Our submission outlines numerous concerns about process and adverse outcomes.
The AMA's submission to the Department of Health and Aged Care on the Stage 2 surgical guides and biomodels (SGBM) post-listing review expresses numerous concerns about the consultation process, and the options for setting the Prescribed List (PL) benefit for these devices presented in the report.
The AMA argues recent departmental consultations on PL matters have given stakeholders way too little time to respond, which casts doubt on whether the PL is being appropriately governed.
Another key concern is that the options presented in the report go beyond the terms of reference for the review and seek to place further conditions on the use of these items. The AMA has rejected these options, arguing that the decisions of clinicians on the number of SGBM required to address the needs of individual patients and specific clinical circumstances must be respected and paid for by private health insurers.
The AMA further argues that given the reductions in price for SGBM listed on the PL already achieved under PL reforms and the Memorandum of Understanding between the federal government and the Medical Technology Association of Australia (MTAA), the public price in Australia, which reflects a competitive market, should be the default PL benefit for these devices.
The submission also notes that SGBM biomodels that are the subject of this consultation reflect only a small fraction of the SGBM in routine use by clinicians across numerous specialties in Australia, because most of them are not currently approved for listing on the PL. The AMA cautions that the PL appears to be lagging current practice.
Finally, our submission argues that great care must be taken to ensure that PL reforms advocated by private health insurers do not have the unintended consequence of putting the private health sector in a disadvantaged position compared to public hospitals, further undermining the value proposition of private health insurance.
