Diagnostic imaging is a vital component of the health system and assists
health care professionals with the 'appropriate initial diagnosis and ongoing
assessment of many medical conditions'.
There are various diagnostic imaging modalities and techniques used by clinical
computed tomography (CT);
diagnostic radiology (such as x-ray and mammography);
magnetic resonance imaging (MRI); and
nuclear medicine imaging, such as positron emission tomography
This inquiry considered key issues relating to diagnostic imaging
services, including geographic disparities, Commonwealth subsidies, the costs
for non‑subsidised services, and how governments can improve
accessibility to these essential services.
While the terms of the committee's inquiry encapsulates all modalities
of diagnostic imaging, licensing issues relating to MRI machines were a
prominent subject of concern amongst submitters. Submitters concerns, and
potential avenues for reform, are detailed in chapter three.
Diagnostic imaging framework
The Commonwealth Government has no role in the direct delivery of
diagnostic imaging services, but funds diagnostic imaging services through the
Medicare Benefits Schedule (MBS) and the National Health Reform Agreement
(NHRA). Service delivery and the placement of diagnostic imaging services is
the responsibility of private providers and state and territory governments.
The Commonwealth Government regulates Medicare-eligible diagnostic
imaging equipment through three main pieces of legislation. These are:
the Health Insurance Act 1973;
the Health Insurance Regulations 1975; and
the Health Insurance (Diagnostic Imaging Services Table)
Regulations 2017 (DIST).
The Department of Health (Department) administers Commonwealth funding
for diagnostic imaging services through the MBS and the NHRA.
Diagnostic imaging is a significant part of the MBS budget. In 2016–17,
diagnostic imaging accounted for seven per cent of all MBS-funded services and
cost the Commonwealth $3.4 billion.
Issues relating to funding and the MBS are considered in greater detail
in chapter five.
National Health Reform Agreement
The NHRA is an agreement between Commonwealth, state and territory
governments that establishes the financial and governance arrangements for
Australia's public hospital services, including diagnostic imaging services.
The Commonwealth, under the NHRA, contributes to the cost of delivering
public hospital services primarily through activity-based funding, which 'ensures
funding is provided to hospitals based on the volume and type of services
delivered to patients'.
Under the NHRA, the states and territories have committed to:
...provide eligible patients
with diagnostic imaging services through the public hospital system free of
charge, on the basis of clinical need and within a clinically appropriate
The NHRA also enables public hospital patients to be treated as private
...charges to be raised where
medical practitioners at the hospital have provided the service under rights of
private practice arrangements. These services are funded through a combination
of MBS benefits, private health insurance (admitted and hospital substitute
patients), and individual patient contributions.
Diagnostic Imaging Accreditation
The Diagnostic Imaging Accreditation Scheme (DIAS), established under
the Health Insurance Act 1973 and administered by the Department,
ensures that diagnostic imaging services eligible under the MBS 'are safe,
effective and responsive to the needs of health care consumers and provided by
practices which meet specified quality standards'.
The DIAS 'links mandatory accreditations to the payment of Medicare benefits
for diagnostic imaging services listed in the DIST'.
Diagnostic imaging services not accredited under the DIAS are unable to
provide Medicare-funded diagnostic imaging services to patients.
In these circumstances, service providers are required to inform patients that
'a practice is not accredited and that a Medicare benefit is not payable before
providing diagnostic imaging services'.
The Department advised the committee that as of 31 March 2017, there
were 3982 diagnostic services accredited under the DIAS.
Other ongoing reviews
The committee is aware that there are other ongoing reviews relating to
diagnostic equipment and services, such as the MBS review.
MBS Review Taskforce
On 22 April 2015, the former Minister for Health, the Hon. Sussan Ley MP,
announced the establishment of the MBS Review Taskforce to conduct a review of
The purpose of the MBS review is to consider how MBS items could better align
'with contemporary clinical evidence and practice and improve health outcomes
All diagnostic imaging items listed on the MBS are included in the MBS review.
In order to undertake this review, five specialised clinical committees were
established, including the Diagnostic Imaging Clinical Committee.
To date, the MBS Review Taskforce has identified a number of obsolete
MBS items and established specialised working groups to address priority areas,
the breast imaging working group;
the imaging of the knee working group;
the imaging for pulmonary embolism and deep vein thrombosis
nuclear medicine working group;
upper and lower limb working group; and
the vascular surgery and interventional radiology working group.
