The Victorian Regional Committee of RACS offered the following comments on the Bill:


A key aspect to increasing quality and safety is engagement across the health sector. Meaningful engagement with professional bodies is often lacking with appointments to consultation committees and boards often made to individuals, not as representatives of the profession as a whole.

For many years RACS has been involved with maintaining and improving professional standards, which aligns very closely with Targeting Zero's purpose of improving quality and safety. However, Safer Care Victoria appears to have ignored our expertise in this area and appointed individual clinicians. Appointing representatives from a professional body, rather than individuals, to bodies such as the BCV board, SCV and the Victorian Clinical Council, means their views would be representative and RACS could help with implementation and promotion of decisions and contribute our collective expertise to the process. The appointment of individuals without involving their professional body means a potential significant loss of input, expertise and support.

Data collection and monitoring

Clinicians are keen to be involved in any process that improves surgical standards across the health system. Surgeons, and RACS, are already heavily involved in numerous quality activities including the Victorian Audit of Surgical Mortality (VASM) and these efforts should not be duplicated or reinvented. Improving data monitoring and collection should focus on improving and supporting current processes, working with existing quality staff already in place in public hospitals and developing better systems and links with the private system. This will allow surgeons to use their positions of leadership to improve the quality of data collection.

Any data requested by the Secretary must be reasonable and meaningful. The data should not be overly burdensome to collect or send to the Department and appropriate resources should be provided where the data is complex. Data should also be made available to the public by the Department to assist them in making decisions about the quality and safety of their care.

In addition any data fed back to the administrators of health services must be relevant and subject to clinical interpretation, before action is taken.

Appointment of members to boards

Any powers for the Minister to appoint representatives to a hospital Board should be applied only in exceptional circumstances and in consultation with relevant stakeholders. The appointee must have the appropriate qualifications and expertise to support the Board.

In addition, regulations should mandate appropriate clinician involvement and engagement on boards, and also require boards to consult with the appropriate clinical representatives across their organisation to support better quality and safety monitoring.

RACS would support appropriate remuneration of Board members.

Most importantly any regulations which sit alongside this legislation must be written in consultation with the sector. Consultation must be thorough and meaningful and allow sufficient time to consider the potential impacts and outcomes of any changes proposed.

Read the complete submission at the link below.