RACS Advocacy

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2017

Early access to superannuation to cover the costs of medical services, including Medicare Benefits Schedule (MBS) listed services

21 December 2017

In principle, RACS does not support early access to superannuation for surgical procedures. Where there is a genuine need to treat a life threatening illness or alleviate acute or chronic pain or mental disturbance, RACS believes that this should be accessible via the public hospital system.


Australian Competition and Consumer Commission’s Review of Quad Bike Safety

15 December 2017

RACS recommends that the ACCC implement the TARS Australasian Terrain Vehicle Assessment Program for quad bikes and side by side vehicles or a system identical in essence to the New Car Assessment Program as a matter of priority. The results from the TARS research indicate that this would lead to significant improvements in safety through safer vehicle choice, safer vehicles being developed and marketed, and increased safety awareness among users.


Submission to the NSW Upper House Portfolio Committee 1 Inquiry into Alcoholic Beverages Advertising Prohibition Bill 2015

06 December 2017

The NSW RACS Committee and the NSW Trauma Committee greatly appreciates the opportunity to make a submission to the NSW Upper House Portfolio Committee 1 Inquiry into Alcoholic Beverages Advertising Prohibition Bill 2015.

RACS is an organisation with interests in public health and safety, and notes with concern, that current bias in NSW is weighted heavily in favour of the alcohol retail industry, with insufficient regard for community concern, or to alcohol related harm reduction.

As a NSW stakeholder group, RACS surgeons, along with other health professionals, treat the consequences of alcohol related harms, downstream effects of increased availability of alcohol, increased density of liquor outlets, decreased prices of alcohol and the increased advertising and promotion of alcohol sale and consumption.


Victorian Statutory Duty of Candour

28 November 2017

The Royal Australasian College of Surgeons supports efforts being undertaken to improve the safety, quality and efficiency of all health services and hospitals in the Victorian health system.

Much of what is proposed in this set of legislative reforms is already adequately covered by current open disclosure requirements and multiple professional codes of conducts across the medical professions. Acknowledging that the recommendation for this change arose from significant organisational failures the focus of this legislation should be on improving transparency and disclosure requirements at the senior organisational level.

If this legislative reform is progressed it is imperative that there is a clear distinction between an apology for an adverse outcome and an admission of guilt.


Briefing to the Incoming Minister (NZ)

22 November 2017

On behalf of our New Zealand Fellows and Trainees, the Royal Australasian College of Surgeons wishes to congratulate you on your new appointment as the Minister of Health. Over the next three years we look forward to working with you, the Government and the Ministry to ensure that New Zealanders have on-going access to high quality healthcare.

The aim of this document is to provide a brief overview of the Royal Australasian College of Surgeons (RACS) and the issues which we perceive to be of importance to the provision of quality surgical care in New Zealand. We outline below the issues and the actions that we believe need to be taken to address these.


Queensland Election Statement 2017

09 November 2017

Prior to State and Federal elections, the Royal Australasian College of Surgeons provides an opportunity for political parties to outline policy positions on key issues relating to the delivery of surgical services. The College then distributes the responses to its membership and the broader community. This document outlines the areas of specific concern and relevance to the Fellows, Trainees and International Medical Graduates of Queensland in the lead-up to the forthcoming State election. The College believes that considered and informed policy positions will allow the Queensland Region of the College to advocate effectively to ensure the best outcomes for patients


Victorian Government's Data Set Proposals

20 October 2017

In October 2016 the Victorian Regional Committee wrote to the Department when this change was first proposed outlining our concerns and recommendations for this Proposal. We reiterate these comments in this feedback.


Review of Accreditation Systems within the National Registration and Accreditation Scheme for health professions

19 October 2017

The Royal Australasian College of Surgeons (RACS) appreciates the opportunity to provide feedback to the COAG Health Council on this consultation, however we felt that the template and options for consideration provided were problematic, hence we are writing to you directly with our concerns. In particular we are concerned about the potential cost of a new model of accreditation as proposed in the Draft Report, in the absence of any obvious benefits to patient care.


RACS First Principles Review of the Medical Indemnity Insurance Fund

18 October 2017

RACS welcomes the First Principles Review, and we believe it is reasonable and practical to routinely review all government programs to ensure that they are sustainable, remain relevant and are delivering their intended benefits. The College does not dispute that there are enhancements that could be made to improve the efficiency of the schemes that underpin the Indemnity Insurance Fund (IIF). However, RACS cautions against making widespread changes to what has been predominantly a well-functioning and successful area of public policy.


