Attachment 1 SA Pathology’s response to questions from the Public Service Association (PSA) are outlined in blue below. Please note SA Pathology is happy to meet with the PSA to discuss these matters in more detail. Frome Road/RAH - Response to the Proposal and General Comments 1. Changes in practices at the point of collections are likely to increase the time with patients at the point of collection and slow down patient TAT. Currently Phlebotomists do not complete data entry after they collect a sample. With the shift in requirement to either a Phlebotomist, Nurse or Doctor to enter the data in the EPLIS system this will inevitably slow down patient TATs at the clinical end. Has the likely reduction in patient TAT been calculated? If so what are they forecast to be? if not why not? The new EPLIS system will improve consistency and enable more efficient laboratory processing. Therefore we expect that turnaround times will be improved. Clearly TAT is important, and we will keep this under review as part of our Business As Usual (BAU) KPI monitoring. 2. There are reports that the track systems installed with the new Analysers are not compatible with EPLIS. The system does not 'talk' to EPLIS completely. Has this been factored into assumed productivity improvements? If not why not? The EPLIS system interfaces are currently being tested and refined. We expect to achieve full functionality and therefore we expect to realise the forecast productivity benefits. 3. Because of the compatibility between the track systems and EPLIS noted at point 2 above, non-urgent testing of aliquots will require manual re-labelling. This will introduce manual handling where it was not before, increase the TAT of samples and increase the risk of errors. The re-labelling of samples is widely accepted as poor lab handling practice as it introduces a risk to patients. What, if any risk assessment has been completed on the incompatibility between the new track systems and EPLIS AND the productivity impacts specifically in relation to the new requirement to manually add bar codes to aliquots? As above we anticipate full functionality for ELPIS and the track systems. 4. With the automated machines the quantity of hard copy material to be assessed has increased. The machine performs the tests quickly but the information still has to be analysed by a human being. There will actually be the need for more staff at this step than previously in order to keep up with the machine's output. What is SA Pathology's response to this? We do not expect that paper utilisation or requirements for human intervention will increase. 5. How many staff have left since the benchmark count? Many positions are being held vacant. Does the loss of numbers relate to positions from the organisational structure (some of which are now vacant) or current actual staff numbers? It is intended the next consultation process will include more detail around staff numbers. In most cases vacant positions declared excess since the 2014 review have counted towards staff reductions. 6. Media reports that the Cancer Research service in the UK that was used as a benchmark to slash staff and services at SA Pathology. It does not bode well if we are cut to the same level. Are we expected to reduce services to the same standards that are now proving to be on the verge of collapsing in the UK?

Page 1 of 25

http://www.cancerresearchuk.org/about-us/cancer-news/press-release/2016-1 1-23-uks- pathology-services-at-tipping-pojnt http://www.dailymail.eo.uk/heal th/article-3963376/NHS-labs-tipping-point-putting-cancer- tests-risk-charity-warns. html I am aware of the cited articles in the UK media. Clearly, laboratory services in the UK are not on “the verge of collapsing”. The cited papers lack verifiable data. However, these claims are concerning and we continue to keep them under review. As noted in my response to consultation feedback document dated 9 February 2017, benchmarking studies do not dictate – rather they inform – our decisions. We will continue to keep the UK issues under review. Meanwhile, we will use the best available information to inform our decisions as we proceed to implement a safe and effective laboratory service. 7. The attached response from the Royal College of Pathologists (UK) to a February 2016 report into productivity in diagnostic labs highlights that the numbers are also unreliable. This raises serious questions and suggests that SA Pathology ought not to have been benchmarked against UK labs. (attached). As above. 8. Unfounded assumptions that the new EPLIS/LIS system and new equipment will improve laboratory efficiency. I have spoken with the staff that have been given the (very unenviable) task of building the LIS. These staff do not believe that there will be an improvement in efficiency based on the LIS alone. Many processes are actually more labour intensive than with the current system. Management does not have a good track record of implementing automated equipment effectively. What measurements will determine that the new LIS is more effective than the old? I have personally spoken with many staff about this project. Overwhelmingly, people are positive about the anticipated benefits of EPLIS and the automation systems. It should also be noted that SA Pathology has an excellent history of adopting new technology. The Haematology and Biochemistry platforms recently deployed throughout our laboratories have been enthusiastically received and are performing very well. With respect to measurement: we will continue to monitor key performance KPIs, consistent with contemporary laboratory practice. These include TAT, error rates and complaints, as well as staff and customer feedback. 9. Proposed workforce model does not include any reductions to medical staff. From the numbers presented, we have 93.3 medical staff and there are no proposed reduction to these staff members. Using a conservative assumption that 80 of these medical staff are pathologists (not registrars) and the average salary is $300K p/a, we are talking about $24million in salary p/a that is not being considered as a saving. Meanwhile there are proposed 50% reductions in scientific and technical staff in the blood sciences directorate. It is not genuine to be proposing cost savings without looking at medical staff. Are 93.3 medical staff really required for supervision/reporting requirements for our organisation? Moreover, what strategies are being put into place to up-skill medical scientists so that they are able to take on supervisory/reporting roles? Medical scientists are a lot less expensive than pathologists. We should be ensuring that staff that are performing roles are at the correct levels. If pathologists are performing scientific roles, this is very costly and not commensurate with the advanced level of training that a pathologist is required to undertake. Such heavy reductions to lab staff may not be required if costs are cut from staff with the highest hourly rate (e.g. 1 pathologist = 4-5 scientists). My response to the perceived imbalance of proposed staff reductions was addressed in my response to consultation feedback document dated 9 November 2017.

Page 2 of 25

10. Why are Anatomical Pathology and Genetics not expected to make savings? Surely if the organisation as a whole is being asked to make savings, we should be looking at all areas. As above. 11. Who is accountable if the LIS or automated equipment does not achieve the savings it is expected to? As Pathology Director, I am accountable for this. 12. Who made the decision to start an efficiency improvement program in a time of major staff upheaval with new LIS, hospital, EPAS, Transforming health going on at the same time? The hyperactivity of the organisation is leading to reduction in quality of service. As outlined in my response to feedback document, I am aware that this is a time of uncertainty and significant change. It is true that we have multiple concurrent projects that are very demanding on our people. I am aware that this creates some risk, and we continue to keep this risk under review. However I am encouraged by the energy, commitment and resilience of SA Pathology people and I am confident that we will manage these projects effectively. If problems arise, we will rely on timely and effective communication to ensure we respond effectively, and I am committed to the consultation process with staff and the PSA. 13. With the current work practices, staff are very stressed. There is not enough time in the day to their normal role. Increased sick leave and stress is making the working environment very unpleasant. I am happy to discuss with the PSA any specific concerns about current work practices at any time. I also encourage staff to use the Employee Assistance Program (EAP) during this difficult time of significant change. 14. Support services that have a direct impact on Laboratory performance are not within scope, however these areas are under considerable stress. ICTS is an enabler for lab processes. Business as usual ICTS requests are being cancelled as EPLIS is taking too many resources. How are lab staff supposed to improve productivity/efficiencies when ICTS cancel their requests? For example, a minor modification to an ULTRA comment to enable the lab to improve test performance with the implementation of a new kit was rejected after the majority of work had already been completed (e.g. ICTS request #50891 and 50261). A standard comment that existing ICTS request have been cancelled has been logged against these requests s per JCT Transformation Group Review, this has been cancelled - resubmission required via new process if requester would still like this to go ahead.) The new process that has been implemented is grossly inefficient with an excessive amount of paperwork, meetings and signatures required. Business as usual processes are being adversely affected by the large number of projects currently being undertaken. Some IT changes have been deferred or placed on hold as they are inappropriate to be made during transition from the old LIS to the new LIS. This is part of the change control required to launch EPLIS. 15. Permanent positions are being converted to contract positions when the incumbent leaves. Previously permanent positions that are now contract positions are at the greatest risk of being cut. These new employees are the future of pathology and have very unsecured positions. What is the succession planning for knowledge, skills and training in a complex learning organisation? Where appropriate, temporary contracts are being issued while we determine the final workforce numbers required for SA Pathology. We will assess the knowledge, skills and training required of positions within SA Pathology. 16. We are in a negative feedback look with regards to Quality. When people are stressed, and have less time to perform their jobs, quality is reduced. This has hit the media recently. When quality is reduced, management require more reporting (e.g. SLS for incidents) which gives less time for Quality, and the service diminishes . We are at a critical point where staff are so stretched that there is increased risk of reporting errors, injuries etc.

