Background

Meeting of health professions with Department of Premier & Cabinet

• transitional administrative risks - historical precedent reminds us that when a new registration arrangement is introduced unforeseen consequences abound, with the registering authority often caught by inadequate transitional arrangements with existing cases falling under two legislative regimes, which leads to court challenges and delays. Equally health professionals are unfairly dealt with because of the extended time in resolving cases, which may leave them unable to work for months or years. These problems are significant enough when the changes involve two pieces of legislation however the problems for Victoria will be more acute as the professions will be plagued by a transition first to the HPR Act in July 2007 to be followed one year later by a new national scheme;
• employer risk - the uncertainty engendered by the proposed changes causes very significant stress on all the staff of the current registration boards, with the risk that many qualified staff will resign, leaving the boards ill-equipped to manage the most complex changes they are ever likely to face;
• registration risk – amongst all this change and disruption is a real risk that there will be a breakdown in registration processes, which will allow unqualified people to be registered;
• national model risks – the adoption of a standard national model threatens arrangements that are unique to one state or another, in Victoria for instance this encompasses the funding of the Victorian Doctors Health Program;
•  interface legislation risks – the new Victorian HPR Act necessitated amendment to 51 other Acts no doubt other States would have a similar tally. Unfortunately just as the registration Acts are different from State to State, so is this other legislation. For example the Health Services Commissioner [however titled] in each State has an integral role in the registration boards’ complaints handling system. In Victoria it is limited to a referral of cases to the HSC where safety of the public is not an issue and where the complaint could reasonably be conciliated. By way of comparison in NSW, the Health Care Complaints Commission, not only investigates complaints made to the Board, but also prosecutes them.

•  innovation risk – far from enabling innovation, the requirement for national agreement before amendments to legislation can be made, will stifle the development of new models of care;
• workforce risk – the struggle to get national agreement on assessment of international medical graduates [IMG] presages future conflict between the States about recruitment of these doctors. Set the bar too high and gaps in the workforce will soon manifest themselves, not only in rural and outer metropolitan areas, but in major teaching hospitals, which are increasingly dependent on large numbers of IMGs to fill service gaps. Set the bar too low and doctors whose knowledge and skill are not adequate for practice in Australia will be registered.

• safety & quality risk – medical education in Australia has evolved and improved continuously over the last half a century, to a point where it is accepted as a world leader. It is inconceivable that such a system would be put at risk by the imposition of changes that are untested and have not been subjected to even a minimum level of scrutiny;
• international education risk – Australia is a destination of choice for international medical students, however if the medical education accreditation scheme is seen to be politicised or undermined this will change which will have direct revenue implications for Universities and have implications for Australian citizen graduates who wish to work overseas.