2016Election Commitments Osteopathy Australia seeks commitments from all parties and candidates at the 2016 election.

Here are 20 ways the next Government can help osteopaths and their patients.

Osteopathy Australia is the peak body representing the interests of Australian osteopaths, osteopathy as a profession, and the consumer’s rights to access osteopathic services.This gives us a unique voice for representing the profession and lobbying to ensure high industry standards are established and maintained.

Osteopathy Australia is sending this to all major parties. Responses will be published in full on our website and via social media before the election.

We seek specific and detailed commitments to each of our policy positions, but non-committal or equivocal responses will be published and highlighted as well.

Osteopathy Australia’s members, and their patients, can also use this document to question candidates in electorates around the country.

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Medicare and Commonwealth health policy

1. End the freeze on MBS indexation, with immediate increases that take into account the years since it was last indexed?

2. Increase the DVA fee schedule so that veterans and their families have access to the same quality healthcare as other Australians?

3. Increase the number of the Individual Allied Health Services under Medicare permitted under the Chronic Disease Management scheme?

4. Permit direct referral from osteopaths to specialist medical practitioners, where clinically indicated?

5. Pay a Medicare rebate on all imaging requested by osteopaths for clinically indicated diagnostic purposes, not just on the current arbitrary items?

6. End the ban on so-called “double-billing” than is a brake on clinically appropriate referrals to osteopaths?

7. Provide improved clarity and dedicated educational resources to ease the compliance burden on practitioners?

8. Guarantee the inclusion of osteopaths within the Health Care Home trials?

9. Profession-specific consultation about the implementation of Health Care Homes trials, including intersection with Chronic Disease Management items?

E-Health

10. Write and upload-access to My Health Record (not just read-only access) for osteopaths?

11. Parity of esteem among professions, including equal software subsidies for all private sector health professions?

Private Health Insurance

12. Increase direct Commonwealth support for Private Health Insurance?

13. Keeping “extras/ancillaries” (however defined as to include osteopathy) as part of the insurance mix attracting the subsidy, and within any defined use of a proposed lifetime health savings account?

Summary of election commitments

Will you commit to...

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National Disability Insurance Scheme (NDIS)

14. Include osteopaths as eligible providers within the NDIS?

Public Safety

15. Amend, via COAG processes, s 123 of the Health Practitioner Regulation National Law, which currently permits anybody at all—including untrained members of the public—to manipulate the non-cervical spine?

Workforce

16. Maintain osteopathy on the Skilled Occupation List for the life of the next Parliament, not just for 2016-17?

Health Regulation

17. Make, via COAG processes, the Australian Health Practitioner Regulation Agency and the Osteopathy Board of Australia more accountable to the practitioners who fund them?

18. Ensure, via COAG processes, that registration fees paid by osteopaths will decrease?

19. End, via COAG processes, the subsidisation of complaint-handling for non-regulated health professions by regulated health practitioners?

Continuing Professional Development (CPD)

20. Maintain the deductibility of education expenses incurred by compliance with a mandatory CPD standard?

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Election commitments in detail...

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yWill you commit to... End the freeze on MBS indexation, with immediate increases that take into account the years since it was last indexed?

1. Election Day 2016 will mark 44 months since an MBS schedule increase.

This effectively means a continued and worsening disincentive for our members to do the important Chronic Disease Management work that we, and the Government, agree is the most cost-effective and useful point of intervention.

The longer the freeze lasts, the less effective the Initiative becomes.

Already osteopaths’ private fees are significantly higher than the frozen rebates for public work.

Osteopaths’ frozen remuneration under Medicare has forced higher and higher

gap payments onto patients—it’s a copay by stealth. These higher and higher gap payments come straight from patients’ pockets; they are not claimable on private health insurance.

For fairness to patients, and fairness to osteopaths, the MBS freeze must end.

When it ends, the reindexation of the MBS must account for the years of frozen fees with increases tied to true health sector inflation, not just a one-off increase calculated on economy-wide CPI.