Page 3 of 25

Further to my response to the consultation feedback dated 9 February 2017, I reiterate that while the process for assessing workforce configuration is to gain efficiencies, this by no means will be at the detriment of quality patient care. I welcome the opportunity to meet with the PSA to discuss any particular concerns regarding workload. 17. Answer to "What is SA Pathology core business" from executive is unsatisfactory. This matter requires clarification, and would therefore be best dealt with through discussion. 18. We have real concerns that the proposed roster and hours of work suggested for LMH, and then modelled for the entire Metropolitan service was based on extrapolated data collected on one day of the year. Out of an entire year why is it that EY used Melbourne Cup Day (a day known to quite) rather than collect data over a range of days to average data? This surely is a more reliable method which in the very lest would have provided for the inclusion of data that factored in peaks in demand with quieter periods of demand. This data is not sound enough to suggest there are the level of inefficiencies when compared with staff numbers and test output rates. I have addressed issues associated with benchmarking and the process moving forward in this document and my response to feedback document dated 9 February 2017. 19. There are no proposed medical staff cuts. Why are there no identifiable efficiencies and job cuts? Why are they not part of the review or included in the proposal? As already outlined in this document, my response to the perceived imbalance of staff reductions was addressed in my response to consultation feedback document dated 9 November 2017. 20. There are no proposed nursing staff cuts. Why are there no identifiable efficiencies and job cuts? Why are they not part of the review or included in the proposal? As above. 21. EPLIS - can it perform to acceptable levels to manage risk? Yes. EPLIS is expected to decrease pre-analytical errors leading to improved patient outcomes. 22. Work around is a manual task, where/how it is proposed to be automated? This matter requires clarification, and would therefore be best dealt with through discussion. 23. With an increase in manual work-ups there will be an increase in the risk of errors. What efficiency measures are there and what risk measures will there be? This is the situation now with automation – at SA Pathology and in laboratories everywhere. There are always workflow exceptions. And laboratories are very good at managing these workflow exceptions and monitoring performance. As we embrace further automation in laboratories, manual handling will reduce, consistency will improve and errors will decrease. If there are specific areas of particular work areas where for any reason, manual handling is required then our usual practice for minimizing risk will apply. I have addressed the issues of KPIs elsewhere in this document. 24. EPLIS cannot do what Ultra can. Ultra is now not stable. Both systems do different things. All LIS systems are different. Ultra is a very old and unsupported system, way past its end of life. Millenium is a modern, supported LIS used in laboratories all over the world. There are inevitably some local issues that we need to address. Our EPLIS teams continue to work diligently to ensure Millenium is robust, effective and adequately addresses various local issues. 25. The incompatibility between the systems has introduced an increase in manually tasks which not only increases risk factors but also deceases efficiencies. This has been addressed above.

Page 4 of 25

26. Did the UK Lab that SA Pathology was compared to in the benchmarking exercise also use Ultra? The benchmarking process included data from a number of UK laboratories – not a single laboratory. A range of LIS systems were in operation in these various laboratories. 27. EPLIS is currently not functional - how long is it proposed before it can be tested and come up to efficiency? EPLIS is expected to go live at the Women’s and Children’s Hospital in the week commencing 20 March 2017. 28. Surge Protection with infectious diseases - what is the plan? We are reliant upon our clinical and scientific experts in the MID directorate, working with Infectious Disease physicians, government, and other public health stakeholders to anticipate and manage infectious diseases and public health. This is the situation now and is not changed under the Efficiency Improvement Program. 29. Much is riding on the assumption that EPLIS will improve efficiencies. What are the metrics to relied upon to show that it will be more efficient? This issue has been addressed elsewhere in this document. 30. Currently automated does not talk to Millennium - it does not print out labels: will we have to change our labelling? As one would expect, Millenium will bring many changes and the way we label will be one. Labels and communication with automation will all be addressed prior to “go-live”. These detailed questions are best addressed through EPLIS training. 31. It is our view that the EPLIS tender was good at the contract stage but since then bits and pieces have been taken out. Why has this occurred? The EPLIS contract process is of course confidential. Our implementation team is working to ensure that the EPLIS system satisfactorily meets the needs of SA Pathology and our customers. 32. I.T. is a critical enabler and we rely heavily in Labs on I.T. for efficiency. Even today there is a huge backlog of I.T. jobs and recently the back log was cancelled arbitrarily and therefore jobs on the list have not been addressed. The recent cancellation occurred without proper notification or consultation to staff who had logged requests, e.g. requests to change testing interfaces that had some work completed but was lost. The impacts of I.T. quality, serviceability, and specific enabling factors on Lab efficiency ought to have been measured and continue to be measured. Will there be a method and process in place to measure how well or not the I.T. systems EPAS, EPLIS, ULTRA , OACIS and Millennium and the various testing equipment negatively impacts on efficiencies. If so how and what will be tested and if not why not? This issue is addressed at question 14 above. In relation to issues of communication, if a change request is not accepted by the change control group a communication is sent to the requestor. The change control team meet weekly to manage this process. Consultation Process Concerns 1. Our Manager has sent information out by email but it has been adhoc. We have not been provided with any time to read & review the proposal, we have to read it in own time. We have not had a single staff/team meeting to discuss the proposal.

Page 5 of 25

As outlined in my covering letter to this document, I have noted concerns raised by the PSA in relation to communication issues and look forward to working with you to address these. It would be useful for me to understand the particular areas where this was of concern as I understood Directorate managers spoke regularly to their staff about this. 2. Medical Scientists are meant to have adequate time to read the latest journal research findings but we have increasingly had little time to do this . Our knowledge base, skills development and expertise is currently being undermined by unreasonable workload demands. We cannot begin to see how the proposed reduction in over 100 Medical Scientist can be justified . Again I am happy to discuss any particular concerns regarding workload with the PSA. Assumptions EPAS must be in place before EPLIS is fully functional. All requests wiil have to be printed on multiple forms in any event due to incompatibility issues. This in itself will decrease efficiencies. The EPAS/EPLIS connection will bring additional efficiencies over our current system. 1. It is a red flag that there are reports that both the UK - National Health Service and Queensland Pathology are looking to recruit more staff following there respective efficiency drives where jobs were cut. What does SA Pathology have to say about these reports? I have addressed this issue earlier in this document. 2. Micro Lab was consolidated from QEH & LMH to Frome Road by 2013. Microbiology Directorate have already lost (consolidated) about 20 staff (approximately 18 FTE) but the EY did not include this data post consolidation . Why did EY not take this into account? Will this be included when considering the number of jobs that are proposed to be cut in Microbiology? In my response to consultation feedback document dated 9 February 2017, I acknowledged that directorate leaders and managers have worked hard to embrace and lead change, and in some cases this has entailed significant restructuring and efficiency improvements. However, transformation of pathology services must assess our current situation and future needs. For reasons discussed above the need for further change remains. A key enabler for the proposed Lab configuration is the new testing equipment but as it has not been tested by anyone in SA Pathology we do not know how it will run, it may prove to be slower than our current practices. Assumptions have been made about the efficiencies of EPAS and EPLIS but this is not tested. In fact there are reports by medical users that EPAS should be abandoned. Therefore any changes to the supporting workforce ought to be made until EPAS & EPLIS as well as the various testing equipment are validated. We must protect our public Pathology provider. All pathology tests that are too difficult and complex for the Private Pathology providers are sent to SA Pathology. Frome Road - Engineering Our job roles are highly dependant on how EPLIS is implemented. At this stage we have been told our (ULTRA) current system will be run alongside the start-up of EPLIS. This may (most likely) create extra work at least for a short period while both are running. Isn't it prudent to trial the validity of EPAS, EPLIS before any staff cuts are made, if not why not? EPLIS is expected to go live at the Women’s and Children’s Hospital in the week commencing 20 March 2017. We will have therefore tested most (not all) aspects of that system before EPLIS is live at new Royal Adelaide Hospital.