As of January 2018, the MBS Review Taskforce had made two tranches of
recommendations relating to bone densitometry and low back pain.
The Department submitted that, as a result of the review, the government
had implemented the findings of the reports on reducing unnecessary spinal
(to be implemented November 2017) and the removal of obsolete items (as of 1
July 2016) from the MBS.
Further reports released by the review for consultation include:
pulmonary embolism and deep vein thrombosis;
the removal of obsolete items; and
reducing unnecessary spinal x-rays.
Key advisory groups
In addition to the MBS review, other key advisory groups are:
the Diagnostic Imaging Advisory Committee that acts as a
forum for the Department to engage with the diagnostic imaging industry,
clinicians and consumer representatives to seek advice on diagnostic imaging
matters relating to the MBS;
the Diagnostic Imaging Accreditation Scheme Advisory Committee
that provides the Department with advice about the quality and safety standards
of practice for MBS funded diagnostic imaging and the development of policy
under the DIAS;
the Medical Services Advisory Committee, an independent
non-statutory body that appraises new medical services, reviews existing
services and provides advice to government on whether new medical services
should be publicly funded.
The Department also formally and informally engages with diagnostic
imaging professionals, industry groups, consumers and other stakeholders to
develop policy advice for diagnostic imaging services.
Quality Framework for Diagnostic
The Royal Australian and New Zealand College of Radiologists (RANZCR)
and the Australian Diagnostic Imaging Association (ADIA), independently of
government, developed a Quality Framework for Diagnostic Imaging (Quality
Framework) in order to ensure Australia's diagnostic imaging services are:
...underpinned by a regulatory framework which ensures
practices – both private and public – can continue to provide patients across
the country with high-quality, safe and affordable services.
The priority issues addressed in the Quality Framework are:
ensuring patients have access to Medicare-funded CT services in
patient access to radiologist supervised diagnostic mammography
and musculoskeletal ultrasound services;
quality protocols for remote reporting of images (for images
taken at a different location than the place the reporting practitioner is
Medicare-funded ultrasound services to be performed by
practitioners with an accepted minimum professional qualification.
The Quality Framework is considered in more detail in chapter four.
This report is presented in six chapters:
this first chapter provides an overview of diagnostic imaging
services in Australia and the conduct of the committee's inquiry;
Chapter 2 considers the distribution and accessibility of diagnostic
imaging machines (other than MRI machines) around Australia;
Chapter 3 examines the use of MRI in Australia, in
particular, the existing MRI referral pathways (including the current licensing
scheme) and its impact on the health system;
Chapter 4 addresses the diagnostic imaging workforce,
including the shortage of radiologists, radiographers and sonographers;
Chapter 5 considers the effect of the MBS items for
patients and service providers, and the effect of capital sensitivity rules;
Chapter 6 concludes the committee's considerations and contains
the committee's recommendations.
Conduct of the inquiry
On 17 August 2017, the Senate referred the availability and
accessibility of diagnostic imaging equipment around Australia to the Senate
Community Affairs References Committee (committee) for inquiry and report by 5
December 2017 with the following terms of reference:
and other disparities in access to diagnostic imaging equipment;
for Commonwealth subsidy of diagnostic imaging equipment and services;
costs for services that are not subsidised by the Commonwealth and the impact
of these on patients; and
respective roles of the Commonwealth, states and other funders in ensuring
access to diagnostic imaging services.
On 16 November 2017, the Senate granted the committee an extension of
time for reporting until 7 March 2018 and on 7 March 2018 the Senate granted
the committee an extension of time for reporting until 9 March 2018.
The committee's inquiry was advertised on the committee's website and
the committee wrote to 192 stakeholders inviting them to make submissions.
The committee invited submissions to be lodged by 6 October 2017.
In total, the committee received 45 submissions. A list of submissions
provided to the committee is available on the committee's webpage and at Appendix 1.
The committee held two public hearings: one in Perth on 9 November 2017
and one in Brisbane on 13 December 2017.
A list of the witnesses who provided evidence at the public hearings is
available at Appendix 2.
The committee thanks all those who contributed to the inquiry.
Note on references
All references to Committee Hansard are to proof transcripts. Page
numbers may vary between proof and official transcripts.
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