Bills Digest No. 137 2003-04
Health Legislation Amendment (Podiatric Surgery and
Other Matters) Bill 2004
WARNING:
This Digest was prepared for debate. It reflects the legislation as
introduced and does not canvass subsequent amendments. This Digest
does not have any official legal status. Other sources should be
consulted to determine the subsequent official status of the
Bill.
CONTENTS
Passage History
Purpose
Background
Main Provisions
Concluding Comments
Endnotes
Contact Officer & Copyright Details
Passage History
Health
Legislation Amendment (Podiatric Surgery and Other Matters) Bill
2004
Date Introduced:
1 April 2004
House: House of Representatives
Portfolio: Health and Ageing
Commencement:
The different parts of
Schedule 1 of the Bill have various commencement dates, as
indicated under Main provisions , below.
This Bill is an
omnibus bill which proposes various, unrelated amendments to
legislation within the Health and Ageing portfolio:
-
Schedule 1, Part 1 provides for amendments to the Health
Insurance Act 1973 to enable private health insurance funds to
provide benefits for the hospital treatment costs associated with
foot surgery performed on admitted patients by accredited
podiatrists
-
Schedule 1, Part 2 provides for amendments to paragraphs within
the Health Insurance Act 1973 which relate to the
provision by private hospitals of Hospital Casemix Protocol data to
the Department of Health and Ageing
-
Schedule 1, Part 3 provides for amendments to provisions within
the National Health Act 1953 which govern the
Pharmaceutical Benefits Scheme (PBS), to provide for the continuing
supply of pharmaceutical benefits in the event of the death of a
PBS approved pharmacist
-
Schedule 1, Part 4 provides for minor amendments to the
Health and Other Services (Compensation) Act 1995 and the
Health Insurance Amendment (Diagnostic Imaging, Radiation
Oncology and Other Measures) Act 2003 to correct drafting
errors.
This part of the Bill proposes amendments to
the Health Insurance Act 1973 to enable private health
insurance funds to provide benefits from their hospital tables for
hospital accommodation and nursing costs associated with foot
surgery performed in hospitals by registered podiatric
surgeons.
Podiatry (also known as chiropody) deals with
the prevention, diagnosis, treatment and rehabilitation of medical
and surgical conditions of the feet and lower limbs .(1)
Podiatrists treat a range of conditions, including those which
result from bone and joint disorders such as arthritis and
soft-tissue and muscular pathologies, as well as neurological and
circulatory disease .(2) Podiatric surgery is a branch
of podiatry, specialising in the treatment of feet and lower limb
conditions which warrant surgical intervention.(3)
The majority of work podiatrists do involves
older patients experiencing difficulty with mobility as a result of
injury, structural problems, or the effects of chronic diseases.
Diabetes, for example, if not adequately controlled, can damage
nerves and cause problems with blood supply to the feet. Foot
conditions often develop with age; subsequently, demand for
podiatrists is likely to grow as the Australian population
ages.(4)
According to the Podiatry Labour Force Survey
conducted by the Australian Institute of Health and Welfare (AIHW)
in 1999, there are over 2200 registered podiatrists in Australia.
The podiatry workforce has grown rapidly in recent years: it
increased by 42.7 per cent over the 8-year period 1991 to
1999.(5) By contrast, there are only a small number of
podiatric surgeons approximately 25 in Australia.(6) The
majority of podiatrists counted in the AIHW s 1999 survey (74.5 per
cent) worked in the private sector.(7)
The practice of podiatry in Australia is
regulated by state and territory legislation.(8) To
become a podiatrist, a practitioner must complete a recognised
undergraduate degree, and be registered to practise with a state or
territory registration board.(9) Podiatric surgeons are
podiatrists who have undergone additional postgraduate training,
and who have successfully completed the requirements for admission
to the Australasian College of Podiatric Surgeons
(ACPS).(10) They are not required to have medical
degrees.
Under state and territory legislation,
podiatrists are licensed to perform a limited range of foot
surgery, including soft tissue procedures such as toe nail
removal.(11) The vast majority of these kinds of
procedures are performed in podiatrists rooms, community health
centres, and some hospitals (though generally in out-patient
facilities). Podiatric surgeons can perform more complex surgical
procedures, including deep tissue surgery and some bone surgery
(such as hammer toe corrections).(12) Many of these
procedures are also performed in podiatrists rooms, but as they may
require the use of general anaesthetic, they tend to be performed
in hospitals.