Page 6 of 25

In terms of implementing the Efficiency Improvement Program, it is reasonable to plan for full functionality of our IT systems, which have been subject to rigorous testing and review. Of course, there is always some risk with large IT projects, and as with any quality organisation we will have contingency plans in place for dealing with any unexpected issues that arise. This is always our approach under standard “business as usual” management. Frome Road - Virology - Micro and Infectious (MID) 1. MID is solely the domain of SA Pathology - there are no private providers - so when there are suspected meningococcal B or meningitis cases or Salmonella outbreaks in the community trained MlD staff must urgently respond to ensure quick testing and diagnosis. Lives are lost or saved by quick diagnostics. This does not seem to have been factored into any EY bench modelling or considerations at any point from the beginning of this plan to cut SA Pathology staffing. What modelling has been undertaken to include surges in community outbreaks for things like suspected meningococcal B or Salmonella outbreaks? This issue has been dealt with earlier in this document. 2. In Virology we don't understand how more than 60 positions can be culled from MID as proposed. Concerns regarding MID were noted in my response to feedback document dated 9 February 2017. 3. How many job losses are proposed from Bacteriology compared to Virology in the MID directorate? It is expected that more detail about staffing will be provided in the next consultation process. 4. We need details of what ratio of job losses are proposed before we can appropriately respond. As outlined above, there will be more detail about workforce numbers in the next consultation process. 5. Is it the intention to implement the proposed jobs cuts once we have transferred to the new RAH? If so after what period of transition time are the job cuts likely to occur? One of the key enablers for the changes is the move to the new RAH, however not all changes are dependent on this. We intend to provide more information in the next consultation process about timing for various changes, including associated changes to the workforce. 6. Do the UK & Queensland Labs that we have been benchmarked against have the same equipment as SA Pathology now? Clearly all laboratories operate a range of different testing platforms – The benchmarking experts have used their best ability to match laboratories as closely as reasonably possible. Please also note my earlier response about benchmarking more broadly. 7. Bacteriology is not yet automated; any proposed job cuts we assume are dependant on the expected/assumed efficiencies of the new testing equipment. Still no-one has actually used the new equipment to be installed in the nRAH so we do not know how well or even how it performs. Wouldn't it be prudent to wait and run the system before the proposed job cuts of qualified staff are decided? If not why not? I have responded to this question earlier in this document. 8. Why is Genetic & Molecular Pathology (GMP) no longer part of the review or included in the proposal? I have responded to this question earlier in this document.

Page 7 of 25

9. Why is Anatomical Pathology (AP) no longer part of the review or included in the proposal? As above. Lyell McEwin Lab - Response to Proposal Staffing I Workload: 1. There has been a significant increase in workload at SA Pathology LMH post Modbury to LMH bed transfer. YTD the workload increase at LMH is 17%. 2. CAHLN - NAHLN bed transfers still pending (for first half of 2017) which will further increase workload . Workload is expected to further increase in the order of 10-20%. 3. Workload complexity has also increased. The LMH case mix index has risen from 1.2 - 1.5. This impacts all areas but in particular Blood Transfusion and Blood Morphology. 4. The suggested staff levels and shifts for LMH lab are not compatible with the actual LMH workload and level of task complexity. Based on what we have been able to interpret in the proposal we believe this will also be the case even when allowing for new sample management processes and automation. 5. There are discrepancies in the staffing levels quoted on the report. While they are not huge they contribute to the impression that the EY review did not capture information accurately. Specifically:

• On page 12 the current data entry and specimen reception staffing at LMH was a total of 13.0 in the document and currently in reality it is 13.3.

• However the number of ASOs is quoted as 0, but in reality it is 3.8 and has been for a long time.

• The number of OPS is 9.5, but the document quotes 12.0. • There are no TGOs in data entry and reception and have not been as far as I can

determine , but the document quotes 1.0. • On page 24 of the document 3.8 ASOs are quoted which reflects the current staff

accurately. This seems to contradict what is quoted on page 12. LMH staff levels in the lab area that are quoted in the document are slightly different to the current real levels and some of this may be due to changes made since the EY review.

• MES1, 1.7 quoted, current real figure is2.4 • MES2, 9.4 quoted, current real figure is 9.2 • MES3, 2.9 quoted, current real figure is 3.0 • MES4, 0.8 quoted, current real figure is 0.6. This is the Lab Managers position. He is 0.6

LMH and 0.4 at Modbury. The document quotes 0.8 at LMH and 0.4 at Modbury. • TGOO and TG01, 8.3 quoted, current real figure is 10.04 • TG02, 3.1 quoted, current real figure is 2.0 • TG03, 0.2 quoted, current real figure is O

Nothing earth shattering but there are again discrepancies. Big decisions are being made and it is important that these be based on accurate data. 6. In addition to this SA Pathology acknowledged in October 2016 that the FTE impacts of the Transforming Health agenda and the CALHN to NALHN transfer was not correct. Now it has been confirmed there will be an impact and the likely impact is to be a need to increase staffing by 11.3 FTE (including blood collection, pretesting and laboratory staff) and comprising:

Phlebotomy - 2 FTE OPS - 2 FTE

Anatomical Pathology - 2 FTE Medical Consultant - 1 FTE Scientific - 1 FTE

Automated and Transfusion - 6.8 FTE OPS - 4 FTE

Page 8 of 25

Scientific/Technical - 2.8 FTE Haematology - 0.5 FTE

Medical Consultant - 0.5 FTE Local SA Pathology Management recognised the need for staffing assistance at LMH and has employed the following strategies to alleviate the current workload stresses at LMH. Modbury and QEH currently loaning staff to LMH ( - 1.7FTE ). 7. The staffing numbers at LMH are only managing the current workload due to the additional hours worked by staff. Any additional staff transferred through the EOI process will help manage the projected increased workload due to the CAHLN to NAHLN bed transfers due to take place in 2017. The staffing numbers that were suggested in the Proposed Operational Configuration and Supporting Workforce Model for SA Pathology to cover shifts at LMH (a major metro hospital site) are similar to those seen at small regional laboratories performing a small percentage of the workload currently seen at LMH. 8. The Proposal assumes major efficiencies will be achieved from electronic ordering of requests from EPAS, new instrumentation both at LMH and RAH and the yet to be implemented SA Pathology Laboratory Information system (EPLIS) . Until all these items are fully functional it is impossible to evaluate their impact on staffing. We do understand that these new systems will provide efficiencies in the test ordering mechanism and also increase potential specimen throughput. What is unclear is whether the efficiencies gained can lead to staffing reductions or whether they will merely allow the current workforce to cope with the projected workload increases. Errors in the report I Areas it has failed to address 1. The report referred to LMH as a Rapid Response laboratory able to perform CSF microscopy. This is not currently the case. Core staff would need to be trained in this area. This is a highly skilled task and training and maintaining NATA requirements and competency in this area will be a significant challenge. There will be a labour cost associated with this. 2. Blood film morphology was not mentioned in the report. This is another highly skilled area that requires a substantial labour input to train and maintain staff competency. Currently morphology is staffed by -2.5 staff over a 24hr period. 3. The vast majority of LMH workload is generated by the hospital and must be performed on site (not represented accurately in the report - the report has split hospital work into urgent and non urgent - how was this determined? All hospital work must be performed on site) 4. . No mention of supervisory staff on the proposed staff requirements from the proposal. Currently Transfusion , Clinical chemistry and haematology each have 2 core supervisory staff who oversee the management , training and quality control of these areas. These staff are required for these departments to function within the accreditation requirements we are bound by. 5. There is a scientist /team leader role (not currently recognised on the LMH structure) . This is also not included in the review. This role involves management of rosters, recruiting and supervision of the pretesting area, staff performance reviews and performance management. Other FTE requirements not accounted for in Proposed Operational Configuration and Supporting Workforce Model for SA Pathology (the Report/Proposal): Cover for meal breaks Duties such as:

• QC's • External QAP's • Scheduled Daily/Weekly/Monthly maintenance • Troubleshooting for any QC or analyser issues (can result in downtime) • Stores (ordering and unpacking) • Phone call enquiries • Following up problem samples • Attending to add on requests

Page 9 of 25

• Duties associated with the laboratories supervision of the running of numerous point of care instruments both inside the LMH hospital and at external collection centres.

