MBS Review
Report of the MBS Principles and Rules Committee (PRC)
AACP response to PRC Report
The MBS Review is now well underway and a number of reports have been released over the past few weeks for comment. The AACP has been making representations at various times to the MBS Review and has made a number of nominations for consideration for membership of clinical committees.
Most recently the AACP has responded on the MBS Principles and Rules Committee’s (PRC) Report. This committee was established: “to consider matters falling within the scope of the MBS Review which are not of a strictly clinical nature. This includes the examination, and updating where appropriate, of the legislative and regulatory framework underpinning the MBS, but also involves consideration of broader questions about the principles, objectives and boundaries shaping the MBS’s conceptual approach and its impact in practice”.
The Committee has made recommendations on the following issues:
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Provider education in MBS rules and processes
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The ‘complete medical service’ and the multiple operation rule
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Initial vs subsequent attendances and determining a single course of treatment
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Removal of the differential MBS fee structure for remaining ‘G&S’ items
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Co-claiming attendances with procedures
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Aftercare
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Specialist to specialist referrals
While it has responded on all the recommendations, the AACP has particularly focussed on the matter of initial vs subsequent attendances and determining a single course of treatment, because the PRC’s recommendations do not appear to recognise the broad range of situations applicable to consultant physician / consultant paediatric practice that would be affected by the PRC’s recommendations were they to be implemented.
The AACP is following this issue closely and the AACP is arranging for the President to meet with the Taskforce Chairman shortly to discuss these and other issues.
The AACP is concerned about the potential impact of this recommendation if implemented, and pointed out the importance of consultation between the various committees of the MBS Review to ensure that recommendations will not have unintended consequences. The committee dealing with CPP / specialist consultations has not yet been established.
Initial vs subsequent attendances and determining a single course of treatment
The questions of when an initial attendance item may be charged and what constitutes a “single course of treatment” were looked at by the PRC.
The PRC’s report included data that showed instances of billing for initial attendances with a “new referral”, but at the same time the PRC acknowledged that: “most specialists and consultant physicians who see patients on an ongoing basis do not claim a new initial attendance item (item 104 or 110) after a defined period”. The PRC noted the data support this. The PRC’s report also noted that it is not possible to ascertain from the data which are genuine new courses of treatment for different conditions.
In view of the above comments in the PRC’s report, it is therefore not clear why the committee has recommended:
That only one initial attendance item be claimed in relation to any single course of treatment for a particular patient, regardless of the duration of that course of treatment. All other attendances are to be considered subsequent attendances.
since this recommendation is not supported by the data the PRC has quoted.
Further, while the PRC noted that the current explanatory notes make provision for a range of reasons to support charging an initial attendance item, the PRC has determined that “there seems to be an excess of initial specialist and consultant physician attendances (items 104 and 110) being claimed” that it attributes “in part ... to confusion over whether initiation of a new referral is linked to the ability to claim an initial attendance”.
The AACP’s response was that what constitutes a “single episode of care” is not always clearcut. For example, we pointed out that a sub-specialist who deals with cardiac problems may only deal with that condition for his/her patients and thus the condition may be defined as a "single episode of care". However a sub-specialist consultant physician / consultant paediatrician who is dealing with patients with diabetes may also be managing a range of other related conditions such as heart disease, cerebrovascular disease, kidney disease and nerve disease and, at any stage, additional morbidities may present. The PRC’s recommendations suggested a lack of understanding of these situations.
Similarly, rheumatologists and nephrologists may also be dealing with multiple conditions. Therefore, restrictions which determine that only a subsequent item may be billed fail to acknowledge not only the ongoing complexity of the patient’s condition, but also the frequency with which the patient’s condition changes such that the CPP is no longer dealing with what might have originally been defined as a “single course of treatment”.
Accordingly, the PRC’s recommendation is not supported by the available data, nor does it reflect CPP practice.
The PRC has proposed other options for discussion:
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Amending rules and definitions around the concept of a ‘single course of treatment’ to improve clarity
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Introducing a time-tiered attendances structure for specialists and consultant physicians, as currently applies to GP attendances
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Abolishing the initial/subsequent attendance structure and replacing it with a new single specialist attendance item, supplemented by an extended specialist attendance item where the attendance lasts for longer than, say, 40 minutes. The fee for the ‘new’ specialist attendance item would be designed to be cost neutral overall.
The PRC is referring these views to the Specialist/Consultant Physician Attendances Clinical Committee for consideration. The AACP has made a number of nominations for this committee.
Clearly any changes to the above would be significant and the AACP is developing submissions on these matters.
AACP members are encouraged to have their say on all the above issues and provide their input both directly to the MBS Review when these issues are being considered by the Specialist/Consultant Physician Attendances Clinical Committee and also to provide input to the AACP, together with any relevant data, to assist with our next round of submissions.
Finally, the PRC has acknowledged the importance of the referral system as a “key operational component of Australia’s healthcare system”; the AACP also strongly endorses the continuation of the referral system. A copy of the AACP’s recent submission on referrals (with data drawn from the AACP’s referrals survey) was attached to the AACP’s submission on the PRC’s recommendations.