Podiatric surgeons have been performing foot
surgery in Australia since the early 1970s. However, podiatrists
and podiatric surgeons are not recognised as medical practitioners
(they are classified as allied health professionals). Consequently,
the number of hospitals both private and public in which podiatric
surgeons are able to perform surgical operations is very
limited.(13)
As the section below on podiatry and health
insurance discusses, podiatrists and podiatric surgeons services do
not attract Medicare rebates, and are only eligible for private
health insurance coverage in some circumstances. Subsequently, much
of the foot surgery that could be performed by podiatric surgeons
is performed by orthopaedic surgeons instead. However, there is
evidence to suggest that the treatment outcomes of foot conditions
treated by podiatrists and podiatric surgeons are as good, and in
many cases better, than when the same conditions are treated by
orthopaedic surgeons and other registered physicians.
Therefore, there seem to be good reasons, from
a public health perspective alone, for expanding the availability
of podiatric surgeons services within the Australian health
system.(14) Such an expansion would bring Australia into
line with treatment patterns elsewhere: in the USA, for example,
podiatrists perform almost two thirds of all major (orthopaedic)
foot surgery (compared with only 10 15 per cent in Australia). In
the UK, podiatric surgeons operate widely within the National
Health Service, the UK s public health system (whereas they tend to
operate almost exclusively in the private sector in
Australia).(15)
Until this year, podiatry and the services of
other allied health care professionals have not been eligible for
any rebates under the Medicare program Australia s publicly funded
health insurance scheme. According to the Explanatory Memorandum
circulated with this Bill:
Extending Medicare benefits coverage to a wider
range of allied health care providers (which includes podiatrists)
has been considered on other occasions and each time it has been
decided that it is not possible to extend these arrangements given
the economic climate. This is still the case.(16)
However, the revised Medicare Plus package
negotiated earlier this year between independent senators and the
government has resulted in Medicare benefits being made available,
in some circumstances, for services provided by allied health care
professionals (including podiatrists) for the first
time.(17) However, because the new benefits will only
apply to consultations with allied health professionals for
services delivered for and on behalf of a GP , it is unlikely they
will extend to surgical procedures performed by podiatric
surgeons.
Private health insurance which includes ancillary
(or extras) cover provides cover for non-hospital services which
are generally not covered by Medicare. Out of hospital services
provided by podiatrists and podiatric surgeons (as well as those
provided by other allied health professionals such as dentists,
chiropractors, home nurses, physiotherapists, and occupational
therapists) are covered by most private health insurance policies
with ancillary cover.
As mentioned above, foot surgery performed by
podiatric surgeons often needs to take place in hospital because of
the need for general anaesthetic. However, in-hospital
foot surgery performed by podiatric surgeons is not covered by
private health insurance. Under the Health Insurance Act,
private health insurance benefits for in-hospital treatment are
only payable for treatment performed by providers of professional
attention , which includes medical practitioners, nurses with
obstetric qualifications (midwifes), and dental practitioners.
Podiatric surgeons are not recognised as medical practitioners, and
therefore are not included as providers of professional attention
under the Health Insurance Act. In its 2003 assessment of
governments progress in implementing the National Competition
Policy and related reforms, the National Competition Council found
that this arrangement restricts competition between medical
practitioners and substitute health care providers , such as
podiatrists.(18)
Patients with ancillary health cover may be
eligible for limited benefits towards the cost of podiatric surgery
performed in a hospital, but the patient usually has to pay the
full cost of hospital accommodation and nursing care. In other
words, people who choose to have foot surgery performed by
podiatric surgeons in hospital are likely to be liable for all of
the out-of-pocket costs associated with the surgery. The amendments
proposed by this Bill will make it possible for private health
insurance companies to pay benefits towards the cost of hospital
accommodation and nursing care for podiatric surgery performed on
admitted patients.(19)
The extension of private health insurance
benefits to foot surgery performed by podiatric surgeons raises
some issues about public patients equity of access to equivalent
kinds of treatment (since podiatric surgeons practice in only a
very small number of public hospitals). However, as noted above,
orthopaedic surgeons also perform the kinds of surgery in which
podiatric surgeons specialise.(20) Public patients
therefore have access to the same type of treatment which this Bill
will enable private health insurance funds to provide cover for. It
is also important to bear in mind that the amendments proposed by
this Bill will not alter existing foot surgery practice, and in the
short term, are unlikely to significantly alter treatment patterns.