There must be an equitable and honest adjustment for the frozen period, so there is no long-term penalty ensuing from the freeze.

Will you commit to... Increase the DVA fee schedule so that veterans and their families have access to the same quality healthcare as other Australians?

Unlike Medicare-funded osteopathy under the MBS, Department of Veterans’ Affairs patients cannot be asked to pay a gap. This means Australia is relying on the goodwill and charity of its health workforce to treat veterans, which is insulting to them and unfair to practitioners.

The Government does not expect any other segment of society—not pensioners, not serving Defence personnel, not politicians—to survive with remuneration

frozen for years at a time.Each DVA consumer treated at a loss means a full fee-paying private consumer is turned away. Our members are decreasingly able to support veteran health at their own personal detriment.

2. Election commitments in detail...

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Will you commit to... Increase the number of the Individual Allied Health Services under Medicare permitted under the Chronic Disease Management scheme?

3. Chronic disease management (CDM) is the most cost-effective way of improving public health and simultaneously reducing the pressure on the public purse. Medicare’s Allied Health Initiative is a crucial part of the Government’s strategy of treating chronic diseases early in order to treat them effectively and at the lowest cost.

We urge a prominent re-commitment to an expanded Medicare Allied Health Initiative, with increased expenditure.

Osteopathy Australia urges the Initiative’s expansion in these ways:

> Consumers should be eligible for as many consultations as the referring GP determines is clinically indicated, not limited to five per calendar year.

> If there must be a numerical cap it should be 12, one per month, not five per calendar year.

> The number of consultations—whatever it is—should be per chronic condition/disease per practitioner, not per consumer regardless of the number of chronic conditions and diseases. (It is common to have two or more chronic diseases requiring management, and common to require regular care from practitioners of two or more professions for the same disease.)

Will you commit to... Permit direct referral from osteopaths to specialist medical practitioners, where clinically indicated?

Australia’s next Government can avoid unnecessary expenditure on duplicated consultations by permitting direct referrals to specialists.

We note that the Australian Physiotherapy Association estimates this would save the Government $13 million per year. (It would also save patients millions, as well as important time.)

We endorse the APA’s estimate, and note that even more could be saved by

permitting direct referrals to specialist medical practitioners by the nation’s 80,000 allied health practitioners, working within scope and with their patient’s clinical benefit always paramount.

Direct referral would benefit consumers and the taxpayer but would have no effect on remuneration or profit for osteopaths. The benefits are in better case coordination, faster care, and decreased likelihood of complications.

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5. Will you commit to... Pay a Medicare rebate on all imaging requested by osteopaths for clinically indicated diagnostic purposes, not just on the current arbitrary items?

MBS rebates should be payable on a full range of diagnostic imaging services requested by osteopaths. By limiting the kind of diagnostic imaging to the current item numbers, the Government is forcing consumers to make an additional and avoidable visit to a GP—often bulk-billed—merely for the purpose of requesting imaging that an osteopath could very well request in the first instance.

In the words of former Health Minister Dutton, this is a classic case of a way to “cut waste in health and invest in areas that provide the greatest benefits to patients.”

Data available from the Department of Human Services indicates that osteopaths request diagnostic imaging at very low, clinically responsible rates—certainly less frequently than comparable professions.

Will you commit to... End the ban on so-called “double-billing”?

The 2013-14 Budget measure ending so-called “double billing” is still in effect. This measure should be rescinded immediately. GPs should be able to treat consumers under one MBS item and write a CDM plan under another item on the same day. Doing so is efficient and desirable—either consumers leave without care plans they should be getting (and therefore go without the care itself), or they must return and take up another appointment that could be used by another unwell consumer.

Forcing consumers to attend twice to receive services under two item numbers is inefficient for GPs and clinics, burdensome for consumers, and causes avoidable adverse outcomes for those who do not re-attend.

