And ‘watering down’ standards won’t fix the workforce issue.
Standards should remain in the hands of those with professional experience, and workforce reforms should be paid for by governments, not practitioners through their registration fees, says the AMA.
Last year, the federal government initiated an independent review into the complexities of the National Registration and Accreditation Scheme, following concerns over inconsistencies.
In its response to the review’s first consultation paper, the AMA said the review did not sufficiently address transparency around AHPRA registration fees and funding.
“At Senate estimates on 26 October 2023, Senator David Pocock asked Mr Martin Fletcher, AHPRA CEO, about what had contributed to the 16% fee increase for medical practitioners,” read its submission.
“Mr Fletcher’s response demonstrated that doctors’ fees were covering the costs of reforms to the health system, which should have been paid for by health ministers.”
Workforce reforms, like the cosmetic surgery reforms, should not be funded by AHPRA registration fees, said the AMA.
“To be clear, we do not oppose these reforms — we oppose health ministers using AHPRA registration fees to fund them.
“The AMA is legitimately concerned if the health ministers turn the National Scheme into a health workforce body, the fees of the registrants will be funding this endeavour.”
The association said it was supportive of stronger regulatory connections – for example, say between the AHPRA and the TGA “on concerning developments in closed-loop prescribing models, largely focused on cannabis”.
But, again, the AMA added that additional funding should be provided if the National Scheme was to take on those additional roles.
It was “extremely disappointed” in the review’s lacklustre “half a page” exploration of the impact of AHPRA notifications on practitioners.
“The AMA calls for the review team to place practitioner distress experienced as a result of the National Scheme at a higher priority,” it said.
“Practitioner distress and complexity of the National Scheme go hand-in-hand and therefore must be considered in parallel.”
The AMA also raised concerns over the review’s intent to use the National Scheme as a workforce lever and rejected proposed reforms to give health ministers greater powers over accreditation.
“[The review] stipulates that any reforms to the design and delivery of accreditation functions should support workforce reform and needs,” the AMA said.
“The AMA sees this statement as problematic.
“Accreditation exists as part of a framework to ensure that Australian doctors are trained to the highest standards in the world – delivering world leading care to patients.
“Any introduction of a workforce focus will lower the standards of the medical professions and specialities.”
AMA president Dr Danielle McMullen said the National Scheme must retain a focus on the quality of patient care.
“Watering down accreditation standards will not solve current workforce shortages and represents short-term thinking,” Dr McMullen said.
“Accreditation is part of a framework to ensure Australian doctors are trained to the highest standards in the world.
“The review seems intent on exploring changes that would ultimately lower the standards of care that patients in Australia receive.”
The AMA called for workforce shortages to be addressed outside the National Scheme, in part through the establishment of an independent national body tasked with advising ministers on how to build a sustainable healthcare workforce.
The review also floated the establishment of cross-profession regulatory structures, as opposed to the current Board-led approach.
The AMA dismissed the idea, but agreed there could be space for greater collaboration and resource sharing.
“Doctors want the regulatory decisions about them to be made by doctors,” it said.
“It would be inappropriate for a doctor to make a regulatory decision about the practice of another health professional where they have not trained in or participated in the education, training and core competencies of that profession.
However, the AMA supported having a single front door for patients’ complaints against health professionals.
“A single health complaints entity requires commitment by health ministers nationally working towards uniformity,” it said.
“Transition into this comes at a cost and health ministers must be prepared to fund any new entity proposed.
“Further consultation must be conducted with key stakeholders to ensure funding, infrastructure and processes remain fully transparent.”
ACRRM, which also released its submission this week, flagged concerns over undermining the remote and rural workforce.
It also called for the recognition of the role of medical colleges and other health professional organisations in care provision and in curating standards.
“While the review seeks to identify opportunities for improvement through changes in the NRAS, we would urge a precautionary approach that also recognises what could be lost,” said ACRRM.
“The benefits from professional organisations are more than the sum of their parts, and divesting key functions from them may fundamentally undermine their role and contribution.”
ACRRM said stewardship for standards should remain with the bodies with the relevant professional expertise.
“Delegating stewardship to a bureaucratic third party would decouple decision-making from knowledge and understanding of the science and its human application,” it said.
The college called for greater collaboration and coordination.
“There is currently an unhelpful distance between colleges and decision makers in many NRAS processes,” read the submission.
“In the context of rural and remote health services, this has been an issue for decades.
“We would see opportunity to create better structures for professional organisations and other key stakeholders and the NRAS authorities to engage constructively on key issues particularly where there is a need for urgency.”
