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ADF - Accreditation Systems Review – Submission

Accreditation Systems Review – Submission

The Australian Doctors’ Federation has examined the 188 page report, and the 38 draft recommendations and comments as follows in regard to the Australian medical profession. The ADF does not seek to speak for other health professions.

1. According to the Australian Public Service Commission, “There is no ‘one size fits all’ approach. … The structure should be matched to the task.”1 The ADF maintains that a major problem with the analysis and recommendations of the Accreditation Systems Review (ASR) is its desire to impose a ‘one size fits all’ structure onto what is essentially a complex adaptive system. The ASR recommendations treat healthcare delivery as a closed system by recommending centralised top-down management and compliance with social policy directives. This is at best naïve, and at worst a threat to public safety.

2. There are good reasons why Australian healthcare has been delivered through separate and specialised professions. It is a risk management system that works with high regard for patient safety by holding the medical practitioner legally accountable for the outcome of the patient’s medical treatment. As such, the medical profession must determine the content and method of its own education and training. This important foundation of medical practice cannot be determined by health economists or anyone who does not have direct legal accountability for the delivery of medical treatment.

3. The ADF draws the attention of all Parliamentarians to the following quote from the report: ‘Although not referenced in the National Law, one of the principles is that “While we balance all the objectives of the National Registration and Accreditation Scheme, our primary consideration is to protect the public.” The Review considers that this is a retrograde step, with safety and quality potentially being offered as reasons to resist beneficial innovation and the development of a flexible, responsive and sustainable workforce.’2

4. Parliamentarians are well aware of the tragedy that occurs when issues of safety and quality are downplayed, bypassed or ignored in the delivery of healthcare. For this reason, Australian law has insisted that medical practioners are legally liable to their patients to ensure that the advice and treatment they give meets high standards of patient safety. The ADF is alarmed that the principle of public safety, which has been established by the National Boards is now considered “retrograde” by the Review. There are major implications for legislators should the approach of the Review be endorsed.

5. The scientific basis of medical education and training has emerged in response to a demand for safer and more effective medical interventions. This process has delivered world class

1 Australian Public Service Commission (2012), Connecting Government: Whole of government responses to Australia's priority challenges,

2 Accreditation Systems Review Draft Report, p. 95

medical care in Australia, contributing to greater life expectancy and higher quality of life for many Australians. The recommendations of the report would impose top-down, non-scientific directives/objectives (including workforce experimentation) into the education and training process through a government appointed Health Education Accreditation Board (HEAB) and an empowered Agency Management Committee (AManC). The ADF maintains that this would amount to a weakening of medical education and training and a demand that it deliver on conflicting and confusing objectives. i.e. a mix of science and social policy.

6. The ADF respects the work of the Australian Medical Council (AMC) and believes it is critically important that this Council remains an external and independent body from the health regulator and that it continue to be able to give direct, independent, unmanaged and uncontrolled advice to all Federal and State jurisdictions. This process is an important part of removing critical public safety decision making from the political process. The recommendations of the ASR would needlessly reduce and diminish the role of the AMC to a reporting body, contrary to previous decisions by Federal and State Health Ministers made for considered and valid reasons of public safety at the establishment of NRAS.

7. The ADF notes that the ASR recommends that interprofessional training be mandatory. This represents an authoritarian, top-down approach to the complexities of Interprofessional cooperation and training and is a grave misunderstanding of the way the health workforce must function in any particular situation. Cooperation and teamwork between professionals emerges from in-situ responses to healthcare needs, demands and emergencies and must always be flexible and locally coordinated and led. In addition, appropriate clinical risk-management will require that critical decisions (high downside impact) be made by those with the greatest expertise in whole-body systems. This is accepted practice among experienced health professionals who are legally accountable for healthcare outcomes.

8. There is no evidence that Australia is not producing a sufficient number of healthcare professionals. Medical graduation rates are now at around 3,000 per year and the rural medical workforce has increased significantly. In addition, Australian healthcare reflects our own unique response to the challenges of delivering high quality accessible healthcare services to the entire population. This includes a strong public/private sector balance and general and specialist medical training with interprofessional cooperation and quick response to national emergencies. Any attempt to borrow or impose interventions from the UK, US or elsewhere, need critical examination as these jurisdictions do not appear to have outperformed Australia’s healthcare standards.

9. The ADF is concerned at the lack of data or evidence offered in regard to the recommendations of the ASR. It is based on assumptions by health economists of efficiency and responsiveness, which are not justified in the report and remain aspirational. This should also concern legislators and anyone who is interested in the health and wellbeing of all Australians.

10. In regard to the Australian medical profession, the ADF does not support any change to the current role, standing or independence of the Australian Medical Council and believes that the accreditation of Australian medical education and training must remain the direct responsibility of those who have the medical expertise, experience and legal accountability to deliver the next generation of doctors.

Dr John M Harrison AM Chairman, Australian Doctors’ Federation

16 October 2017

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