Private Hospital Data Collection Review Final Report

3.3 A list of private hospitals

Private Hospital Data Collection Review - Final Report

Page last updated: 14 June 2012

      This term of reference has been overtaken by recent events relating to the national health reforms. In particular, NHPA will be required to report on hospitals and will have to decide what constitutes a private hospital in this context. This requirement effectively supersedes any mechanism that this Review might recommend.

      Accordingly, although this Review considered recommendations relating to this term of reference, the Department has advised that those recommendations are no longer required. Nonetheless, this section presents the options considered by the Review, in relation to this term of reference. This information is presented in the hope it may be of value to NHPA and the Department in considering the NHPA requirements for such a list under the national health reforms.

      An authoritative list of private hospitals will need to serve a number of purposes for the Department and the Commonwealth. These include:

      • planning in relation to the nature and distribution of hospital services across Australia;
      • policy analysis and development relating to hospital policy overall and to private hospitals specifically;
      • ministerial briefings and advice;
      • identifying hospitals within scope for different data collections; and
      • identifying hospitals for performance monitoring and reporting, for national reforms as well as for ongoing health system oversight.

      Most private hospitals in Australia are declared under the Private Health Insurance Act 2007. The exceptions are smaller clinics, nursing posts and hospitals that provide services to self insured people or otherwise without the need to lodge a claim with a health insurer.

      In terms of coverage of the private hospital system for the above purposes, these non declared hospitals are marginal and unlikely to add significant capability to a list of private hospitals. Given their non declared status, it is difficult to identify some of these facilities. There is also no effective mechanism for the Department to obtain the desired details from these hospitals. This Review found no clear means by which a suitable such mechanism could feasibly be established and operate effectively.

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      When a hospital is declared, the Department obtains an initials set of hospital details (see Section 2.3.1). It is these items that the Department is most interested in keeping up to date.

      The Department has developed a database internally for storing this information. That database holds the information collected at declaration and allows staff within the Department to access that data for review, update and reporting purposes. The database has been recently developed and is in the process of being implemented across the Department.

      States and Territories collect some of the information that the Department needs for its authoritative list, from hospitals that they license within their respective jurisdictions. The process of declaration under the Private Health Insurance Act 2007 requires that the declared hospital be licensed or otherwise approved to operate by the relevant State or Territory health authority. This means that States and Territories hold some of the information that the Department needs for most of the declared hospitals.

      Moreover, the licence renewal processes in each State and Territory (usually annual) update that information locally. Some jurisdictions, such as Queensland, WA and Victoria, informally pass on updated information to the Department.

      In some cases, such as classes of clinical services offered and category of hospital, the States and Territories classify hospitals differently than does the Department and than does each other. This limits the usefulness of some of the information somewhat. However, it does not render it useless as classes can sometimes be mapped successfully to Departmental classifications.

      A significant gap at the State and Territory level is that South Australia does not license private day hospitals. Therefore, South Australia has no information that it can pass on to the department for this large subgroups of private hospitals in that State.

      An ideal solution to the need for an authoritative list would be a single national list that was able to be shared by the Commonwealth and States and Territories.


      Option 1   Develop a portal for capturing, storing and managing private hospital details

      This option proposes the development of a web based portal for capturing, storing, reviewing and updating private hospitals’ details. The operating model for such a portal would be as follows:
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      • The Department supports and maintains the portal.
      • The portal is accessible by the Department, other Commonwealth agencies, State and Territory health authorities and by private hospitals themselves.
      • Access to the portal is secured with different access privileges for different users. A private hospital could access its own data only, for review and modification, with access to selected fields limited (such as declared hospital status, jurisdictional licence status). A State or Territory health authority could access data for all private hospitals within its jurisdiction, for review, modification and reporting, with access to selected fields limited (such as declaration status). The Department could access all private hospitals’ data, for review, modification and reporting, with access to all fields. Other Commonwealth agencies could access records for all private hospitals, for review and reporting purposes only and with selected fields barred from access.
      • Private hospitals would automatically receive annual reminders (via email) to review and confirm or update their information via the portal.

      Benefits

      • This approach minimises the need for private hospitals to provide similar or the same information to more than one recipient.
      • The process of updating is relatively simple, via a web based interface.
      • It can be modified to issue more frequent reminders than annual, if it’s needed to provide greater confidence that the database is as up to date as practicable.