The current prohibition of “double-billing” is bad policy and doubtless costs more in the long term than it saves in short term. The next Government should be encouraging preventative care and early intervention, not giving consumers reasons to delay treatment until it is too late, when it is more expensive, and when the only appropriate treatment may involve hospitalisation.

An alternative policy setting would be to abolish (or lower) the fee for writing the plan—often a perfunctory document—and use the resources to increase the maximum number of Allied Health consultations in a plan. This would accord with a bipartisan desire to fund services to consumers, not paperwork.

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Will you commit to... Provide improved clarity and dedicated educational resources to ease the compliance burden on practitioners?7.

Osteopaths face increasing demands for their time, and increasing compliance burdens. We think all regulation should be the least intrusive, least costly, and least time-consuming consistent with its purpose.

In the case of MBS rules and practitioner compliance, the Government should provide clear, unambiguous resources to guide osteopaths, leaving them more time with their patients.

Will you commit to... Guarantee the inclusion of osteopaths within the Health Care Home trials?

Outcome based or capitation based models of care and remuneration are to be trialled from 1 July 2017. Many of our members are clinically and administratively equipped to participate fully in such models. However, detailed and extensive consultation will be necessary well in advance, and it must be with all affected professions, not just medicine and the larger allied health professions.

Consumer choice is an influential and often justified philosophic approach that future Governments may adopt across many portfolios.

With regard to health, it’s important to realise that many consumers will require carefully considered transitional arrangements (fee-for-service CDM plans last a year, for example, and presumably will coincide for a period of time with Health Care Home arrangements in the trial sites.)

8. Will you commit to... Profession-specific consultation about the implementation of Health Care Homes trials, including intersection with Chronic Disease Management items?

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Will you commit to... Write and upload-access to My Health Record (not just read-only access) for osteopaths?10.

My Health Record is being implemented in a discriminatory way that fails to assist allied health practitioners, and will therefore result in adverse health outcomes for consumers.

Osteopathy Australia supports the potential benefits that may flow from a well-designed and inclusive My Health Record.

Unfortunately, to date the scheme has prevented the nation’s 80,000 allied health workers from being able to add important health information to My Health Record.

My Health Record should be extended to involve all practitioners working in professions that provide Medicare-rebated services. Only this way can My Health Record provide a thorough and

comprehensive record of health, and only this way will it achieve its goals of “better, safer, and more efficient care for patients.” Commonwealth money spent on a E-health record system that excludes allied health is largely wasted money.

We have participated to the extent possible in consultations, and made a detailed submission to the Government’s Review.

Our members are aware of the benefits of a functional My Health Record system, and eagerly anticipate participating in it.

However, osteopaths remain frustrated by zero discernible progress on this issue during the last two Parliaments. Fair and equal access to financial incentives are essential to the trials’ success.

Will you commit to... Parity of esteem among professions, including equal software subsidies for all Medicare-funded health professions?11.

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Increase direct Commonwealth support for Private Health Insurance?

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Osteopathy Australia reiterates our long-held position on the importance of encouraging private health insurance. Measures that increase the take-up of private health insurance are necessary for the affordability of the nation’s health system.

Osteopathy Australia undertakes publically to support any future Government that increases the level of private health insurance as long as it covers “ancillary services” including osteopathy, and as long as osteopathy is included within the purview of any proposed individual health savings account.

Will you commit to... Keeping “extras/ancillaries” (however defined as to include osteopathy) as part of the insurance mix attracting the subsidy, and within any defined use of a proposed lifetime health savings account?

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14. Will you commit to... Include osteopaths as eligible providers within the NDIS?

Osteopaths have a range of skills that can assist people with a disability, but the administrative arrangements need to be clarified to ensure osteopaths are eligible providers under this scheme.

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yWill you commit to... Amend, via COAG processes, s 123 of the Health Practitioner Regulation National Law, which currently permits anybody at all—including untrained members of the public—to manipulate the non-cervical spine?