• Training • Maintaining/updating competencies • Admin duties such as:

o Performance reviews o Recruitment of staff o Rostering o Performance management

• New analyser and test workups • New reagent batch number workups • Professional development • Complex testing that takes more time e.g. Difficult antibodies (transfusion), blood film

morphology Current unknowns include: 1. RAH capacity to take on extra workload, 2. impact of the new automated technology 3. impact of new laboratory information system (EPLIS) 4. no EPAS at Lyell McEwin hospital (installation currently not scheduled) 5. transforming health impact on LMH hospital workload and complexity of patients 6. LHN SA Pathology service agreement has not been finalised so we aren't sure what the LHN's expectations of SA Pathology are as yet. It must be noted that efficiencies in data entry will only be seen once (if) EPAS is introduced and online test ordering from the hospital is in place (EPAS currently not scheduled for installation at LMH). The Proposed Operational Configuration and Supporting Workforce Model for SA Pathology report that was released had specific rosters & staffing levels for the Lyell McEwin laboratory stated in it. It is unbelievable to think that without a number of factors (as listed above) being correct or implemented, that they can accurately tell us how much work we will be doing and how many staff we need to do it. The observations on referral patterns at LMH are noted. It is beyond the scope of this response to deal further with the many highly detailed and specific issues raised. I have directed that these issues be considered by the relevant managers in refining the model. I can support further dialogue involving the PSA and their members about this if required. Please also note that the staffing information will be refined for the next consultation and provide more detail. Comments regarding impacts of technology are addressed above in this document. Our overall impression of the document it is difficult to interpret and to fully understand and thus to sensibly respond to it. In my response to consultation feedback document dated 9 February 2017, I acknowledge that there were some aspects of the consultation document that lacked clarity. We will take this on board for the next consultation paper. LMH Template The LMH model has been used as the template for other laboratories in the network. The LMH model is currently being propped up with help from staff from other sites. More help is currently required as evidenced by the EOI for staff to transfer to the LMH site. The impact of technology and LHN pathology needs are currently unknowns. Quantifying the impact on future staffing needs is purely guess work.

Page 10 of 25

The decision by SA Pathology to effectively threaten staff with the prospect of staff cuts is at this early stage unwise, uncaring and unhelpful. I acknowledge that the prospect of staff reductions creates considerable uncertainty for people. SA Pathology originally took the view that, out of respect for our people, we would be open and transparent about the Efficiency Improvement Program. I strongly support this view. The alternative is secrecy and the inevitable leaks. Secrecy is the preferred approach in the private sector, and I have personal experience of this. Secrecy does not respect our people and in fact the inevitable leaks and rumours cause more, not less, distress and mistrust. I am aware of the significant scale of this project, and its impact on people. Shortly after my arrival I committed SA Pathology to full support of our EAP programs. You will be aware that I have encouraged all staff to avail themselves of these services. I also encourage staff to talk openly with their manager, and I am happy to meet individually or attend meetings if this would assist. Other Feedback 1. The revised structure for LMH in table 4.2.1 shows that transfusion is now under haematology and there is only 1 staff in each department per shift. There is no mention of supervising scientist in haematology, chemistry or transfusion. It was mentioned at the road show that a rapid response laboratory needs supervising scientists but this new proposal doesn't seem to reflect this. With a proposed reduction in staff and increase in multidisciplinary staff, a supervisor in each area is even more necessary to help the staff perform the work to a high standard and ensure patient safety. 2. Training is proposed to occur only at one site. With minimal staff in the new proposed structure this would pose a high risk as staff wouldn't be able to leave the laboratory to obtain sufficient training. 3. The proposal of only 1 staff member during the day in transfusion at LMH is not realistic and in fact it would be dangerous. Work in this area is time critical and medical emergencies can result in the need for immediate support. It is critical that the laboratory is resourced to provide such support. 4. One cost saving measure would be to consolidate the work from 2 or 3 hospital laboratories within 15 minutes of each other to 1 of these laboratories e.g. Lyell McEwin is one of the major metro site laboratories (based at one of the 3 major "spine" hospitals) and there are 2 small laboratories 15 mind away (Gawler and Madbury). Out of hours the Lyell McEwin laboratory performs all of the Gawler hospital work (not Gawler laboratory). The Lyell McEwin laboratory is currently having improved Automated equipment that will increase its capacity for work . It would make sense, improve efficiency and save money to consolidate the work from Modbury and Gawler laboratories to the Lyell McEwin laboratory? Another example is the Noarlunga & FMC laboratories. Clearly this review has a focus of saving on salaries and not provision of services These comments are noted. I outlined in my response to consultation feedback document dated 9 February 2017 the principles that should be considered moving forward, which includes a focus on patient outcomes and service quality. I also outlined challenge we face is how to modernise our structure, to implement a contemporary and sustainable model, while preserving patient safety and supporting other activities such as research and training. LMH - Automated 1. Antenatal samples are sent off site to be processed (to QEH) so those extra samples are going onto QEH numbers not LMH. Reasons for sending on is LMH can't cope with workload already. 2. Amount of add-ons is high, not included in the proposal 3. Work is predominantly hospital work now not private. Hospital is growing rapidly in size therefore sample numbers also increasing

Page 11 of 25

4. Turn around time will be severely affected by sending country samples to the city (Frome Rd/RAH) 5. LMH site is adding specialist areas - dialysis unit, chemo unit, NICU - cases presenting are becoming more complex, more difficult - time taken to process is longer 6. HSR/OHS time not currently given when needed, due to low prioritisation. Will be worse with fewer staff 7. Annual reviews not being done due to not enough time. 8. Q Pulse documents (procedures of operations) go unread as no time allocated to do so - there might be a changed procedure in an area but not followed due to lack of knowledge of the changes 9. Proposed longer night shifts outside EB This feedback is noted, and will be addressed to comply with the Award and Enterprise Agreement. 10. 1 person in each area is not enough. Does this include supervisors and 21C's? Top heavy? 11. Sampling process queried - was it LMH on a Melbourne Cup Day?!!! The comments above are again noted, some of which have been addressed earlier in this document. Flinders Medical Centre - Response to Proposal 1. Possibilities written about in the proposal are dependent on unproven factors (equipment more efficient across the board, and EPLIS in place and functioning effectively) 2. Even if the above is effective, it is likely that data entry and sorting will need less staff but that collections will need more 3. 10.5 hour shift proposed, outside EB, not acceptable This feedback is noted, and will be addressed to comply with the Award and Enterprise Agreement. 4. Services delivered not included at all in the report include:

• Diabetics Clinic, numbers increasing at an alarming rate, staff taken from labs for hours • Blood gas • Bone marrow • Cardiac Trimponin • Ordering • Goods handling - deliveries , unpacking • Maintenance and breakdowns • Assessing QC • Troubleshooting • 2 of 7 tests on the Chief Pathologist's list are not included in the report • Add ans • Time taken to contact wards for urgent follow up • Phone calls in and out. Sometimes it takes long attempts to track down a clinician for

urgent responses 5. Struggling to fill 7-day rosters already with existing quantity of staff, will become impossible with suggested numbers 6. 240 Repat patients will add to current workload 7. If insufficient blood sample size, humans know how to stretch it out for multiple tests, machine will reject with "not enough blood" report. Human lives will be impacted.