      Enablers

      • The Department has built its internal database, which could provide the underlying database structure needed to support such a portal.
      • The risk of States and Territories and the Commonwealth using conflicting information regarding the numbers and profiles of private hospitals is virtually eliminated.
      • Compliance with the necessary business processes would be relatively simple for all parties.
      • State and Territory licensing requirements provide a legislative basis with sufficient power to enforce compliance from private hospitals.

      Barriers

      • While the Private Health Insurance Act 2007 provides a legislative framework to require compliance, it does not provide a strong basis for enforcing compliance. This will be an issue for those hospitals not subject to State or Territory licensing requirements.
      • States and Territories would need to agree to modify their current processes and use the portal to collect the information that they need for licence management and renewal purposes. This would require them to be satisfied that security and access controls are sufficient to protect the data for private hospitals within their jurisdictions, as well as giving them sufficient access and control over data over which they currently exercise total control and ownership.
      • There would be significant effort required to set up such a portal. Once set up, its maintenance and support would not be such a significant burden. However, user management and support would need to be provided.

      A solution such as this portal is a long term proposition. At this early stage, it would be over engineering the solution to the problem of an authoritative list of private hospitals, and there would be a significant risk of failure. Nonetheless, it has several attractive qualities that mean it should not be dismissed totally. Rather, alternative approaches should be pursued in the short term, in a manner that does not prevent reconsidering the portal option in the medium to longer term.


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      Option 2   Establish formal arrangements for exchange of private hospital details between the Department and individual States and Territories

      This Review found that at least one jurisdiction (WA) would be amenable to putting formal arrangements in place for sharing private hospitals’ licensing information with the Department. It is likely that other jurisdictions would also be amenable to entering into such arrangements.

      The minimum arrangements would need to include the State or Territory advising the Department when a currently licensed private hospital’s details change. This would provide the Department with an opportunity to actively contact the hospital concerned and seek confirmation or updating of details held by the Department.

      Additional elements to the partnership that should be pursued would be for the State or Territory to also pass onto the Department the updated details for the private hospital.

      Where the Department becomes aware of a private hospital changing its details, then it could reciprocate by advising the relevant State or Territory health authority of the fact and providing any changed details it may have.

      Entering into arrangements such as that described would not prevent consideration or implementation of the portal approach discussed above, at some future date. Indeed, it is more likely to foster a collaborative relationship between the Department and the jurisdictions, which could aid in setting up a portal. It would also offer an opportunity to identify business process issues that might affect the design and implementation of such a portal.

      Benefits

      • The Department would have more timely access to updated details for private hospitals whose licensing details change.
      • States and Territories might likewise have access to more timely intelligence and details regarding changes relevant to private hospitals’ licences.
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      Enablers

      • The Department’s private hospitals information area has good relationships with most States and Territories.
      • For some jurisdictions, entering into such arrangements would simply be formalising an existing, informal practice.
      • The risk of States and Territories and the Commonwealth using conflicting information regarding the numbers and profiles of private hospitals is reduced.

      Barriers

      • While the Private Health Insurance Act 2007 provides a legislative framework to require compliance, it does not provide a strong basis for enforcing compliance.
      • This option does not permit capture of information for those hospitals not subject to State or Territory licensing requirements.


      Option 3   Establish an internal database and annual process for updating private hospitals’ details

      As stated above, the Department has developed an internal database for the purposes of maintaining this authoritative list of private hospitals.

      The current view within the Department is that relationships with private hospitals are generally agreeable and that private hospitals are likely to be amenable to being asked to confirm or update their licence details, from time to time. If a private hospital is provided with a copy of their current details, as known to the Department, the effort involved in checking and providing any updated information would be minimal.

      This effort could be reduced further if the protocol for seeking an update from a private hospital took into account whether the private hospital concerned has had its details updated recently. This might have happened because the hospital contacted the Department itself when its details changed, or as a consequence of advice from a State or Territory health authority.

      In considering how often private hospitals should be approached for confirmation of their details, an annual update is consistent with licensing renewal periods in most jurisdictions.

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      Benefits

      • The Department would have more timely access to updated details for private hospitals whose licensing details change.
      • The risk of States and Territories and the Commonwealth using conflicting information regarding the numbers and profiles of private hospitals is reduced.

      Enablers

      • The Department’s private hospitals information area has reasonable relationships with the private hospital sector.

      Barriers

      • While the Private Health Insurance Act 2007 provides a legislative framework to require compliance, it does not provide a strong basis for enforcing compliance.
      • The Department needs to ensure its database captures the date of the most recent update or confirmation of the private hospital’s details. This should not be a difficult barrier to overcome.