That is, the Bill, if passed, will not change the kinds of
procedures podiatric surgeons currently are and are not able to
perform, or where they are able to perform them. Rather, it will
simply allow private health insurance funds to pay benefits for
accommodation and nursing costs associated with procedures which
are already being performed.
Both the Australasian Podiatry Council, the
peak body representing podiatrists in Australia, and the
Australasian College of Podiatric Surgeons, the body which
develops, implements and monitors guidelines for the practice of
podiatric surgery in Australia, fully support the amendments
proposed by the Bill.
According to the Explanatory Memorandum
accompanying the Bill, certain medical groups have expressed
concern about the safety and quality of surgical procedures
performed by podiatric surgeons, and the level of training
podiatric surgeons receive. However, these concerns are rarely
expressed publicly. Further, there is little, if any, clinical
evidence which supports these concerns. In any case, as noted
above, the amendments proposed by this Bill will not alter existing
foot surgery practice, but simply make it possible for private
health insurance funds to provide some benefits for in hospital
foot surgery performed by podiatric surgeons.
This part of the Bill proposes amendments to
provisions within the Health Insurance Act and the National Health
Act which govern the collection of data about the activities and
outputs of private hospitals in Australia. The proposed amendments
will update the existing legislative provisions to reflect current
practice for the collection of this data and are likely to be
uncontroversial.
Data on Australia s hospitals and the health
system is collected and published by a number of
agencies.(21) Detailed and comprehensive data collection
is important for monitoring the effectiveness of Australia s
hospitals and health care system, as well as for planning for the
future.
The Hospital Casemix Protocol Data Collection
which is managed by the Department of Health and Ageing was
established to monitor the deregulation of the private health
industry, following the 1995 Private Health Insurance Reform
legislation.(22) The Hospital Casemix Protocol refers to
the arrangement whereby private hospitals provide the Department of
Health and Ageing with a series of patient de-identified casemix
data. Patient de-identified data means data which does not identify
individual patients. Casemix data refers to data which incorporates
both the number and types of patients treated, and the mix of
diagnoses, treatments, procedures, and so on provided to patients.
Casemix data is a way of measuring, monitoring and comparing
hospitals output and activities.(23) Private hospitals
are required to supply this data under Section 23EA of the Health
Insurance Act:
For the purposes of this Act and the National
Health Act 1953, a declared private hospital must provide data
specified in the Hospital Casemix Protocol:
(a) in a patient identifiable state, to a
registered private health insurance organization which has an
applicable benefits agreement with the patient;
(b) in a patient de-identified state to a data
bureau established for the purpose of receiving and disseminating
such data.
The Department releases the Hospital Casemix
Protocol data annually to all private hospitals, registered health
funds, and various external stakeholders. The data can be used to
analyse trends, compare variations in charges between different
hospitals, and examine the effects of clinical and patient
demographics.(24)
The Private
Hospitals Data Bureau was established in 1997, following the 1995
amendments to the Health Insurance Act. Between 1997 and 2002, the
Department funded an external agency to perform the functions of
the Private Hospitals Data Bureau, and to collect Hospital Casemix
Protocol data from private hospitals on the Department's behalf.
However, during this time, both private hospitals and the
Department itself experienced problems with access to the data, and
with the completeness of the data collection. Subsequently, since
January 2003, the Department has managed the Private Hospitals Data
Bureau internally. Since the Department took over the management of
the Private Hospitals Data Bureau, it has worked with the private
hospital industry to improve the accessibility of the data, the
completeness of the data collection, and to streamline the process
of collecting the data itself.
The first amendment proposed by this part of
the Bill removes the reference in Section 23EA of the Health
Insurance Act to the data bureau , and replaces it with the
Department . This will not change existing practice, but rather
reflects the current arrangements.
The second amendment proposed by this part of
the Bill inserts a new subsection in the National Health Act, which
will require day hospitals that is, facilities in which the
procedures performed do not require an overnight hospital stay to
provide both private health insurance funds and the Department with
the same Hospital Casemix Protocol data that private hospitals are
obliged to provide under the Health Insurance Act.