Page 12 of 25

8. Clinicians often make mistakes, assigning a blood sample to a neighbouring patient. A human can identify the error, notify quickly and make the corrections following confirmation. A machine will just be factual and could lead to time-wasting errors or wrong diagnosis Patients are positively identified at the point of samples being collected, a barcode is produced at that point of collection and would be used throughout the analytic process reducing transcription errors. 9. Doctors can communicate now with lab walk ins and direct conversation with lab staff. This is useful in collaborative diagnosis, particularly for the more complex blood tests. Centralised automated testing will lead to a loss of service and could become dangerous with regards life and death scenarios. SA Pathology will not implement or support dangerous practices. I have acknowledged the importance of close contact with clinicians. Daily, at many locations around South Australia, we are providing an excellent service to doctors and patients. In some cases, this involves on-site staff. In others, conscientious and experienced SA Pathology pathologists and scientists communicate with doctors across distance – providing the same, quality service. This will continue. 10. Fairness questioned, is there a conflict of interest as there are no job losses proposed in the Anatomic Pathology and Genetic & Molecular areas? This matter has been addressed earlier in this document. 11. Quality issues - subject to regulations 12. No secretarial/ admin support will increase workload, slow down services 13. Why use LMH as a sample lab?

• not as complex • more complex takes more time-wasting

This matter has been addressed earlier in this document as it relates to benchmarking. 14. The Hub model will slow down response capability. FMC currently performs 90% of tests within 1 hour. 15. Currently difficult to manage leave rostering - LSL impossible!! Will become much more problematic with fewer staff - 37 down to 22 will be impossible to staff 24/7. 16. Keestra system interstate - practice already showing that same number of staff is still required 17. Difficult specimens will still need to be performed manually 18. Automation will still require manual processing 19. Staffing issues compounded at the moment with staff being seconded for EPLIS testing - taking managers, leaving fewer subject matter experts 20. Virology already lost 4 staff recently. 21. There is opposition to the proposal from clinicians. Flinders Medical Centre Immunology Lab - Response to Proposal Prepared by the staff from the Immunology main lab at FMC We are very concerned about the proposal put forward for SA Pathology. Outlined are details of each of the concerns that are focused at Flinders Medical Centre.

Page 13 of 25

Job of a Scientist is much, much more: Many technical officers have degrees but are not employed as scientists. Many may seek to leave SA with the proposed job cuts, and with the lack of recognition. Even a title change to Medical Technologist would serve us better. Our duties include, but are not limited to:

• Perform assays • Interpret I Analyse results • Perform quality control • Fill out maintenance forms • Order supplies I reagents, etc - Oracle, Basware, Sort problems

o Includes receipting • Reagent Preparation - in-house assays • Troubleshoot machines, assays

o Sometimes test have to be performed manually • Management meeting • Quality meetings • Safety meetings • Internal Audits • Monthly Calibrations • Laboratory meetings • Specimen reception • Communication: pathologist, practitioners, nurses • Review and Update procedures • ENDLESS PAPERWORK not related to doing our Job

o Our job title should be scientist + secretaries The contribution made by laboratory scientists is understood and highly valued. We depend on scientists for ensuring we have a safe and effective service. The additional duties listed are acknowledged (and I understand this list could be extended further). Most of the activities listed reflect standard laboratory practice by scientists. In some cases scientists have additional special areas of expertise in certain areas and these will be taken into consideration on a case by case basis in the detailed planning for workforce design. Flinders Medical Centre: teaching school, location

• Gives practitioners involvement in coming into the laboratories and learning about how test are performed and clinical information in order to request tests. Many will come in for a couple of hours to take a look at how the laboratory works, and understand the importance of co-communication to get the best outcome for patients.

• Flinders has much recognition in research around the world and is highly recognised for its work. Research in many instances involves monitoring pathology results to determine effects. Example: ANA Hep2000 cells were developed in the Immunology department at FMC and is the considered to be the best platform for ANA testing, allowing the detection of the presence of SSA, which is a diagnostic marker for autoimmune diseases (over 70 recognised Al diseases).

• Flinders outside of the RAH is the biggest hospital and caters for the south which is expanding - Aldinga, Seaford, Victor Harbour are all booming in population. Why would you want to delay results to such are large population size, bypassing FMC to RAH will cause delays in analysing critical results e.g. Flow Cytometry.

• Our pathologist have been known to visit patients in the hospital based on results found in our onsite laboratory and order more specific testing that is performed on site. They are able to look at the results to put together the clinical picture - giving the patient quality service.

• FMC services are providing quality results with efficient turn around times, and the best • service. It has been shown when tests have moved to RAH, turn around times have

increased due to not being able to cope with the workload I courier transportation .

Page 14 of 25

• Southern suburbs people and Doctors expect and deserve a high quality serviced based at FMC and not being sent to RAH.

• FMC is constantly one of the first targets for job cuts, despite performing at high levels of efficiently.

As acknowledged in my response to the consultation feedback document dated 9 February 2017, SA Pathology has a proud tradition of teaching, research and excellence in clinical care. SA Pathology’s origins are in the communities and hospital networks that they serve. We will continue to recognise and celebrate this proud heritage. As we move towards a more robust and sustainable – and unified – organisation, we need new ways of working that recognise and preserve this tradition whilst embracing change and the opportunities that technology bring. With respect to specific issues listed: • We will always welcome medical practitioners into our laboratories to learn about Pathology.

Equally importantly, we must engage more effectively with clinicians and their staff in their practice locations in the community, since these relationships are important to preserving and growing our community service footprint.

• Research will continue to be encouraged and supported • The concerns regarding TAT for regional samples are noted. It must be noted that there are two

key issues with TAT: speed, and consistency. It is well established that single hub consolidated models are more reliable for providing consistent turnaround times. Speed of turnaround is important, however the major components of TAT are not, in fact, road transport time but relate to consistent and well designed collection and delivery systems, as well as efficient and consistent sample handling and receipt. That said, we will of course continue to monitor TAT, and refine operational models as required.

• Pathologist contact with clinicians is important. As per my earlier response, the solutions are in flexibility, mobility and technology. Patient contact is generally under the clinical consulting roles of dual trained pathologists, and this activity will continue (regardless of where the tests are performed).

• People and doctors living in the southern region expect and deserve a high quality, predictable and effective service. Most people also recognise and embrace change. In this world of technology and communications, business models are changing daily. If we maintain our level of engagement with doctors, and in particular commit to and deliver a consistent, reliable service I believe patients and doctors will happily accept our new, fresh approach.

• Neither FMC nor any other location is being targeted or given preferential treatment. As I have said consistently since my arrival, SA Pathology is one organisation. All people and institutions are valued equally. A key challenge, nine years after the creation of SA Pathology, is all of us embracing a single culture – based on a shared history, new ways of working together, and a commitment to creating a positive future.

EY Review Concerns:

• The whole document is based on the Freme Rd site as the central location. There is uncertainty about it maintaining this location in the long term. The document also states that there is NO ROOM for the non-urgent laboratories at the new RAH. o Page 3 + 9 o No transparency as to what the plan is for the Freme Rd lab movement o Believe there is available space at FMC due to most of microbiology moving to RAH

• There is current debate about the need for Immunology to remain on two sites. Freme Road has the largest concentration of employees currently working in immunology so should be consolidated there. o Page 9 o Does this really sound like the best way to make a decision???

Just because a site has more numbers does not in itself reflect the level of staff skill sets and expertise at a site.

o FMC site has good efficiency, quality, shown by TAT, QAP o FMC staff are multi-trained, o Cost of moving equipment to FR site, then having to move again

Page 15 of 25

o FMC site has room to absorb the RAH lab o FMC site has a massive list of exclusive tests not currently performed at the RAH site,

therefore staff may need a lot more training. • Table 4.1.3 , page 13 (table inserted in original document)

o Shows ALL Sites are working at what APPEARS to be greater efficiency than FR/RAH lab. The reasons for this have not been properly explained an indicate an over simplification of the method used to determine efficiency.

