As per the response to Q.49, it is suggested that staff safety culture data collected by private hospitals and day procedure centres are made available when required. Regular analysis of this data will highlight any issues that may need to be addressed. Reporting back to staff the results of this analysis and any actions taken in response will help promote staff engagement and compliance with the process, in turn promoting a better staff safety culture.



55. Should the regulations require that staff safety culture data be collected, but not specify how or what to collect?

A potential risk with requiring facilities to collect staff safety quality data without specifying how or what is collected is that some facilities may only collect data likely to present the site in a positive light. Furthermore, this may lead to different facilities collecting different data, rendering comparisons of the safety culture in different organisations meaningless. As noted in the response to Q.54, there are clear benefits to hospitals and day procedure centres through collecting, analysing and acting upon staff safety culture data. Providing data to facilities to enable comparisons with other centres (only possible if all are using the same set of measures) has been demonstrated to improve performance and is common in many areas of hospital activity such as infection rates and waiting times in emergency departments.



Fees

56. Do you support the proposal to combine the application fees and registration/registration renewal fees into a single fee, payable every two years?

The proposal to combine the application fees and registration/ registration renewal fees into a single fee, payable every two years, is supported.



Conclusion

Overall, ANZCA supports the intent of the proposed changes to the Health Services Regulations. Of particular importance is the requirement that any procedure involving the administration of general anaesthesia, major regional anaesthetic blocks, intravenous sedation or high doses of local anaesthetic be undertaken in a registered facility.

While patient safety and quality of care must take precedence over any potential negative outcomes, it is

acknowledged that these proposed changes to the regulations may reduce access to care for some services.

ANZCA is concerned to ensure that strategies make certain that patients, particularly those on low incomes,

are not unduly disadvantaged by the proposed changes.

ANZCA broadly supports aligning the governance and data reporting requirements for private hospitals and day procedure centres with those of public hospitals, acknowledging however that this will not be without associated costs and some smaller facilities, particularly sole owner operated sites, will require support to transition.

ANZCA believes that, particularly in regulations relating to governance, more consideration should be given to establishing the governance standard rather than prescribing how each facility should implement governance.



Contact details

Australian and New Zealand College of Anaesthetists

ANZCA House

630 St Kilda Road,

Melbourne Victoria 3004

President:

Professor David A Scott

[email protected]

+61 3 9093 4913

General Manager, Policy Safety and Quality:

Ms Jo-anne Chapman

[email protected]

+61 3 9510 6299



December 8, 2017 Private Hospitals Unit Commissioning ... · The medical specialty of anaesthesia is critical to the provision of safe, effective anaesthesia and perioperative care

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