Section 3GA workforce programs
In 1996, the Health Insurance Act 1973 (the Act) was amended to include a number of new sections – 19AA, 3GA and 3GC –collectively known as the Medicare Provider Number Legislation. These amendments were introduced to recognise and support general practice as a vocational specialty and to provide a framework for achieving long-term improvements in the quality of the permanent medical practitioner workforce. Under s. 19AA, a medical practitioner is unable to access a Medicare Provider Number unless they hold vocational recognition (by the RACGP, ACRRM, or another specialist medical college) or are participating in an approved training or workforce program under s. 3GA of the Act.
The provisions of the Act allow medical practitioners who are working towards vocational recognition to access Medicare benefits. Approved training programs include the Australian General Practice Training (AGPT) Program, the Remote Vocational Training Scheme (RVTS), the Prevocational General Practice Placements Program (PGPPP), and fellowship programs offered by the specialist medical colleges. These have been discussed in Chapters 3 and 4.
Alongside these, there are a number of approved programs under s. 3GA that are aimed primarily at addressing workforce shortages in particular locations or settings. These are open to both Australian doctors and OTDs who are permanent residents who do not hold vocational recognition, and include:
- The Approved Medical Deputising Service (AMDS) program, which allows participants to provide Medicare-rebatable services in metropolitan ‘after hours only’ accredited medical deputising services offering home visits;
- The Approved Private Emergency Department (APED) program, which was established to overcome a shortage in emergency physicians available to practise in private emergency departments, and enables access to the sessional pool of non-emergency physicians; and
- The Rural Locum Relief Program (RLRP), which is described above.
The remaining s. 3GA programs have been introduced as mechanisms to address certain exceptional circumstances that preclude access to a provider number:
- The Special Approved Placements Program (SAPP) provides access to Medicare benefits for those doctors who are unable, due to extreme personal circumstances, to participate in any other s. 3GA program; and
- The Temporary Resident Other Medical Practitioners (TROMPs) program was established in 2001 to address an anomaly created by amendments to the Medicare Provider Number legislation which would have seen a number of long-term temporary resident medical practitioners lose access to a provider number.
Medical practitioners can participate in more than one s. 3GA program at a time.
It should be noted that the SAPP and TROMPs program do not place any restrictions over where participants can practise. There has been a significant increase in the number of medical practitioners participating in the SAPP, from seven participants in 2004-05, to 49 in 2008-09 and 159 in 2010-11.
For the most part, these s. 3GA workforce programs also support the intent of s. 19AA to improve the quality of the medical workforce by requiring participants to work towards vocational recognition (the TROMPs program is the exception).
The exception to this is the TROMPs program, which does not require participants to pursue vocational recognition. However, the number of TROMPs participants has declined substantially from 93 in 2010-11, to five current participants, and it is unlikely that there will be any increase in the future. It is likely that many previous participants have completed their fellowships and are no longer subject to Medicare benefit restrictions. Alternative arrangements should be pursued for this small number of temporary resident doctors.
The balance between the goals of workforce distribution and quality applying to the AMDS was raised by a medical deputising service during the course of the review, who urged caution about placing too great a focus on participants achieving vocational recognition. AMDS participants are eligible for the After Hours Other Medical Practitioners (AHOMPs) program, which also includes a requirement to pursue fellowship.
Under the Act, the operation of sections 19AA, 3GA and 3GC (relating to the Medical Training Review Panel) must be reviewed every five years. The most recent review was completed in December 2010, and DoHA advises that implementation of its recommendations is currently proceeding (where these are consistent with government policy). A summary of the findings of the 2010 Review of the Medicare Provider Number Legislation is included at Appendix vii.
Given the similarity in the operational arrangements of the s. 3GA workforce programs, there could be merit in pursuing the amalgamation of these programs to realise administrative efficiencies, and provide less complexity for participating medical practitioners.
Other medical practitioners programs
Non-vocationally recognised (non-VR) medical practitioners who have been granted a Medicare Provider Number through participation in a s. 3GA workforce program are only entitled to claim the lower A2 Medicare rebate. The Commonwealth supports a number of programs targeted at these ‘other medical practitioners’ (OMPs) that provide a financial incentive – access to the higher A1 Medicare rebate – in return for working in an area of workforce shortage.
The OMPs programs currently available are detailed in the following table.
|Program||Required Area of Practice||Participants Nov 2012|
|After Hours Other Medical Practitioners program (AHOMPs)||Across Australia providing after-hours general practice services|
|Medicare Plus Other Medical Practitioners program (MOMPs)||Districts of workforce shortage|
|Outer Metropolitan Other Medical Practitioners program (OM-OMPs)||Outer metropolitan|
|Rural Other Medical Practitioners program (ROMPs)||RRMA 4 to 7|
The OMPs programs target three key groups of non-VR medical practitioners:
- Temporary residents who are practising within districts of workforce shortage under valid s. 19AB(3) exemptions;
- Permanent resident and citizen medical practitioners who are working towards obtaining vocational recognition as a general practitioner on an approved s. 3GA workforce program, primarily the AMDS program or the RLRP; and
- Medical practitioners who were registered in Australia prior to 1 November 1996 (i.e. prior to the introduction of the Medicare Provider Number legislation) and who are not subject to the vocational recognition requirements of s. 19AA of the Act.