• • Table 4.1.1, page 10 (table inserted in original document) o Shows FMC has the highest number of Urgent samples processed, by >50,000 tests o Shows that FMC is a critical acute hospital, where services should not be targeted

• Table 4.2.2, page 19 (table inserted in original document) o FMC staff numbers concern, why would a major spine site have similar staffing

numbers than non-spine sites? o Massive % cuts to FMC, >50%

• Table 4.3.1, page 20 (table inserted in original document) o No cuts to medical - why???

1 Dr v 5 Scientist Scientist make the job easy for pathologist to do Many Automated results are released without pathologist

o FMC proportion of cuts is the highest of all sites o Doesn't compare what laboratories are at each site - may affect staffing numbers

• Page 26: Cut 200 jobs (scientific, technical), increase productivity by 69% o How can cutting 200 jobs at the production, analytical end increase productivity

by 69%? o Less people doing the work, same work load or very likely to unreasonably increase o the workload on the staff remaining. o Scientific and technical staff analyse and interpret results and report

Specialist Laboratories Need to Stay

• Not number based results • Results involves patient history, clinical notes, other test results, interpretation • Many results have reflex testing to confirm diagnosis, many diseases have overlap • Many have limited Automation availability

o Run risk of placing in automation laboratory of machine wastage Tempted to run daily

• Increase calibrations, control • All big $$$ wastage • Generally non-urgent tests

Staff are already stressed and are performing at Maximum capacity. Job cuts to our services will results in reduced quality, and increased sick leave. Examples of Impact: Patient 1:

• Based in Aldinga, gets bled, sample goes to RAH, patient deteriorates and presents at FMC (closest major hospital, Noarlunga is a walk-in), Dr phones FMC to expect arrival of patient - chase results, cannot look at raw data as sample is at RAH, patient has to be re-bled at FMC for extra tests, etc. o unnecessarily rebleed o Dr cannot access raw data for interpretation (Flow cytometry) o Delays:

courier travel time - patient could present quicker at FMC than sample received at RAH

validation (difficult interpretation) Staffing Levels

• Departments are already at Skeleton staff • Sick I Stress Leave: unproductive workplace • Hard to take AIL: staffing levels - too low to cover

o Staff members are reaching critical levels of high AIL

Page 16 of 25

• Lots of hours of Unrecognised Over Time o Passionate about our importance and role

Staff Wellbeing

• Impact quality of life • Cost extra $$$ to work in city • Extra travel time • Research shows: Happy Employees = Efficient Workforce • Issues with different working in different locations - Example

o One works at FMC, the other in the city. Both get up and leave for work at the same time. The FMC worker is home approx. 4.30pm, the city worker doesn't get home till after 6pm. Extra 90min spent travelling to and from work, away from family.

Reflex Testing

• Immunology staff are trained in reflex testing, many results need interpretation before being released to clinician.

• Example 1: SLE patients: dsDNA: High, ANA = Homogenous • Example 2: DFS patients: ANA: suspect DFS, perform dsDNA, ENA and EIB for

confirmation of ANA pattern • Example 3: Ro Ab: Use ANA and ENA/EIB: confirm presence of Ro in ANA • Plays a very important role in early diagnosis and better prognosis for patients

Automation

• Run when significant numbers to reduce reagent wastage • If placed in an automated lab, risk of running daily increasing reagent consumables

Re-using bar-code numbers

• Received a sample in the laboratory with the same bar-code as a patient 4 months earlier • Multiple staff spent 2 hours trying to sort out the problem • The sample would scan in to Ultra as the patient 4 months earlier • Sample had to be renumbered so that the system could accept the sample

o Involves Lab Staff: picked up issue o Managers: trying to work out the problem

Troubleshooting issue o Data Entry: renumber the sample, re-enter

Laboratory Benefits

• Request form that was hard to interpret • Staff member consulted with our pathologist • Patient was in the hospital, pathologist went and visited and liaised with practitioner • Enable more specific testing to be formed • Allowed an earlier diagnosis, as the pathologist had the skill set to know what specific

testing should be performed Laboratory: Saving Lives

• Dr requested an ENA • ENA positive, with a UPL (undetermined precipitin line)

o Identifying UPL is a big area of research, which will lead to better diagnosis for patients

• Lab decided to perform additional Myositis testing • MYI: showed a strong Ku antibody • Pathologist went to the ward to speak to Dr • Discovered the patient had lung scarring • Enabled a much quicker diagnosis and better outcome for patient • THIS DID SAVE THIS PATIENTS LIFE

As with the specific feedback about Lyell McEwin Hospital, I have directed that these issues relating to FMC be considered by the relevant managers in refining the model. I can support further dialogue involving the PSA and their members about this if required. Some of these matters are also

Page 17 of 25

addressed in my response to feedback document dated 9 February 2017, and elsewhere in this document. FMC - Data Entry 1. Specimen Reception - report says 0.8 position, but all bloods will still require second check with regard to correct patient detail, dab, mismatch or mislabelled. How is this process likely to be managed with only 0.8 staff? EPLIS will create different ways of working. As above the refined staffing model is yet to be finalised and consulted. 2. It appears as though there will be a loss of continuity of point-of-care testing. Currently different lab staff from across directorates, (such as Haematology & Biochemistry) both maintain the machinery and assist with blood gas/troponin/diabetes testing. Has this been taken into consideration, if not why not? Who is going to perform all these tests considering the suggested reduced staff numbers? 3. Bone Marrow Clinics - Theatre staff are currently assisted by Haematology Lab staff - Has this been taken into consideration, if not why not? This will be factored into detailed plans. 4. Flinders Private wards and the FMC Women's Health Clinic will still require printed and sorted reports. 5. Currently Data Entry Staff frequently process Doctor add-on tests and must do so within required time constraints. Who is going to perform all these tests considering the suggested reduced staff numbers? Detailed plans will provide sufficient capacity for essential tasks. 6. Currently Noarlunga hospital is still defined as a regional hospital rather then a metropolitan hospital. It is our understanding that all regional labs are out of scope for the review. The surrounding suburbs of Seaford, Noarlunga, Meadows, Aldinga etc. are all experiencing large population growth. Has the regional status and resultant funding of this lab been reconciled with expected increases in patient presentations with an increased population growth? If not why not? 7. Is Noarlunga Hospital still defined and funded as regional hospital? If so why? 8. Paediatric/Alliqot and Samples that need dilution. This is a manual task that cannot be automated. 9. How will a proposed reduction of 10 staff (8 FTE) to 4 FTE be able to maintain all the workload demands outlined in all of the above issues? The impact of EPAS will inform final data entry requirements and will be factored into detailed plans. QEH - Response to Proposal 1. Services not included in report:

• stem cell infusion, this area is increasing • Renal Week once per month emergency bone marrow • add-ons • phone calls/enquiries • emergencies (stabbing occurred during our meeting, needed urgent test performed)

2. Transfusion - one case is not the same as another, all have different times to completion. The proposal simplifies "tests" to standard time taken. Inaccurate.

Page 18 of 25

3. Communication will be less as clinician and lab are separated with centralisation 4. Time will be wasted and lives put at risk trying to track down clinicians off site 5. QEH currently performs back up role to RAH is RAH goes down for any reason. Reduced staffing will make it impossible to provide back up. 6. SA Pathology used to perform much better prior to IMVS takeover. IMVS software was a debacle and slowed down most processes. 7. Haematology and Morphology tests are high product usage, lots of tests, high degree of manual films required, human must assess films. Reduced staffing will impact on quality of services 8. With nRAH coming on stream, QEH becomes Day Surgery - this will lead to increased bone marrows, increased time, which is not factored in. 9. Re-skilling to fit the new model will take time, not factored in. 10. Sampling process queried - hearsay - LMH on a Melbourne Cup Day?!!! 11. not covered under the review is the number of add - on requests we have to do the admin for and process. There are around 100 per day - 700 per week which equates to about 35,000 per year. 12. Extra work that perhaps was not included being:

• Blood gases, add on requests, phoning Doctors and wards regarding many issues, e.g. critical results, haemolysis, short samples, incorrect specimen received,

• Coag Lab requires a lot of phone calls. Phoning switch to find Doctors pager number to then call Doctor.

