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ADDITIONAL COMMENTS BY
COALITION SENATORS
Private Health
Insurance (National Joint Replacement Register Levy) Bill 2009
1.1 The
Coalition believes that a number of issues raised by Submitters were not
adequately addressed in the Chair's Report. The Coalition believes a number of
problems could have been avoided with better industry consultation by the
Department.
LACK OF INDUSTRY CONSULTATION
2.1 The
Coalition is concerned at the number of submitters who gave evidence that the
industry and stakeholders were not consulted by the Department of Health and
Ageing before the Bill was introduced. As Lifehealthcare Distribution noted in
its submission:
Certainly this kind
of proposal should follow appropriate consultation to achieve a result fairly
across the spectrum of stakeholder, and there has been no consultation so far
from the department of Health and Ageing with the industry on this matter.[1]
2.2 Whilst
the Department gave evidence that it had briefed the Medical Technology
Association of Australia (MTAA) on the Bill, the MTAA said that:
There has been no
exchange of views on how best to implement this legislation through the rules.
Although the Department intends that the levy on listings could be as low as
zero, they conceded that they do not have accurate utilisation data on which
they will presumable base exemptions. This is a process which should be
understood as being practical and achievable before the legislation is passed.[2]
2.3 The
Coalition is concerned that meaningful consultation did not take place before
the Bill was released.
CONFLICT OF INTEREST
3.1 The
Coalition recognises industry concern that allowing one stakeholder group, the
Orthopaedic Association, to have sole management of the Registry could give the
appearance of a conflict of interest. Mr Wiltshire of Medtronic Australasia said:
When any single group
that is involved runs the entire process there is the potential for a conflict
of interest. We do not suggest that the Orthopaedic Association has a
particular conflict of interest. However, if data being collected that involves
multiple stakeholders and only one stakeholder group owns the data and directs
the design of the registry, there is always the potential for a conflict of
interest.[3]
3.2 The
MTAA point out that the UK National Joint Registry has industry members on its
Steering Committee. The inclusion of a number of industry stakeholders allows
potential conflicts of interest to be resolved in Committee. As the MTAA points
out:
Joint
replacements can fail for a number of reasons including as a result of the
implant and the manner of surgical implantation and accordingly it will be
important to balance all competing conflicts of interest in the management of
this important resource.[4]
3.3 Industry
consultation will be required by the Committee in order to address conflict of
interest concerns held by stakeholder groups.
LEVY RATE SETTING
MECHANISM
4.1 The
Coalition notes that serious concerns were raised by several submitters with
regards to the levy rate setting mechanism. For instance, the MTAA raises the
following issue with the Department's comparisons to the United Kingdom model:
The Department of
Health and Ageing officials have understated the difference between their
proposal and the manner of the UK levy. The UK levy is based on an amount
per procedure collected by the manufacturer which is essentially a utilisation
driven process. The Department’s proposal is related to listings in the
Prostheses List and the legislation if passed, will provide no obligation to
consider utilisation in determining the amount of the levy.[5]
4.2 Once
again, more consultation with industry would have allowed the Department to
consider and answer these concerns before releasing the Bill.
RECOMMEDNATIONS
Recommendation 1
That the levy system
and the funding of the Registry be reviewed in 12 months time.
Senator Sue Boyce
LP, Senator for Queensland |
Senator Judith Adams
LP, Senator for Western Australia
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