This amendment, if passed, may lead to a
change in existing practices, in that day hospitals have hitherto
not been required to provide health insurance funds or the
Department or the Private Hospitals Data Bureau, when it was in
existence with Hospital Casemix Protocol data (though many day
hospitals may already provide this information, even if they are
not under any legal obligation to do so). Imposing this requirement
on day hospitals will improve the comprehensiveness of the Hospital
Casemix Protocol Data Collection, and therefore the ability of the
Department and other stakeholders to monitor day hospitals output
and activity, as well as that of the private hospital sector as a
whole.
The Department will be required to observe
both the Privacy Act 1988, and the secrecy provisions in
section 135A of the National Health Act and section 130 of the
Health Insurance Act in using the data collected under the
provisions proposed by this part of the Bill.
The Australian Private Hospitals Association,
the peak body for private hospitals in Australia, supports both
amendments proposed by this part of the Bill. The Australasian Day
Surgery Association supports the amendments pertaining to the
provision of Hospital Casemix Protocol data by day hospitals.
This part of the Bill proposes a series of
amendments to provisions within the National Health Act
1953 which relate to the continuing supply of pharmaceutical
benefits in the event of the death of a pharmacist who was approved
to supply pharmaceutical benefits at or from particular
premises.
The proposed amendments seek to remove
deficiencies in the existing provisions. While the volume of
amendments proposed by this part is substantial compared to Parts 1
and 2 of Schedule 1 of the Bill, most of the amendments are
technical in nature and do not represent new policy. Therefore,
this part of the Bill is likely to be uncontroversial.
The Pharmaceutical Benefits Scheme (PBS) is
the publicly funded scheme for the subsidisation of medicines which
exists under the National Health Act. State and territory
legislation regulates the registration of pharmacists and the
practice of pharmacy (that is, the actual dispensing and
compounding of medicines). Under the National Health Act, however,
to supply PBS medicines, a pharmacy must be approved by the
Commonwealth Department of Health (on the recommendation of the
Australian Community Pharmacy Authority).(25)
State and territory legislation also provides
for legal personal representatives of deceased pharmacists estates
to continue deceased pharmacists businesses, as long as the actual
practice of pharmacy in the business is conducted by a registered
pharmacist.(26) There are provisions in section 90 of
the National Health Act for legal representatives of deceased
pharmacists to apply for approval to supply PBS medicines at or
from the premises at which the deceased pharmacist was approved by
the Commonwealth to supply pharmaceutical benefits that is, to
continue the deceased pharmacists business with respect to the
supply of PBS medicines. However, according to the Bill s
Explanatory Memorandum, this provision has been found to be
deficient in a number of respects. For example:
In some cases, the time period involved in
obtaining an approval under section 90 is lengthy. This is
particularly so if it is only viable for a legal representative to
apply for approval after probate or letters of administration are
granted.
In some instances, the legal personal
representative requests an Act of Grace payment be made to the
estate of the deceased approved pharmacist in relation to
pharmaceutical benefits supplied during the period following the
death of the approved pharmacist and before the granting of a
section 90 approval. In some cases the amount claimed is large, and
the ongoing viability of a pharmacy has been jeopardised by having
to carry this financial burden.(27)
The proposed amendments are intended to enable
a person who is, or is likely to become, an executor or
administrator of the estate of a deceased pharmacist, to apply for
permission to supply pharmaceutical benefits (for PBS purposes) at
or from the particular premises at which the deceased pharmacist
was approved. The amendments are also intended to clarify that in
cases where a beneficiary of a deceased approved pharmacist is not
a pharmacist, s/he may only apply under section 90 for approval to
supply pharmaceutical benefits in circumstances where he or she has
acquired the deceased approved pharmacists interest in the pharmacy
.(28)
The amendments do not give legal
representatives of deceased approved pharmacists the right to
practice pharmacy as noted above, state and territory legislation
regulates the registration of pharmacists and requires that, in the
event of the death of a pharmacist, the actual practice of pharmacy
must be carried out by a registered pharmacist. Nothing in section
90 of the National Health Act (or the amendments proposed by this
part of the Bill) authorizes the Secretary [of the Department of
Health and Ageing] to grant approval to a pharmacist in respect of
premises at which that pharmacist is not permitted, under the law
of the State or Territory in which the premises are situated, to
carry on business .(29) Rather, the amendments simply
seek to improve the process by which a person who acquires a
deceased pharmacist s interest in a pharmacy can apply for
reimbursement, under the PBS, for PBS medicines dispensed.
