Medicare-funded diagnostic imaging services consultation - Regulation Impact Statement (RIS)

About improving the quality and safety of Medicare-funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements

Page last updated: 02 May 2016

Stakeholder submissions

The ‘Medicare-funded diagnostic imaging services consultation’, Regulation Impact Statement (RIS) was released for comment between 14 May 2015 and 25 June 2015. Through it the Department of Health invited comment regarding:
    • the likely regulatory impacts and costs, on consumers and businesses, of government proposals
    • matters relevant to the implementation of the proposals
    • additional suggestions not included in the RIS.
The table below lists the individuals/organisations that have provided comments on the RIS, and includes links to the PDF and word versions.
No.Individual or organisationPDF versionWord version
1A/Prof Nick StephensonVersion (PDF 255 KB)Version (Word 474 KB)
2Australian Institute of Radiography Version (PDF 148 KB)Version (Word 47 KB)
3Australasian Society for Ultrasound in MedicineVersion (PDF 321 KB)Version (Word 556 KB)
4M4 Healthcare PtyVersion (PDF 148 KB)Version (Word 49 KB)
5Australasian Sonographers AssociationVersion (PDF 243 KB)Version (Word 103 KB)
6Alpenglow Australia Pty LtdVersion (PDF 339 KB)Version (Word 478 KB)
7X-Ray & Imaging Pty LtdVersion (PDF 140 KB)Version (Word 28 KB)
8Radiology Support, Health Support QueenslandVersion (PDF 148 KB)Version (Word 37 KB)
9Chiropractic Australia LtdVersion (PDF 223 KB)Version (Word 53 KB)
10HDAA Australia Pty LtdVersion (PDF 131 KB)Version (Word 40 KB)
11Confidentiality requestedVersion (PDF 131 KB)Version (Word 42 KB)
12Quality Innovation Performance (QIP)Withheld at respondents requestWithheld at respondents request
13Australian and New Zealand Society for Vascular Surgery (ANZSVS)Version (PDF 95 KB)Version (Word 22 KB)
14The Cardiac Society of Australia & New ZealandVersion (PDF 153 KB)Version (Word 47 KB)
15Royal Australian and New Zealand College of Obstetricians and GynaecologistsVersion (PDF 143 KB)Version (Word 53 KB)
16Australian Diagnostic Imaging AssociationVersion (PDF 112 KB)Version (Word 57 KB)
17National Association of Testing Authorities Australia (NATA)Withheld at respondents requestWithheld at respondents request
18Australian Orthopaedic AssociationVersion (PDF 246 KB)Version (Word 124 KB)
19Royal Australian College of General PractitionersVersion (PDF 165 KB)Version (Word 243 KB)
20Australasian College of Physical Scientists and Engineers in Medicine (ACPSEM)Version (PDF 155 KB)Version (Word 57 KB)
21Royal Australian and New Zealand College of Radiologists (RANZCR)Version (PDF 195 KB)Version (Word 123 KB)
22Confidentiality requestedWithheld at respondents requestWithheld at respondents request
23Confidentiality requestedVersion (PDF 140 KB)Version (Word 50 KB)
24
Chiropractors' Association of AustraliaVersion (PDF 3739 KB)Version (Word 303 KB)
25Confidentiality requestedWithheld at respondents requestWithheld at respondents request
26WA Country Health ServiceVersion (PDF 135 KB)Version (Word 29 KB)

Next steps

  1. The Department of Health (the Department) will consider the consultation comments that have been received and assess the impact of potential change, including the potential impact on rural and remote areas.
  2. Further consultation via stakeholder meetings is expected to clarify the feedback received in formal submissions and will be used to revise the potential costs and benefits associated with the proposed options. In addition, the Department may undertake further, targeted consultation with key industry stakeholder groups.
  3. The Department will provide the Australian Government with options for consideration.
  4. The intention is that should changes be agreed, there will be sufficient time for diagnostic imaging practices, requesters and consumers of diagnostic imaging services to incorporate any changes into their working arrangements.

Background

Over time, stakeholders have expressed a desire for greater clarity regarding the level of supervision required while diagnostic imaging services are being performed. This Regulation Impact Statement (RIS) was developed (by the Department) specifically to enable this problem to be described and potential solutions sought.

This RIS was designed to encourage stakeholders to:
  • review the current Medicare requirements for the provision of diagnostic imaging services
  • explore options for enhancing quality, reducing waste and minimising the harm caused by inappropriate, unnecessary and sub-optimal diagnostic imaging services.
The consultation process was designed to draw public comment that informed Australian Government decision-making regarding how to improve the quality and safety of Medicare-funded diagnostic imaging services through changes to the regulatory environment.

To do this, the consultation RIS:
  • described the existing regulatory framework
  • documented problems associated with the existing regulatory framework
  • outlined the objectives of reform
  • suggested proposals for reform
  • invited comment on the likely impact of implementation of the suggested proposals.
Respondents were asked to address any, or all of the options posed and/or to identify other issues (as per departmental submission template). In As such, comments were sought in relation to:
  • the appropriateness and feasibility of the proposals
  • whether the proposed changes would address current concerns held by the diagnostic imaging sector
  • potential cost impacts
  • potential workforce impacts
  • patient access to appropriate imaging including rural and remote access
  • the time required to implement the proposed changes
  • the impact on small and large diagnostic imaging practices
  • any other relevant comments, questions or concerns.

The Consultation RIS is attached below:

Regulation impact statement (RIS) Improving the quality and safety of Medicare funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements (PDF 1341 KB)
Regulation impact statement (RIS) Improving the quality and safety of Medicare funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements (Word 128 KB)

The dedicated RIS templates, used for seeking input are attached below:

Consultation Regulation Impact Statement: Improving the quality and safety of Medicare funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements - Consultation submission (PDF 169 KB)
Consultation Regulation Impact Statement: Improving the quality and safety of Medicare funded diagnostic imaging services through the enhancement of regulatory and accreditation requirements - Consultation submission (Word 518 KB)

For further information please email the Diagnostic Imaging Team.