• Also Instrument maintenance and trouble shooting, assay problems, problem solving QC &Calibrator errors and also reagent issues, also patient result investigations, when unusual results appear and we have to be sure of the results before contacting the Doctor, not all results are normal, some patients are very sick and or results could be contaminated etc. So Technical staff can take time in confirming results.

13. Recently I was working on a weekend and I had a very very high Vane result, which required diluting in the Calibrator level 1. This investigation took me several hours and also included phoning a colleague - On-call and also the Pathologist on-call before I phoned the Doctor. I had never had a result that high requiring me to dilute in the Calibrator. All of which can be very time consuming. 14. Also training staff on the spinning bench and which I have spent many years assisting with training staff in Chemistry, especially with the cross training of staff from Haematology. This takes a lot of time. 15. Supervisors at this stage spend very little time in the Lab assisting with routine lab work, so are they included in the expected rostering of lab work? Are Medical scientists allowed the time for QC work, QAP's, auditing, Nata requirements, work up of instruments, continuation of monitoring of QC's and Calibrations, also new reagent, QC & calibrator set up and monitoring. What about Pipette calibrations? 16. Plus have they included busier times which include Renal Week, plus bone marrows and Haematology patient samples. 17. Annual Leave, Sick Leave, Retention Leave, Long Service Leave - were they considered in the staffing numbers especially if the data collected was flawed? This matter requires clarification, and would therefore be best dealt with through discussion. I note that I have addressed matters regarding benchmarking and future staffing in this document, as well as in my response to feedback document dated 9 February 2017.

Page 19 of 25

18. I also had a thought about if the spinning bench be staffed in this new plan by OPS-1 & OPS-2 staff. Does this mean we the Technical staff have to train them to then have them take over our jobs and then we get told we no longer have our job? Part of this process will be to ensure staff are working to their full scope of practice and in accordance with the work level definitions commensurate with their classification. With regard to training of staff, this will be considered as part of the implementation of the new structure. 19. Knowing the data was taken from one Lab at LMH on Melbourne Cup Day, 18 months ago is very limiting with data, considering everything is on computer you would think data would be collected at every laboratory over at least 1 month to give more of an accurate collection of data. 20. Also someone made mention that Bone Marrows could increase at QEH which would require more staff as this is a long procedure from start to finish, and Doctors require emergency Bone Marrows to be performed at times. Is bone marrow testing likely to increase at QEH? We do not anticipate significant increase in bone marrow procedures at TQEH. 21. Regarding Blood Transfusion we understand there will be cross training staff between Transfusion and Automated Lab which can take many many months to achieve. There will clearly be a long transition before any efficiencies can be achieved, in fact if jobs are cut before the assumed enablers are in place and running appropriately and staff are trained there could be a great period of insatiability and high risk to patients. 22. Would it be possible to allow reduction of staff to occur naturally, rather than cut staff dramatically and then realise that too many staff were cut and Quality and standards be affected, which can result in patient care being compromised . Natural attrition alone will not deliver the workforce model that we require. QEH - Automated 1. Backup for RAH - The QEH is currently expected to be the backup laboratory for the RAH - this has not been included in the review. Why not? 2. Why is it that the efficiencies of senior management roles nor have all Directorates been included in this latest proposal? Will there be a review to include possible improved efficiencies in the job roles and Directorates not in scope of this proposal? If so what and if not why not? This is addressed in my response to feedback document dated 9 February 2017 regarding the perceived imbalance of proposed staff reductions. 3. The system was archaic particularly the IT system Ultra when some of us started working for SA Path a good number of years ago. The "management" in guiding the organisation to the current times has been minimal, lacking initiative, and ignoring of staff suggestions. Are these intended to be the people guiding the change? (That is a troubling situation.) It is difficult to answer your question without more information about the areas of concern. I did acknowledge change management issues in my response to consultation feedback document dated 9 February 2017. In addition to EAP services, we will be looking at ways to address this matter further. If you can provide more detail, I would like to discuss this further with the PSA. 4. There has also been inference that SA Paths labs difficulties are due to the lack of hard work by the staff, which is insulting. 5. Regarding the proposed core lab for routine and private samples - why duplicate two labs in the city?

Page 20 of 25

I am not clear on the meaning of this question, and would therefore be best dealt with through discussion. 6. Annual competency testing is not included in the Proposal while these requirements are increasing constantly. This includes Work Health & Safety (WHS) modules like manual handling, hand hygiene, fire safety etc. and competency testing in all disciplines (Haematology, Biochemistry, Coagulation, Morphology, Blood Transfusion etc). Front end processing with the proposed increase in multi-skilled lab staff will have high demands on the competency training added to the need for increased testing , all of which takes up significant time for each staff member. Has this been considered in terms of impacts on service quality, and workload? 7. It is our view that compared to a specialised workforce, extensive multiskilling will result in increased errors. There is only so much information someone can keep in their head, this will also be compounded by learning new systems as well!! (EPAS, EPLIS and the new equipment). 8. There is rarely time to adequately consult around procedures and multiple procedure revisions now. This will become untenable under the weight of work, in multi-disciplines and the cuts in staff numbers further jeopardisi ng patient safety and creating stress for staff. 9. Not enough staff to cover Annual Leave, Long Service Leave, retention leave, breaks. 10. Not taken into account: Bone Marrows, Blood ???, Machine Maintenance, Semens, Add ens (EPAS has created more add one for chemistry). 11. Time taken to do RCPA's 12. Training/ringing through results. Lab cleaning bins etc. In relation to questions 5 to 12, please refer to my earlier response above regarding scientist duties. 13. Noticed Night shift were 10.5 hour shifts. This feedback is noted, and will be addressed to comply with the Enterprise Agreement. 14. Ensure part-time workers considered. Not all staff can do all shifts - will this change cater for people with disabilities. TQEH Blood Transfusion Lab - Haematology Directorate 1. Rostering to meet current needs of LSL or Retention Leave is difficult to fill now, let alone with 69% fewer staff. 2. The one Tuesday at LMH (Melbourne cup day!) is not representative of Lab work times. How were figures determined: What tests constitute urgent or non-urgent? 3. Which UK Lab was the benchmark? Is it similar to work done @ SA Pathology? 4. In the transfusion Lab (TMU) - staffing levels in the proposal only relate to number of specimens . 5. There is no allowance for any stock/inventory control. 6. This includes - ordering stock (Red Cells, Platelets, Plasma, manufactured products)

• unpacking and receiving stock on LIS • blood grouping of Red Cells • maintenance of stock levels (daily counting and changing status on LIS) • Red Cell and pit 'bloodmove' project - the receiving and sending of near expiry stock) • issuing of products to patients in hospitals • issuing of products off site to patients • maintenance and QC of cold room and fridges