This part of the Bill proposes minor
amendments to other legislation within the health portfolio to
correct minor errors. The proposed amendments are discussed under
Main Provisions , below.
The following items all relate to the
Health Insurance Act 1973.
Item 1 inserts a definition
of accredited podiatrist to subsection 3(1) of the
Act.
Item 3 expands the Act s
definition of professional attention (which currently includes
treatment performed by or under the supervision of medical
practitioners, nurses with obstetric qualifications and dental
practitioners) to include podiatric treatment performed by an
accredited podiatrist.
Item 4 inserts two new
subsections (3AAA and 3AAB) which provide for the accreditation of
podiatrists by the Minister for the purposes of the Act, and for
appeal to the Administrative Appeals Tribunal for review of the
Minister s decision in this regard.
Schedule 1, Part 1 commences on a date to be
fixed by Proclamation, or if this does not occur within 6 months of
Royal Assent, on the first day after the end of that period.
Item 5 and Item
6 amend paragraphs of the Health Insurance Act
1973 and the National Health Act 1953 pertaining to
the collection of Hospital Casemix Protocol data, for the purposes
described in the Background section, above.
Schedule 1, Part 2 commences when the Act
receives Royal Assent.
The following items all relate to the
National Health Act 1953.
Item 7 and Item
8 repeal existing definitions of pharmacist and approved
pharmacist in subsections 4(1) and 84(1) respectively, and replace
them with revised definitions.
Item 10 inserts new
subsections (90(3AC) and 90(3AD)) defining when an interest in a
deceased pharmacists business has been acquired for the purposes of
the Act.
Item 12 prevents
beneficiaries of deceased approved pharmacists, who are not
pharmacists themselves, from applying for approval to supply
pharmaceutical benefits under section 90 unless they have acquired
the deceased approved pharmacist s interest in the pharmacy.
Item 13 inserts a new section
91 which sets out the process for granting approval to the executor
or administrator of the estate of a deceased approved pharmacist to
supply pharmaceutical benefits at or from the premises from which
the deceased pharmacist had been approved. Item 14
provides for appeal to the Administrative Appeals Tribunal for
review of decisions in this regard.
Schedule 1, Part 3 commences on a date to be
fixed by Proclamation, or if this does not occur within 6 months of
Royal Assent, on the first day after the end of that period.
Items 15 to 18 propose minor
amendments to the Health and Other Services (Compensation) Act
1995 and the Health Insurance Amendment (Diagnostic
Imaging, Radiation Oncology and Other Measures) Act 2003 to
amend typographical and other drafting errors.
The provisions in Schedule 1, Part 4 commence
immediately after the time specified for the commencement of the
relevant sections and items in the Acts this part of the Bill
amends.
None of the proposed
amendments contained in this Bill are significant in terms of
numbers of persons affected or in terms of government expenditure
or savings the financial impact of the Bill is negligible.
With the possible exception of Schedule 1,
Part 1, the proposed amendments do not represent any change to
existing policy or practice, but rather, will streamline, improve,
and/or codify existing arrangements, and are therefore likely to be
uncontroversial. As noted above, the amendments proposed by
Schedule 1, Part 1 (pertaining to podiatric surgery) raise some
questions about public patients ability to access the kinds of
treatment performed by podiatric surgeons, since orthopaedic
surgeons appear to have a monopoly on foot surgery performed in
public hospitals at present. However, the issue of whether or not
podiatric surgeons services should be made more widely available in
the public hospital system is beyond the scope of this Bill.
-
Australasian Podiatry Council (APODC) website: see: http://www.apodc.com.au/Podiatry%20in%20Australia/scope.htm
(accessed 9 May 2004).
-
ibid.
-
Australasian College of Podiatric Surgeons (ACPS) website: see:
http://www.acps.edu.au/surgery.html
(accessed 9 May 2004).
-
Australian Institute of Health and Welfare (AIHW), Podiatry
Labour Force 1999, National Health Labour Force Series, Number
23, AIHW, Canberra, 2002, p. 1.
-
ibid., pp. 5 7.
-
Explanatory Memorandum, p. 3.
-
AIHW, op. cit., pp.5 7
-
The Northern Territory, which does not regulate the practice of
podiatry, is the exception to this rule.
