Recent advocacy highlights in Australia
To read about our latest advocacy work, visit our news and media centre.
Proposal to Change the Protected Title for Podiatric Surgery
RACS opposes the proposal to change the protected title for podiatric surgery to "surgical podiatrist" due to concerns relating to public safety, clarity for consumers, and professional standards. RACS maintains that terms such as "surgical" or "surgeon" should be reserved for those who have comprehensive surgical training, similar to what medical specialists must undergo, so that patients are not misled regarding qualifications and expertise. RACS instead suggests the use of other terms such as "procedural podiatrist" that may define the scope of the podiatric practice without creating in patients' minds a notion of the extent to which a practitioner has obtained training. The change is subjective to confuse patients who will not make the required distinction between medically trained surgeons and podiatry practitioners. The consequence of this will be inappropriate choices of care. It will increase the number of incidents of legal scrutiny and costs for podiatry practitioners. Furthermore, the proposal is in contrast to the recent legal standards set under section 115A of the Health Practitioner Regulation National Law that restricts the "surgeon" title to certain medical professionals. This demonstrates that there is a need for clarity and safety in professional titles. The Australian Orthopaedic Association agreed to co-brand the submission and were pleased with our efforts.
Read RACS submission (PDF 202.42KB)
Scope of Practice Review
RACS has been involved in the Unleashing the potential of our workforce - Scope of Practice Review, which explores the barriers and incentives for primary healthcare practitioners working to their full scope of practice. RACS provided a response (PDF 189.38KB) to its scoping questionnaire in October 2023 as part of Phase 1. We recognise that when health professionals work to their full scope of practice consumers benefit from prompt and high-quality care in a coordinated manner. Timely access to surgical care should be provided closer to the patient's home by the appropriate surgical practitioner. The non-FRACS surgical practitioner must work in collaboration with FRACS so as to ensure there is no scope creep and there is good continuity of care as a multidisciplinary team (MDT). As part of the phase 2 consultation, RACS provided a submission on the Issues Paper 1 (PDF 317.01KB). It explored the themes, the opportunities for improvement identified in phase 1, with a view to shape some practical proposals for reform. In the phase 3 consultation the Review team sought feedback on its Issues Paper 2. RACS provided a submission (PDF 204.86KB) on how the three reform themes - Workforce design, development and planning; Legislation and regulation; and Funding and payment policy, can support primary healthcare professionals work to their full scope of practice. Additionally, RACS participated in a couple of Roundtable meetings in February and March 2024.
Working Better for Medicare Survey
RACS' responses to the public consultation survey on the Working Better for Medicare Review
Read RACS' responses (DOCX 979.27KB)
Public Consultation on Draft Guidelines for Surgical Cosmetic Procedures
RACS supports the Australian Society of Plastic Surgeons (ASPS) submission concerning improving regulation of non-surgical cosmetic procedures. RACS also included comments on Facilities and non-surgical cosmetic procedures and the draft guidelines.
Read RACS submission (PDF 159.08KB)
Health Technology Assessment (HTA) Submission
RACS made a submission to the Health Technology Assessment (HTA) review, endorsing the reporting of environmental impacts and using this data in approval and reimbursement decisions for health technology products.
Read RACS submission (PDF 212.11KB)
Health Practitioner Regulation National Law- Amendment Bill
RACS recently responded to an Australian Government draft consultation on the Health Practitioner Regulation National Law- Amendment Bill.
Submission on Prescribed List Reforms – Consultation Paper 9 on Cardiac Implantable Electronic Devices (CIEDS) and the Cost of Technical Support Services (TSS)
RACS wrote a submission with input from President Kerrin Fielding, ANZSCTS President Dr. Emily Granger, Associate Professor Andrew Cochrane AM Council Specialty member, and Professor Mark Frydenberg AM HPAC Chair, providing feedback on the Prescribed List Reforms in Consultation Paper 9. While RACS supports the government's aim to reduce upfront costs and improve transparency for Cardiac Implantable Electronic Devices (CIEDs) and Technical Support Services (TSS), RACS cautioned that separating these costs may lead to increased patient expenses and added complexity. RACS advocates for a clear, transparent, and equitable funding model to prevent financial and logistical burdens on patients and healthcare providers.
Read RACS submission (PDF 182KB)
Letter regarding draft Guidance for health service organisations on the introduction of new interventional procedures
RACS wrote to the Australian Commission on Safety and Quality in Healthcare to comment on the draft Guidance for health service organisations on the introduction of new interventional procedures and to provide its critique from a surgical perspective.
Read the full letter (PDF 327.27KB)
Letter regarding proposed reforms to The Health Practitioner Regulation National Law
RACS wrote to the Department of Health to provide its input as it relates to Australian health ministers' proposals for change and reform to the Health Practitioner Regulation National Law (Victoria included) with a focus on three key areas: Increased Transparency, Nationally Consistent Re-registration, and Protection for Complainants and Whistleblowers.
Read the full letter (PDF 325.85KB)
Letter regarding Vaping Reforms Bill 2024
RACS wrote to the Senate Committee for Community Affairs Legislation to express its strong support for the Therapeutic Goods and Other Legislation Amendment (Vaping Reforms) Bill 2024
Read the full letter letter (PDF 207.36KB)
Letters regarding legislation protecting the title "surgeon"
RACS wrote to the Australian Health Practitioner Regulation Agency (Ahpra)'s Independent Review of the Regulation of Podiatric Surgery to express its support for legislation protecting the title "surgeon" and the passage of the Health Practitioner Regulation National Law (Surgeons) Amendment Bill 2023.
Read the full letter (PDF 241.47KB)
RACS wrote to The Hon. Mark Butler MP, Minister for Health and Aged Care, to express its support for legislation protecting the title "surgeon" and the passage of the Health Practitioner Regulation National Law (Surgeons) Amendment Bill 2023.
Read the full letter (PDF 327.2KB)
Letter regarding Royal Australian and New Zealand College of Radiology position statement on Autonomous Artificial Intelligence
RACS wrote to the Royal Australian and New Zealand College of Radiology (RANZCR) to review and provide comments on its position statement on Autonomous Artificial Intelligence (AI). AI is increasingly being integrated into medical fields such as radiology and surgery, promising enhancements in diagnostic accuracy, efficiency, and overall patient outcomes. However, the adoption of AI in these areas comes with significant concerns, particularly regarding the potential for errors, legal liability, and impacts on insurance.
The Australian Gender Affirming Surgery Report
RACS wrote to the Australian Society of Plastic Surgeons congratulating them on the Australian Gender Affirming Surgery Roundtable held 2nd December 2023 and its subsequent report.