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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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ISSN 1328-8091
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