-
APODC website: see http://www.apodc.com.au/Education/Education.htm
(accessed 11 May 2004).
-
ACPS website: see http://www.acps.edu.au/surgery.html
(accessed 11 May 2004). The ACPS is the national organisation
responsible for the development, implementation and monitoring of
guidelines for the practice of podiatric surgery in Australia . The
ACPS was established in 1976 and is affiliated with the
Australasian Podiatry Council.
-
A podiatrists license to practice generally includes a license
to use local anaesthesia where appropriate. In some states, some
podiatrists are also licensed to prescribe and supply S4
(prescription only) drugs.
-
ACPS website: see http://www.acps.edu.au/surgery.html
(accessed 11 May 2004).
-
Less than 10 out of approx. 540 private hospitals have granted
podiatric surgeons admitting rights Explanatory Memorandum (p.3).
The number of public hospitals in which podiatric surgeons
have admitting rights is believed to be even less.
-
It should be pointed out, however, that the Explanatory
Memorandum (at p.6) notes that some medical groups have expressed
concern about the levels of training podiatric surgeons receive,
and whether they are amply qualified to perform non-superficial
procedures. Bennett and Patterson note that objections by the
medical profession to surgical podiatry have also focused on
podiatrists pharmacological knowledge and pre-operative and
post-operative care (Bennett and Patterson 1997, op. cit., p.48).
However, as noted above, there is little, if any, clinical evidence
which supports these concerns. Orthopaedic surgeons have also
expressed concerns about encroachment into their own specialty by
surgical podiatrists and the resulting economic competition
(Bennett and Patterson 1997, op. cit., p. 48).
-
Bennett and Patterson 1997, op. cit., pp.47 48.
-
Explanatory Memorandum, p. 3.
-
The measures contained in the Medicare Plus package will only
apply to services being provided by an allied health provider, for
and on behalf of a GP , for patients with a chronic condition and
complex care needs who are being managed under a multidisciplinary
care plan through the Enhanced Primary Care (EPC) program see the
Department of Health and Ageing s Medicare Plus
website:
http://www.health.gov.au/medicareplus/update_march_04/glance04.htm#section4
(accessed 11 May 2004). Doctors groups have expressed concern that
few doctors will take up the allied health measures contained in
Medicare Plus because of burdensome administrative arrangements
associated with the measures see Adam Cresswell and George Liondis,
Red tape hinders Medicare plan: Concern about allied health/EPC
link , Australian Doctor, 19 March 2004, pp. 1 2.
-
National Competition Council, Assessment of
governments progress in implementing the National Competition
Policy and related reforms: Volume two Legislation review and
reform, AusInfo, Canberra, 2003, p. 98.
-
The amendments proposed by the Bill will not make it possible
for health funds to pay benefits towards the cost of podiatric
surgeons or associated anaesthetists fees, because podiatric
surgery will still not be covered by the Medicare Benefits Schedule
(MBS).
-
Though as also noted above, there is some evidence to suggest
that the treatment outcomes from procedures performed by podiatric
surgeons are as good, and in some cases better, than those
performed by orthopaedic surgeons. However, the issue of expanding
the availability of podiatric surgeons services in public hospitals
is beyond the scope of this Bill.
-
These include the Department of Health and Ageing, the
Australian Institute of Health and Welfare, the Australian Bureau
of Statistics, various state and territory health agencies, and
various non-government stakeholders and interest groups.
-
Department of Health and Ageing, Australian Hospital Information, Performance
Information Program website: see http://www.health.gov.au/casemix/hcp/hcpmain1.htm
(accessed 11 May 2004).
-
ibid., see: http://www.health.gov.au/casemix/glossary1.htm
(accessed 11 May 2004).
-
ibid., see: http://www.health.gov.au/casemix/hcp/hcpmain1.htm
(accessed 11 May 2004).
-
Warwick J. Wilkinson, National Competition Policy Review of
Pharmacy Preliminary Report, Council of Australian
Governments, Canberra, 1999, p. ii.
-
Explanatory Memorandum, p. 1, See: for example, the Pharmacy
Act 1964 (NSW),
sections 27 and 29.
-
ibid.
-
ibid., p. 2.
-
National Health Act 1953, section 90(4).
Dr Angela Pratt
21 May 2004
Bills Digest Service
Information and Research Services
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