Mandatory Reporting Under the Health Practitioner Regulation National Law

28 September 2017

Our position is that options 3 and 4 have merit to them. We favour option 3 slightly over 4 and would consider a hybrid between 3 and 4 as a viable option


Australian Government Surgical Mesh Consultation

14 September 2017

With rapid increases in medical knowledge, technological advancements and the development of highly individualised packets of care available to meet specific patient requirements, being appropriately informed on these aspects of continuing education remains the responsibility of each individual surgeon.

The introduction of new technologies and treatments is dependent on the publishing of supportive peer-reviewed articles demonstrating efficacy without undue risk, and practitioners ensuring they have acquired the appropriate levels of knowledge and skill. This is most satisfactorily monitored through the robust credentialing of practitioners and their work environment, expected as part of each practitioner's employment or right to access surgical facilities.


Tasmanian Inquiry into Acute Health Services

31 August 2017

The Royal Australasian College of Surgeons (RACS) is aware the consultation period for this Inquiry closed on 18 August. Unfortunately due to a combination of factors RACS was unable to respond by the proposed deadline, however we are hopeful that the contents of this letter can still be taken in to consideration as part of the Inquiry.


Inquiry Into the Value and Affordability of Private Health Insurance and Out-of-Pocket Costs- Response to Question on Notice

28 August 2017

Thank you for offering the Royal Australasian College of Surgeons an opportunity to provide evidence as part of the Senate Community Affairs References Committee inquiry into the value and affordability of private health insurance and out of pocket medical costs.

Our response provides answers to the questions taken on notice at the public hearing on 5 July 2017.


New Zealand Election Statement and Party Responses

28 July 2017

Prior to all state and national elections, RACS sends an election statement to all major parties on key issues RACS considers to be of particular importance to the provision of surgical care.

In the lead-up to the 2017 New Zealand General Election, RACS distributed an election statement to all the major New Zealand parties posing policy questions on the following five key issues:

  1. Elective prioritisation and unmet need
  2. Māori health equity
  3. Alcohol-related harm
  4. Obesity
  5. Health workforce

The parties were given five weeks to respond to the election statement. Their responses were collated and distributed to all New Zealand Fellows, Trainees and IMGs.


Evaluation of The Community Impact Statement Requirement for Liquor Licence applications (NSW)

28 July 2017

The NSW RACS Committee and the NSW Trauma Committee greatly appreciates the opportunity to make a submission regarding the NSW Evaluation of The Community Impact Statement Requirement for Liquor Licence applications.


Victorian Health Legislation Amendment (Quality and Safety Bill) 2017

27 July 2017

The Royal Australasian College of Surgeons supports efforts being undertaken to improve the safety, quality and efficiency of the Victorian Health system.


Credentialling and Scope of Clinical Practice for Senior Medical Practitioners Draft Policy (Victoria)

26 July 2017

RACS has completed the response sheet provided by Safer Care Victoria.


SA Pathology Proposed Operational Configuration and Workforce Model

21 July 2017

Our main concern with the proposed reconfiguration of pathology services is the reliance the new model places on the Enterprise Patient Administration System (EPAS). The desire to move towards an electronic based model is understandable; however any system reliant on technology involves inherent risk. Inevitably at some point technical difficulties will occur. In a health setting where even minor glitches can lead to catastrophic outcomes, it is crucial that these risks are mitigated, and disruptions are prevented wherever possible.


Western Australian Human Tissue and Transplant Act 1982, Section 24

17 July 2017

After reviewing the consultation paper carefully at our meeting on 12 June 2017, the RACS WA State Committee formed the view that we do not support the suggested amendments to the legislation.


Inquiry into the use and marketing of electronic cigarettes and personal vaporisers in Australia

07 July 2017

Smoking is the single most important preventable cause of ill health and death in Australia. Tobacco use is known to cause certain cancers and increase the risk of other diseases and congenital abnormalities. Surgical outcomes are consistently poorer for smokers than non-smokers, with patients who smoke experiencing longer recovery times, increased risk of wound infection, and significantly increased risk for myocardial infarction and stroke. Smokers also have a higher post-surgery mortality rate than non-smokers.

RACS is therefore a strong supporter of the goal outlined in the Commonwealth Government's National Tobacco Strategy 2012-2018 to reduce the smoking rate from 15.1% of the population in 2012 to 10% by 2018. In 2012 Australia became the first country in the world to introduce plain packaging laws, and alongside yearly excise increases, plain packaging has proven to be an effective form of tobacco control.


