The submission expressed serious concerns regarding these recommendations, especially regarding the expansion of consultant access (104/105), permitting interventional radiologists to determine self-diagnosis, and theatre banding by specialty (as opposed to specialty training) which was undertaken without engagement, leading to inconsistencies in regulation and patient safety. RACS and co-signatories indicated that such reform blurred professional scopes of practice, breached Australian Medical Council (AMC)-recognised scopes and incorporated financially based models of care which may undermine governance, consent and outcomes.
RACS' submission recommended that the recommendations be withdrawn or delayed enabling true co-design with vascular surgery, the radiology sector, general practice and consumer representatives. Furthermore, the recommendation was made to ensure greater alignment with National Safety and Quality Health Service (NSQHS) Standards, the Health Practitioner Regulation National Law (Surgeons) Amendment Act 2023 and AMC-recognised models of training frameworks, while further enabling diagnostic stewardship, preventing low-value care, and protecting public-private equity, especially in the rural sector.
Submission overview (31 October 2025):
The joint submission advocates withdrawing or deferring Recommendations 15, 17, 18, and 19 to reinstigate procedural fairness and reliable multidisciplinary oversight. It advocates eight principles of reform, including AMC alignment, prohibiting ownership-linked diagnostic incentives, complexity-based theatre banding, co-designed evaluation metrics, and safeguards for public capacity in complex vascular care. The submission concludes with a statement that while Medicare Benefits Schedule (MBS) modernisation is critically important, it must be first implemented with a priority on patient safety, equity, and regulatory integrity rather than simple expedience of cost or scope expansion.