Page 21 of 25

• provision of products to MedStar retrieval 7. No allowance for equipment QC. 8. No allowance for other work e.g. stem cell infusions - which removes one staff member for 3-4 hours. This year to date we have had 24 stem cell infusions. 9. No allowance for extended testing - e.g. complex antibody investigations. Each one can remove a staff member for 1-3 hours. 10. No allowance for dealing with transfusion reaction checks, notices of bacterial contamination etc. 11. Workload in TMU is not linear - you cannot reduce staff by 30% if number of specimens reduce by 30%. 12. Currently TQEH has a Haematology/Oncology ward with high activity patients that need a high level of transfusion support, in terms of usage of blood and products. The feedback above regarding TQEH is noted. I believe most of the matters raised here, particularly with regards to scientist roles, have been addressed earlier in this document, or in my response to feedback document dated 9 February 2017. Women's and Children's - Response to Proposal 1. "Pathology at Tipping Point" suggesting that the UK system is failing. If UK is failing then why use this as a benchmark?!! 2. English - Cancer Research Foundation has concluded: • tests for cancer are at a bottleneck in Pathology • tests not being done in time, patients lives at risk through blood condition not being assessed early enough • now advocating for recruitment 3. Royal College of Pathologists (Australia) - how can you benchmark when numbers are unreliable? This matter has been addressed earlier in this document. 4. Finance people have provided the figures with no regard for the complexity of tests or the different times taken to perform the variety of tests 5. NCOP comparisons (between Australian states - Vic Nsw SA) - 1 test in SA can equate to 4 requests. Each request in the other states counted as 1 test. Figures hugely distorted in terms of cost per test. SA actually performs better than others when this change is utilised so why benchmark against the other states? The role and limitations of benchmarking data in this process have been addressed earlier in this document. 6. Media reports in late November 2016 - UK Health to receive $3.Sb injection into health. 7. Original EY report recommended 22 consultants to go. Current proposal sees O drop. Why the change? The cost of 22 consultants would cover many TGO/Msc/OPS FTE. This relates to the transfer of management responsibilities for clinical services to Local Health Networks (also referred to as 5.2 Clinical Service Delivery initiative of the overall Efficiency Improvement Program).

Page 22 of 25

The matters raised above in relation to WCH are noted I. believe most of the matters raised here have been addressed earlier in this document, or in my response to feedback document dated 9 February 2017. WCH - Genetics and Molecular Pathology 1. There is only a small number of people employed and trained to perform the tasks in my area so a reduction in staff numbers would have a huge affect on the remaining staff members an service deliver. 2. Turn around times (TAT) would be increased with less staff, although there are already staff who do regular unpaid overtime in order to keep TAT down. 3. It is very difficult to have time off for things such as work related study as there is nobody to cover your work load so after study leave is not approved, so any reduction in staff will make this next to impossible to get even though SA Pathology say that they support training it is often not a reality. 4. It will make it harder to cover staff absences due to sick leave and annual leave as it is already difficult to negotiate annual leave when you need it. 5. Remaining staff will be under more pressure to maintain TAT and may feel stressed about the extra amount of work that they are expected to do. Issues regarding turnaround times and staffing have been addressed in this document. WCH - Haematology - Leukaemia/Cancer Diagnostics The Women's & Children's Haematology laboratory is the primary reference Laboratory for Paediatric oncology and Leukaemia for all of SA and NT. The Childhood Cancer Clinic has had an ever increasing success rate & better long term outcomes for sick children because of our ability to provide early and better diagnosis of childhood leukaemia & other cancers. The treating Doctors rely on the Medical Scientists for processing and delivering the results for diagnosis and treatment. With constantly improving methods of testing and treatment we have had an steadily declining mortality rate among children which in itself creates a, very welcome, increase in ongoing workload. It seems that the proposed configuration and supporting workforce numbers may in reality undermine our success and increase workload. The Medical Scientists in Haematology are deeply concerned about the changes proposed by EY with the express aim to increase efficiency and reduce costs for SA Pathology. The concerns , while they are organisation-wide, are focussed primarily on the implementation of the Rapid Response laboratories (RRLs). Proposed for all the major hospitals other that nRAH. While on the surface it would seem an efficiency to reduce the number of samples being received into a laboratory (and subsequent staff reductions), the reality is somewhat different. The samples being sent elsewhere are those which are not required to have a result within the necessary 2 hours turn-around time (TAT) . These samples are typically those which are simple to handle and are not those requiring more detailed and labour-intensive work . The samples that will be handled by the RRL are therefore the most laborious. The correlation of sample number reduction to staff reduction should therefore be non-linear. Since the vast majority of samples at the WCH laboratories originate from within the hospital, it may well be that by sending them off-site we are just guaranteeing an avoidable delay, as we transport them into a central laboratory, only to be run on the same analysers which we have here.

Page 23 of 25

This seems illogical, and would put at risk the occasional patient who comes through clinic as a non- urgent patient, but whose results show a serious abnormality (e.g. HELLP syndrome, thrombocytopenia) requiring more rapid intervention. There are also patients, namely in obstetric, whose status changes rapidly, where results, while initially not urgent, are required immediately if an emergency caesarean or epidural procedure is initiated. 1. How will this be handled if samples are in transit, particularly as there is no individual tracking of samples in courier bags using the Millennium software? Where patients have a higher risk, the location of testing will be taken into account. While it might seem prudent to reduce the laboratories to RRL status in hospitals that are themselves being reduced in scope (namely Modbury and QEH), the WCH will maintain services and its status as a referral and tertiary hospital for children and obstetric services. There is little justification in reducing the acute laboratory services if these and the numerous other clinical services are being maintained. It is intended that the notion of RRL will be reviewed and better described as a Core Lab in the next consultation process. Modbury - Response to Proposal The intra NALHN transfer of services which were initiated by the Transforming Health agenda decreased Madbury lab work by about 20%, however the impact on the LMH lab was not an equivalent transfer of 20% it actually resulted in more demand and increase in workload. 1. 150 panels per week have reduced since this change but there has been an increase in ED (hospital work) and private work. What is the plan to manage with surges in seasonal demand? 2. What impacts on productivity and efficiency rates have been captured in the bench marking in relation to the Tri-State agreement for specialist testing? 3. What impacts on productivity and efficiency rates have been captured in the bench marking in relation to the practices of 'coning' and 'super coning'? 4. What is the EPAS roll out schedule for each Hospital and lab? We will provide this information as it is available as we recognise the impact of dependencies on the proposals. 5. What is the EPLIS roll out schedule or each Hospital and lab? As above. 6. There will a transition and adjustment period with the introduction of EPLIS. It is our view the proposed change to include data entry at the collection site will cause patient contact time to expand. Until EPLIS is up and running, waiting time for blood collection will increase since the Phlebotomist or Nurse will need to data entry patient details in the computer before bleeding patients. Has this been calculated into the expected efficiencies and impacts on patient TATs and workload? This matter has been dealt with earlier in this document. 7. The Federal governments proposal to reduce or cease after hours doctor for home visits will increase ED presentations. Has this been calculated into likely increased presentations? If not why not?

Page 24 of 25

There are many factors that bear on ED activity. ED presentations are increasing everywhere. As well there are seasonal peaks and troughs. We have not specifically addressed the question regarding home visit funding and I am seeking clarification from ED experts on this matter. 8. The stats in the proposal does not show duties and time taken with telephone calls, doctor enquiries, patient enquiries and staff enquiries. Why just rely on FTE and sample numbers for certain tests to determine levels of efficiencies? Issues regarding scientist duties are covered elsewhere in this document. General Comments: 1. What is OACIS ordering rate at each location, particularly at LMH? This matter requires clarification, and would therefore be best dealt with through discussion. 2. FTE in the Proposal is calculated proportionally according to test volumes. However there is a clear incongruence with this method to then determine appropriate staffing levels, more so when then the current staffing levels at the LMH have been underestimated and when this is the sample that all proposed staffing levels at each labs is then based. This issue has been dealt with elsewhere in the document. 3. The method applied to determine the proposed FTE's in the Core lab model does not appear take into account the fact that you cannot move all non-urgent and a range of specific testing to a single purpose facility. This matter requires clarification, and would therefore be best dealt with through discussion. 4. We require more detail of how the single reception point for samples that are not currently undertaken at the LMH is expected to work:

• Will these samples be delivered to SA Pathology or to a Private Pathology Service, or both and if both what proportion at each?

• Where is the new facility likely to be? Is there a method in place that will • calculate the logistical impacts such as transportation times and TAT? If not why not? • What is the expected staffing levels, including classification and numbers as well as the

expected skill set of the receiving centre staff? • There is no consideration being given to referring SA Pathology samples to any provider other than

SA Pathology. • The details of laboratory facilities are being considered through the ongoing working group

process. • Issues with TAT have been dealt with elsewhere in this document. • As outlined elsewhere there will be further consideration and consultation about staffing.

Page 25 of 25