15. Prior to enactment of the Health Practitioner Regulation National Law in 2010 (the “National Law”), there was a patchwork of laws restricting spinal manipulation in Australia.

Since the National Law there has been consistency nationwide: it is illegal for anybody except a registered medical practitioner, osteopath, physiotherapist or chiropractor to manipulate the cervical spine (comprising the upper seven vertebrae).

One objective of the national registration of health practitioners is to:

[P]rovide for the protection of the public by ensuring that only practitioners who are suitably trained and qualified to practise in a competent and ethical manner are registered […].

However, the law is defective in that the public also needs protection from spinal manipulation by people who are not practitioners.

The “[s]uitably trained and qualified” stricture is only partly about the safe and effective manipulation of the spine. It also includes, importantly, judgment about when not to manipulate a patient’s spine.

In other words, properly understood, the “competent and ethical manner” of manipulating the spine is only partly about technique. It’s also about knowing when not to manipulate.

The National Law should be amended so a person may not perform manipulation of any part of the spine unless that person is a medical practitioner, osteopath, physiotherapist or chiropractor.

In addition, the Law’s current definition of “manipulation of the cervical spine” is not appropriate.

Currently, it means:

[M]oving the joints of the cervical spine beyond a person’s usual physiological range of motion using a high velocity, low amplitude thrust.

This definition should be amended to include any movement beyond a person’s usual physiological range.

There is no basis on which a person not registered in an appropriate health profession should be permitted to manipulate any part of the spine beyond its normal physiological range, even if not using a high velocity, low amplitude thrust.

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ce16. Will you commit to... Maintain osteopathy on the Skilled Occupation List for the life of the next Parliament, not just for 2016-17?

For patients to have equitable access to osteopathy, the profession’s position on the Skilled Occupation List must be maintained.

Listing osteopathy for more than the next 12 months would give certainty to employers and to prospective immigrants.

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nWill you commit to... Make, via COAG processes, the Australian Health Practitioner Regulation Agency and the Osteopathy Board of Australia more accountable to the practitioners who fund them?

17. Regulatory Impact Statements should be prepared whenever regulation (or a change in regulation) has a significant impact on practitioners. These statements should include dollar amounts whenever regulation has financial impact, which it nearly always does.

Will you commit to... Ensure, via COAG processes, that registration fees paid by osteopaths will decrease?18.

The National Board has a significant cash reserve that has been built on the basis of many years of high fees. Fees should drop because this operating surplus no longer needs to be amassed, and because of promised efficiencies following the 2016 COAG decision not to amalgamate the nine “low-regulatory workload” professions.

The principal of no cross-profession subsidisation must continue.

Will you commit to... End, via COAG processes, the subsidisation of complaint-handling for non-regulated health professions by regulated health practitioners?

19. Osteopaths are pleased to participate a public-protective system of registration and accreditation. But complaints about unregistered practitioners should not be handled at the expense of registered health practitioners.

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CPD

)20. Will you commit to... Maintain the deductibility of education expenses incurred by compliance with a mandatory CPD standard?

Osteopaths, like all AHPRA-registered practitioners, must complete a mandatory minimum amount of quality continuing professional development annually to comply with the registration standards.

The costs of this are borne by the practitioner, and/or passed on to consumers. To reduce this double burden, it is essential that the tax deductibility of education expenses be preserved.

If deductions for self-education expenses are ever to be restricted, the restrictions should be categorical (e.g., no business class fares can be deducted) rather than a capped dollar amount.

CPD is good for the profession, good for patient health outcomes, and a requirement of registration, and should always receive tax deductibility status.

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Osteopathy Australia, a member association, is a non-partisan peak body that strives to enhance and promote the profession.

Osteopathy AustraliaPO Box 5044Chatswood WestNSW 1515

www.osteopathy.org.au

General inquiries: info@osteopathy.org.auMedia inquiries: comms@osteopathy.org.au