NT 'Towards Zero' Road Safety Action Plan

03 July 2017

Over the past three years in particular, RACS has been vocal about improving road safety standards in the Northern Territory. We were deeply concerned by the reintroduction of open speed limits in 2014, and advocated strongly against this reckless policy. The Government is to be commended for taking a principled stance on this issue and for swiftly reintroducing speed limits following their election. However, it is important that momentum is not lost and that the Government continues to prioritise road safety as a critical area of public policy.

While restrictions on speed are an important safety measure, they are one component of a much broader road safety strategy. Other factors include raising community awareness and promoting safer driving practices, and investing in infrastructure projects that will enhance the quality and condition of Northern Territory roads.


Draft National Competency Framework and Standards for Podiatric Surgeons

30 June 2017

The Royal Australasian College of Surgeons (RACS) is pleased to provide feedback on the ANZPAC Draft National Competency Framework and Standards for Podiatric Surgeons. In responding to this request, RACS has sought consultation from the orthopaedic surgical specialty society - the Australian Orthopaedic Association.


Northern Territory Alcohol Policies and Legislation Review

30 June 2017

The dangerous availability, oversupply, promotion and misuse of alcohol is strongly implicated in our high rates of injury due to interpersonal violence, road traffic accidents, family violence and misadventure such as drownings or falls.


Violence against health care workers (Vic)

21 June 2017

RACS believes that violence is unacceptable in any workplace. No employee should be expected to accept any form of physical or verbal violence or abuse as part of their work environment. This type of behaviour is particularly deplorable when it is directed at health care workers.


Setting of Speed Limits New Zealand

16 June 2017

Generally speaking, RACS supports the intent of the proposed Rule and its goal of a sustained reduction in deaths and serious injuries on New Zealand roads.


Rheumatic Heart Disease – Notifiable Condition (QLD)

02 June 2017

Rheumatic heart disease is a complication of rheumatic fever in which the heart valves are damaged. Rheumatic fever is an inflammatory disease that begins with strep throat. It can affect connective tissue throughout the body, especially in the heart, joints, brain and skin.


Clarification of minimum qualifications for the provision of ultrasound services under Medicare

31 May 2017

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.


Proposed National Recognition and Response System

22 May 2017

HQSC has posed a number of questions on the proposed system and these have been responded to in our submission.


Investing in New Zealand’s Future Health Workforce. Post-entry training of New Zealand’s future health workforce: Proposed investment approach

19 May 2017

MCNZ has accredited RACS as the training organisation for nine surgical vocational scopes - cardiothoracic surgery, general surgery, neurosurgery, orthopaedic surgery, otolaryngology head & neck surgery, paediatric surgery, plastic & reconstructive surgery, urology and vascular surgery. RACS determines the curriculum, standards and training requirements. It runs the examinations and courses and, in conjunction with specific specialist surgical societies, the administration associated with each programme. The clinical practice components of the programmes occur within District Health Boards (DHBs) who are the employers of the surgical trainees.


Health Practitioner Regulation National Law (National Law)

12 May 2017

RACS has considered the Committee's recent request for comment on the proposed reforms to address the inadequacies of the penalties under the National Law, in light of the recent worrying cases of individuals holding themselves out as health practitioners when they are not registered under the National Law. These rogue operators pose a significant risk to the public, and RACS thanks the Committee and Government's ongoing commitment to implementing substantial reform within this framework.


Implementation Plan Advisory Group (IPAG) Consultation 2017

05 May 2017

In addition to our co-authored submission with the Australian Society of Otolaryngology Head and Neck Surgery (ASOHNS), RACS also provides the following submission to the Implementation Plan Advisory Group's (IPAG) consultation on the Implementation Plan for the National Aboriginal and Torres Strait Islander Health Plan 2013-2023.


Implementation Plan Advisory Group (IPAG) Consultation 2017 2

05 May 2017

RACS and ASOHNS recognise that improving the health of Aboriginal and Torres Strait Islander peoples is a public health priority. The Australian Government's National Aboriginal and Torres Strait Islander Health Plan 2013-2023 (the 'Plan') and its associated Implementation Plan provide a crucial strategy that underpins much of the government and non-government work aimed at addressing the social and cultural determinants of health. In particular the Plan places a strong and healthy cultural identity at the centre of priorities for action.


Letter regarding Tasmanian Role Delineation Framework – Royal Australasian College of Surgeons – Paediatric Surgery Guidelines

05 May 2017

The position paper provides guidelines around the expectations RACS and the Speciality Societies have around the minimum quality of care standards that should be provided to children when undergoing surgical care. The paper also outlines a ten-point plan, which was compiled for the interface between the Specialist General and Paediatric Surgeons in hospitals which may have limited access and resources to paediatric care.


