18 November 2021

A little known yet major policy change has been proposed by the Department of Health in a consultation draft on the Primary Health Care 10 Year Plan. The changes proposed would take effect from July 2022 and, if implemented, would have significant impact on ongoing access to certain MBS funded services (initially telehealth).

While the Department has stated it has undertaken two years of consultation with some peak health groups, it should be noted that Painaustralia and other groups we have talked with were not aware such significant changes were being proposed until the Minister released a media statement on 13 October 2021announcing the Draft consultation paper with a four week timeframe for submissions.     

The Plan was developed as a high-level response to the recommendations of the Primary Health Reform Steering Group. Unfortunately, as far as we are aware, those consultations have not included people living with chronic pain.

The most fundamental change proposed is that patients would need to be registered with a practice in order to access MBS funded services – titled ‘voluntary patient registration’. The UK has a registration model that similarly requires patient registration in order to access particular health services. 

If implemented well, it could reward outcomes-focussed quality health care and penalise low value patient care. It could also, for example, enable  multidisciplinary models of care to be supported to ensure access to quality evidence-based care. 

However, shifting away from fee for service to a blended payment model that rewards quality of care and outcomes is ONLY available to the registered population of patients.

While on the surface there are some obvious advantages to this model of care, when it comes to people living with chronic pain, there are two key considerations that must be taken into account. 

The first is that  those with the most complex conditions and highest healthcare needs must be prioritised or there may be  an incentive for practices to ‘cherry pick’ by registering less costly and less complex patients. These are unlikely to be those living with chronic pain conditions and those who are disadvantaged (often they are both) who require complex care and for which outcomes can be difficult to achieve and measure. We must ensure that those with complex chronic pain conditions are actively included in any voluntary registration process and that appropriate levels of funding are allocated to meet their needs or they will be worse off than they are now in a fee for service model that doesn’t support best practice quality of care outcomes.

The second concern about voluntary registration is that the needs of people with chronic pain be specifically recognised in the funding reforms. It’s easy to see how the current disease-based definitions of complex chronic conditions can too readily focus on clearly defined individual diseases such as diabetes or coronary heart disease while overlooking chronic pain (despite high prevalence and multimorbidity) which could fall between the cracks if it is not considered a ‘disease’ in its own right.

It is essential that prior to any implementation of Voluntary Patient Registration, a broad communications campaign be undertaken to enable public discussion and educate and inform people living with chronic pain and those most likely to be substantially impacted.

Another focus in the Plan is on support for technology driven advances in healthcare. While this clearly has significant potential to improve care for people with chronic pain (particularly those in rural and regional Australia), it should not exclude non-registered consumers from MBS-funded telehealth services including the MBS funded services for allied health, mental health and specialist care.

One of the promising areas of potential improvement in the draft Plan includes a model of care that Painaustralia recently outlined in our enews bulletin that would trial rural area community controlled health organisations (similar to the successful Aboriginal Community Controlled Health model) which we believe may have great potential to attract the necessary workforce teams and offer responsive care that meets the needs of local communities.

Finally, we have welcomed the commitment to establishing a baseline evaluation framework and indicators for the evaluation of the Plan. These measures must demonstrate the impact on our most vulnerable and high needs groups including those living with pain conditions. It should also expand approaches that work well and remove those that impede quality care.

Like all chronic conditions, chronic pain is more often managed in the community and quality primary healthcare is critical to achieving good outcomes. We must ensure that major reforms to primary care reflect the needs of our most complex and vulnerable Australians while providing improved care for those living with chronic pain.

Carol Bennett, CEO

Painaustralia’s submission ‘Future Focussed Primary Healthcare: Australia’s Primary Health Care 10 year Plan 2022-2032’ can be found here.