AUSTRALIAN MEDICAL
ASSOCIATION
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T I 6 I 2 6270 5400
FI 61262705499
E I 111fo@ama.com.au
W I w1,vw.ama com au 42 lv1acqur1ri St Barton ACT 2600
PO Box 6090 Kingston ACT 2604
AMA Submission on the NDIS Quality and Safeguards Commission
Joint Standing Committee on the National Disability Insurance Scheme
By email: ndis.sen@aph.gov.au
Thank you for inviting the AMA to provide feedback on the inquiry into the NDIS Quality and Safeguards Commission. The AMA continues to support the NDIS and as such believe a functional Quality and Safeguards Commission is important to achieving its goals. The AMA has one recommendation based on the terms of reference and one general comment to provide.
Comment on terms of reference A, C and F
The AMA has previously recommended to the Commission that it should develop a scale of fees covering the reasonable costs of medical practices when providing clinical records to investigators. Currently, medical practices are required to cover these costs themselves, with the Commission and its investigators having no regard for the time and costs involved.
There is significant precedent for the development of a scale of fees to cover the reasonable costs incurred by medical practices and we do not see that it would impose a significant cost burden on the NDIS.
When dealing with requests for information under other laws such as the Privacy Act, medical practices are able to recover reasonable expenses and schemes like workers compensation provide a scale of fees for the provision of clinical records. We also know that Courts will make an order for the recovery of expenses in complying with Court notices.
The work involved in providing clinical records can be extensive and absorb a significant amount of practice resources. While they are very happy to cooperate with lawful requests for information, they should not be expected to do this to their own financial detriment. It is longstanding AMA policy that doctors should be entitled to recover from the patient or from any other legally authorised person or authority requesting the information, the reasonable cost of providing access to the information contained in a medical record.
General Comment
The issue of payment of doctors for providing services relating to the NDIS is longstanding. Doctors are not included in the NDIS but are an essential part of any participants healthcare team. The lack of clarity around billable MBS items for doctors providing services to NDIS participants is demonstrable of broader problem in how general practice is regarded in the NDIS. GPs are expected to undertake extremely time consuming work in providing complex information on behalf of patients who are applying for, or participants in, the NDIS – yet this is essentially unfunded.
AMA submission on the NDIS Quality and Safeguards Commission Page 1
Australian Medical Association
The AMA’s position is that the time taken to complete any form for a Government benefit may be claimed by the treating doctor under a Medicare item when included as part of a consultation. The AMA is satisfied that legally this may occur, however the wording of item descriptors is unclear.
The AMA has contacted the Department of Health requesting that amendments be made to item descriptors, but clear communication from the NDIS explaining that doctors can claim for assisting patients with NDIS applications or other essential forms is also advisable.
Thank you for taking the time to review the AMA’s submission.
JULY 2020
Contact
Nicholas Elmitt
Policy Adviser
General Practice and Workplace Policy Department
AMA submission to TGA re criteria for Appendix M – 19/85 Page 2