Antimicrobial use and appropriateness in surgical prophylaxis draft Accreditation Advisory

05 May 2017

With respect to the letter from Professor Debora Picone to Mr Philip Truskett regarding antimicrobial use and appropriateness in surgical prophylaxis, RACS agrees that there is an issue in surgical antimicrobial prophylaxis. Although there has been an improvement in the length of time that the antimicrobial prophylaxis is being prescribed for, as noted in your studies from 35.9% in 2014, reduced to 27.4% in 2015, the 2016 data shows that the rate of inappropriate prescribing for surgical antimicrobial prophylaxis was 41.8% overall and 17.9% of prescriptions were for longer than 24 hours. As you correctly point out the benchmark for appropriate prescribing is 95% and this is nowhere near what is being undertaken or achieved at the moment.


Independent Review of Accreditation Systems within the National Registration and Accreditation Scheme for health professions

01 May 2017

RACS notes that the discussion paper for the accreditation systems review focuses on a broad range of issues, many which are associated with undergraduate and non-specialist health professionals. Given this, we will largely focus our feedback on the roles of specialist colleges and post-graduate medical councils (number 31 within the consolidated list of issues, p.6).


Response to Safer Care Victoria Clinician Engagement Scoping Paper

28 April 2017

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.


RACS Response to Victorian Voluntary Assisted Dying Bill Discussion Paper

27 April 2017

Once drafted an Exposure Draft of any Voluntary Assisted Dying legislation should be made available for the industry and public to review prior to its introduction into Parliament.There should be the ability to make submissions to the draft legislation with an appropriate time-frame allowed for these responses.


Universal access to safe, affordable surgical and anaesthesia care when needed

18 April 2017

The Royal Australasian College of Surgeons (RACS) has developed strong partnerships for surgical care delivery and training with our Pacific and South East Asian neighbours. We write to you in view of your candidature for the position of WHO Director General, a leading position that holds great potential to improve universal health coverage, including access to safe, affordable surgery and anaesthesia care when needed.


Regulation of Certain Cosmetic Surgical Procedures Under the Private Health Facilities Act 1999 Discussion Paper - QLD

13 April 2017

RACS does not support the creation of a new class of surgery within the cosmetic procedures group; however greater oversight of the appropriate credentialing of facilities, including appropriate credentialing of practitioners is needed.

If any type of intravenous sedation is required to perform a procedure, then the surgery should only be undertaken in a licensed facility. This generally means a larger operation which requires the resources and oversight found in a larger facility.


Inquiry into the performance of the Queensland Health Ombudsman's functions pursuant to section 179 of the Health Ombudsman Act 2013

06 April 2017

Thank you for your consultation for the Inquiry into the performance of the Queensland Health Ombudsman (QHO). The College wishes to acknowledge the very in-depth and well-constructed document which has been provided into the performance of the OHO.

The College has the view that the complaints management processes in Queensland have had major problems for more than a decade. There have been a number of bodies tasked with this responsibility over the past decade - Health Rights Commission, Health Quality and Complaints Commission, Office of the Health Ombudsman, Queensland Medical Board, Health Practitioner Registration Boards, National Boards and AHPRA. These organisations, it would appear from the evidence provided over a number of years, have not been able to efficiently or effectively manage the complaints processes.


Medical Council of New Zealand Consultation on Strengthening Recertification for Vocationally Registered Doctors

31 March 2017

In the submission RACS has responded to the MCNZ's specific question and other proposals within the consultation document.


Model Scopes of Clinical Practice Project – Consultation on Tranche 2 of Model Scopes of Clinical Practice

16 March 2017

The NSW State Committee greatly appreciate this opportunity to have further input into the Model Scopes of Clinical Practice Project and we would also like to congratulate you on the high level of communication that you have continually tried to bring to the development. The NSW Committee have been given opportunity to not only discuss the project but also to be involved in its development.


Prevention & Management of Head Injuries in AFL with particular reference to the ‘Sling Tackle’

15 March 2017

We commend the AFL for consulting with the AFL Doctors Association regarding player safety and appreciate the changes made to the interpretation of 'dangerous tackle' in the AFL Laws.

We are thankful that the 'sling tackle' has been prohibited.

We anticipate abolition of the 'sling tackle', and expect severe penalties to be issued to delinquent players guilty of the offence of 'sling tackle'.


