RACS is pleased to provide feedback on the Department of Health's consultation on minimum qualifications for the provision of ultrasound services under Medicare. In responding to this request, we have consulted with several surgical speciality societies to seek their input, which are attached and we would encourage that these be read in conjunction with this submission.

In principle, RACS considers the current standards on the provision of ultrasound services under Medicare to be broadly sufficient and that there are adequate regulations in place governing practices surrounding ultrasound imaging through the Diagnostic Imaging Accreditation Scheme (DIAS) and Location Specific Provider Number (LSPN).

RACS requires that all Fellows be appropriately credentialed at all hospitals in which they operate, taking into account experience, scope of practice, qualifications and facilities available. Fellows of RACS are also required to participate in on-going professional development activities through the RACS CPD Program, which requires participation in activities as relevant to their scope of practice.

Fellows who may require re-training or re-skilling are supported by RACS through our Re-Skilling and Re-Entry Program.

In response to the questions raised in this consultation, RACS provides the following comments.

Does the medical training syllabus for any surgeon specialities include training in the performance and reporting of ultrasound?

All Trainees must complete the Early Management of Severe Trauma (EMST) course, which includes a session on Focused Assessment with Sonography in Trauma (FAST).

Some surgical specialty training programs incorporate further ultrasound training into their syllabus.

Urology has a dedicated uro-radiology module that includes training in the performance, interpretation and reporting of prostate ultrasound, bladder ultrasound and renal ultrasound including image guide renal access for urinary stone surgery. Trainees in vascular surgery are also required to undertake specific training in ultrasound. Post-Fellowship training also provides another opportunity for surgeons to gain further education in ultrasound as required. For example some General Surgeons may pursue subspecialisation in breast surgery which requires additional training to enhance their skills and knowledge required in the diagnosis and management of breast disease.

In other surgical specialities, ultrasound is less relevant to their practice and not a mandated requirement within the training syllabus. It may however be recommended for those surgeons undertaking specific procedures such as in Paediatric Surgery where intraoperative ultrasound is used in anatomy visualisation and guidance such as solid organ resection, percutaneous access (biopsy or insertion vascular access line) or the instillation of local anaesthesia.

Are alternative specific ultrasound qualifications are appropriate for any surgeon specialties?

While minimum standards regarding the provision of ultrasound are appropriate, RACS does not support mandating a specific ultrasound qualification. Specialty societies with a specific need for ultrasound training (i.e. vascular, urology) already have this established within their syllabus, with this training being of greater applicability to surgeons and their practice setting than a more generalised training model.

RACS recommends that any discussion about minimum standards be undertaken through a collaborative process with the surgical specialties due to the multi-disciplinary and diverse nature of surgical training. For example, due to the extensive scope in which ultrasound is used within vascular surgery, the Australian and New Zealand Association for Vascular Surgery (ANZSVS) consider their SET syllabus (FRACS Vasc) as having appropriate equivalency to The Royal Australian and New Zealand College of Radiologists qualification for medical practitioners.

Is a Diploma in Diagnostic Ultrasound (DDU) limited to the specific service type relevant?

While developing minimum standards would be beneficial, RACS does not consider that the DDU limited to specific service type is relevant. In particular there are concerns about whether the diploma is appropriately optimised for surgeons and that there are already other training programs (such as that provided by ANZSVS) that are more appropriate for specific surgical specialties.

Whether the inclusion of minimum qualifications for the provision of ultrasound services in regulation would have a detrimental regulatory impact on your discipline.

While RACS supports minimum standards, it does not believe that a minimum qualification is required for the reasons outlined above. There is some concern that minimum qualifications for the provision of ultrasound services may have a detrimental impact on the provision of some surgical services (i.e. rural and remote areas) and RACS would request further engagement (particularly with specialty societies who administer training programs) if this were likely to occur.

An indication of the number of Fellows who would already have the DDU qualification or another qualification relating to the performance of ultrasound.

In terms of Fellows who hold the DDU qualification, our understanding is that only a small number hold the diploma noting that we do not hold a registry of this information.

RACS would like to thank the Department of Health for its invitation to provide a submission to its inquiry into clarification of minimum qualifications for the provision of ultrasound services under Medicare. We look forward to receiving a report on the outcome of this review and working with Commonwealth and State Governments to improve the sustainability of surgical services in the future.

Read the complete submission at the link below.