There are a number of differences in the eligibility and professional development requirements between the OMPs initiatives.
While eligibility for the ROMPs and AHOMPs programs is open to all three categories of non-VR practitioners, eligibility for the MOMPs and OM-OMPs programs is restricted to the third category listed above. These two programs were implemented to ensure that non-vocationally recognised medical practitioners who were registered in Australia prior to 1 November 1996 had a mechanism by which they could access Medicare rebates at a level comparable to the level they were entitled to prior to the introduction of s. 19AA of the Act. Under s. 19AA, these medical practitioners are not legally obliged to work towards obtaining vocational recognition.
Given that the pool of non-VR practitioners registered prior to 1 November 1996 is a limited one, it is likely that participation in the MOMPs and OM-OMPs programs will decrease over time. There is also no requirement under the MOMPs program to pursue vocational recognition.
The ROMPs and AHOMPs programs have experienced increased rates of participation and this is expected to continue, due to the increasing number of graduating medical practitioners and limited capacity of general practice training programs such as the AGPT and the RVTS, which offer a fixed number of training places. These programs provide a way for these non-VR practitioners to access to A1 Medicare rebates while pursuing their fellowship.
When considered together, the OMPs programs provide support to increase the quality of the medical workforce (s. 19AA) and increase the supply of doctors in areas of workforce shortage (s. 19AB). The need for a sustainable medical workforce beyond metropolitan areas is discussed in greater detail elsewhere in this report. Suffice it to say that the OMPs programs provide necessary support to a key component of the health workforce whilst they pursue specialist medical qualifications.
The OMPs programs have financial impacts on the MBS and there are associated administration costs borne by DoHA and DHS.
There are some inconsistencies within and between the OMPs programs that may confuse applicants or create unintended consequences. For example:
- Inconsistent use of geographical classification systems across the OMPs programs, with ROMPs relying on the Rural, Remote and Metropolitan Area (RRMA) classification system and OM-OMPs using an idiosyncratic definition of ‘outer-metropolitan’ based on the 2001 ASGC, whilst MOMPs is based on DWS.
- AHOMPs allows medical practitioners to access A1 Medicare rebates for an initial period of six years. To qualify for RACGP Fellowship, medical practitioners require a minimum of four years general practice experience with a maximum of two and a half years being in after-hours only engagements. This presents a disincentive to AHOMPS practitioners to actively seek RACGP qualification and also discourages them from obtaining the additional one and a half years’ experience on an alternate program.
Development of a single OMPs program
A 2009 review undertaken by the Allen Consulting Group found that the OMPs programs have supported the workforce distribution aims of s. 19AB. The review also noted that the eligibility and participation inequities between the programs could be addressed through the creation of a single OMPs program. This was confirmed in stakeholder consultations for this current review. A single OMPs program would also deliver administrative efficiencies, consistent eligibility criteria and a minimum standard of professional development and service quality regardless of practice location.
To date, DoHA has not pursued the development of a single OMPs program, apparently on the basis that it may be criticised for treating the different groups of non-VR medical practitioners differently due to the operation of s. 19AA and s. 19AB. For example, MOMPs participants are currently not required to work towards vocational recognition, but could be required to do so under a consolidated OMPs program.
The introduction of a single OMPs program, it has been argued, also has the potential to diminish the effectiveness of the rural element, by allowing a greater pool of non-VR practitioners to access A1 rebates in outer-metropolitan and DWS areas (currently limited to the pre-1996 non-VR practitioners). This issue would need to be considered within the design of a consolidated program.
However, on balance the benefits of a consolidated program would outweigh these concerns, which could be mitigated by careful program design. The unnecessary complexity of maintaining and administering several OMPS micro-programs appears difficult to defend.
Stakeholders consulted during this review noted that the operation of the inter-related AMDS program and RLRP should be considered in developing any streamlined arrangements for the OMPs programs. For example, any modification to the geographical classification system used in the ROMPs program would need to be aligned with that of the RLRP to ensure consistent treatment of medical practitioners.
|Recommendation number||Recommendation||Affected programs||Timeframe|
|Recommendation 6.9||The Commonwealth should consolidate the existing Section 3GA workforce programs.||All 3GA programs||Medium term|
|Recommendation 6.10||The Commonwealth should combine the After Hours Other Medical Practitioners program, the Medicare Plus Other Medical Practitioners program, the Rural Other Medical Practitioners program and the Outer-metropolitan Other Medical Practitioners program into a single program. In developing the program, issues to consider include:
||All other medical practitioners programs||Medium term|
|Recommendation 6.11||The Department should undertake a process with individual participants on the Temporary Resident Other Medical Practitioners (TROMPs) program so that a timeline can be set for all participants to indicate a clear intention about engaging with the relevant college on a process to proceed to fellowship.||TROMPS||Short term – small number of program participants.|