Remake of the Health Records and Information Privacy Regulation 2012

14 March 2017

We greatly appreciate this opportunity to comment on the Ministry of Health proposal to remake the Health Records and Information Privacy Regulation in the same form as the 2012 version. We support this action in general but would like to comment on one Clause 6B and ask for clarification on Clause 5.


Response to QoN - Senate Red Tape Committee

09 March 2017

During the hearing we were asked to clarify some points as listed below. Thank you for this further opportunity to provide inpout into this enquiry.


Quad Bike safety in Tasmania Issues Paper

02 March 2017

RACS is extremely concerned about the increasing number of deaths and major injuries as a result of quad bike use. Trauma surgeons who manage these injuries on a far too regular basis are acutely aware of the inherent dangers of quad bikes and have been advocating for quad bike safety for decades.


DFAT Foreign Policy White Paper (Joint Submission and RACS Submission)

28 February 2017

Health among Australia's geographical neighbours should be regarded as a key component in Australia's foreign policy due to the burden of global disease and shifting disease patterns. By 2025, Asia will produce half of the world's economic output, and will increasingly demand high quality healthcare, education, and training services to ensure stability. Factors such as natural disasters, extreme weather events, infectious pandemics, escalating demographic changes, and population movements mean that strong health services are mandatory. Supporting strong health services, health education, and workforce development is a cost-effective approach to achieving security and prosperity in the region.


2017 Western Australian Election Position Statement

16 February 2017

Prior to all government elections in Australia and New Zealand, RACS provides an opportunity for political parties to outline their policy positions on key issues relevant to the delivery of surgical services. RACS then distributes these responses to its membership and the public. This document outlines areas of specific concern and relevance to our membership.


Inquiry Into Price regulation associated with the Prostheses List Framework

31 January 2017

The regulation of prostheses costs in Australia is complex and RACS welcomes the Community Affairs References Committee's inquiry into price regulation associated with the prostheses list framework. In making a submission to this inquiry, RACS considers the following principles as being central to improving existing processes and structures - patient safety and quality assurance; clinician driven reviews and; greater transparency and improved coordination.


Senate Red Tape Committee’s Inquiry into the effect of red tape on the sale, supply and taxation of alcohol

31 January 2017

RACS has strongly advocated for recognition of the harmful effects of alcohol abuse for many years, not only for the increased risk of complication that it poses to surgical patients, but also for the broader ramifications it has on the sustainability of our public health system and society as a whole. In the past year RACS has released an updated position paper on alcohol related harm and made multiple submissions to alcohol policy and regulatory reviews across Australia and New Zealand.


Patient Access to Medicinal Cannabis in South Australia

31 January 2017

While some scientific evidence exists to indicate the potential therapeutic value of cannabis-derived products, there is also considerable evidence highlighting the dangers of frequent cannabis use. 


National Digital Health Strategy

30 January 2017

RACS is supportive of the Commonwealth's ongoing efforts to make improvement across the specturam of eHealth. RACS recognises that there are complex challenges in delivering effective eHealth policy and solutions in Australia and was pleased to provide input into the initial National Digital Health Strategy Consultation Draft in April 2016.


National Health and Medical Research Council - Effects of Alcohol

17 January 2017

The harmful use of alcohol is a significant contributor to the global burden of disease, and its misuse substantially contributes to social disruption, injury and death. While there is some evidence that small amounts of alcohol consumption may have health benefits, overwhelmingly the evidence points to the short and long-term health risks commensurate with increased consumption of alcohol.


South Australian Liquor Licensing (Liquor Review) Amendment Bill 2016

06 January 2017

RACS acknowledges the consultative approach taken by the South Australian Government throughout the development of this Bill. RACS has previously made submissions to the original Liquor Licensing discussion paper, and a supplementary submission that was co-authored by a number of like-minded organisations. We also met directly with the Independent Reviewer, Justice Tim Anderson QC, to discuss our submission in greater detail.


Review of the Victorian Liquor Reform Act 1998

03 January 2017

RACS has advocated against the harmful effects of alcohol for many years, not only for the increased risk of complication that it poses to surgical patients, but also for the broader ramifications it has on the sustainability of our public health system and society as a whole.

Surgeons are often confronted with the effects of alcohol misuse when treating patients with injuries resulting from road traffic trauma, interpersonal violence and personal accidents that are caused by excessive alcohol consumption. Alcohol misuse is also a significant contributor to the total burden of disease, including liver failure, GI bleeding, upper GI and oropharyngeal cancer and infections related to malnutrition.


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