<!--HTMLCleanerRegion--> APPENDIX 3


APPENDIX 3

Letter from the Australian Council for Healthcare Standards (ACHS), 17 November 2010.

Answers to questions on notice from the Department of Health and Ageing, 12 November 2010, including revisions made by the Department to take account of the letter from ACHS, provided 18 November 2010.

 

Community Affairs Legislation Committee

ANSWERS TO QUESTIONS ON NOTICE

HEALTH AND AGEING PORTFOLIO

Inquiry into National Health and Hospitals Network Bill 2010

9 November 2010

Question no: 1

OUTCOME 10: Health System Capacity and Quality

Topic:  National Health and Hospitals Network Bill 2010

Hansard Page:  CA

Senator  asked:

Dr Kathryn Antioch (submission 10) notes that there is the potential for overlap of functions with the National Health and Medical Research Council (NHMRC) – particularly in the area of guidelines development.  A similar issue arises with the work of the Australian Council on Healthcare Standards with respect to the development of standards and indicators (submission 22).

Please outline the work the Department has undertaken on this issue including ways in which this potential for overlap will be managed?

 

Answer:

Interaction with NHMRC

Both the NHMRC and the Australian Commission on Safety and Quality in Health Care (the Commission) have a role in the development of National Clinical Safety and Quality guidelines.  The work of both the Commission and the NHMRC is complementary and mutually supportive.  There is an already well-established close relationship between these two national organisations with a mutual intent of preventing duplication of activity and ensuring that the ongoing work of both is complementary and mutually supportive.

The Commission will prioritise the areas in which guidelines are developed and promote and assist in their implementation. It will source the writing of guidelines from the expert groups who already do this in Australia, particularly the NHMRC.

The importance of the role of the NHMRC in the development of guidelines is recognised by the Australian Government through the allocation of around $1 million per year in funding to the NHMRC to provide validation of the process undertaken to develop the clinical guidelines.  This will ensure that the guidelines are of the highest quality and meet already well‑established NHMRC standards, and that the work of both the Commission and the NHMRC is complementary and mutually supportive.

In relation to the development of guidelines, the Commission will maintain and formalise its relationship with NHMRC to ensure there are no overlapping functions.  This is achieved by Commission representation on Committees, working groups and in the processes of the NHMRC.  

The NHMRC and the Commission have experience in working together in bringing this supportive expertise to projects.  The most recent example of joint work being undertaken between the Commission and the NHMRC has been the development of the Australian Guidelines for the Prevention and Control of Infection in Healthcare.

Interaction with accrediting organisations

The Commission and accrediting agencies have separate roles.  The Commission promotes and improves safety and quality across the whole of the Australian healthcare system.  This will include working across the acute care, primary health care and mental health care sectors on matters relating, but not limited to, development of national clinical safety and quality standards, indicators and guidelines, prevention of healthcare associated infection and patient centered care.  Accreditation agencies, on the other hand, will accredit health service organisations against the standards developed by the Commission.

The Commission will be responsible for developing national standards across all healthcare settings.  The Commission is developing a nationally consistent set of safety and quality accreditation standards that can be applied across all healthcare sectors, not just restricted to hospitals, primary health care or mental health.  While the ACHS has a major role in the accreditation of hospitals it also has a role in accreditation of other community and primary care settings, along with other accreditation agencies operating in these settings.

While there is a multiplicity of accreditation standards, none of these meet the need for a single set of nationally consistent safety and quality standards that can operate across all hospital and non-hospital health services.  The development of one national set of standards will:

  • Reduce the variation and costs associated with multiple sets of standards;
  • Reduce limitations in the current sets of standards; and
  • Increase transparency and access to standards.


Community Affairs Legislation Committee

ANSWERS TO QUESTIONS ON NOTICE

HEALTH AND AGEING PORTFOLIO

Inquiry into National Health and Hospitals Network Bill 2010

9 November 2010

Question no: 2

OUTCOME 10:  Health System Capacity and Quality

Topic:   National Health and Hospitals Network Bill 2010

Hansard Page:  CA

Senator  asked:  

Catholic Health Australia has submitted that—as the organisation representing several not-for-profit hospitals—it is important they are consulted in the development of standards, indictors etc.

Given the vague or general nature of who must be consulted in the Bill, what assurance can you provide to Catholic Health Australia and other stakeholder groups that their views will be taken into account?

Answer:

Catholic Health Australia is an active contributor to the processes of the Commission, and has two nominees on the Private Hospital Sector Committee.

The National Health and Hospitals Network Bill 2010 (NHHN Bill) makes provision under Section 10 for the establishment of a process for consultation with a broad range of stakeholders, including the public, and ‘any other persons or bodies who, in the Commission’s opinion, are stakeholders in relation to the formulation of the standards, guidelines and indicators.’ In addition, Section 9(1)(m) of the NHHN Bill makes it a function of the Commission to consult and cooperate with other persons, organisations and governments on healthcare safety and quality matters.

It is intended that the process of consultation would ordinarily include providing an opportunity for all relevant parties to provide comments, a reasonable timeframe within which to provide those comments and that those comments would be taken into consideration by the consulting party.

In making specific provision for consultation the NHHN Bill sets an expectation that the Commission will consult widely and will comply with international best practice standards.  While each stakeholder is not explicitly listed in the NHHN Bill, it is anticipated that the Commission will regularly consult with consumers, carers, health service organisations – both public and private, clinicians and peak bodies, including Catholic Health Australia.

Consultation Process for Development of Key Projects

The Commission has had a strong focus on stakeholder engagement throughout its work to date and is committed to consulting with a diverse range of stakeholders and consumers on the development of standards, guidelines and indicators to ensure their relevance, effectiveness and ultimately, the appropriateness of services being delivered in a particular healthcare setting. 

The Commission routinely invites public comment on key projects through the development of consultation papers made available on their website, and this level of stakeholder engagement is expected to continue.  For example, the Commission has developed a consultation paper on the development of the draft National Safety and Quality Health Service Standards (the Standards).  A copy of the consultation paper is at Attachment A to this Question on Notice response.  Organisations invited to provide a response are listed at Attachment B.  A list of respondents is at Attachment C.

The Commission has also adopted a formal seven-stage methodology for engaging stakeholders in the development of the Standards.  A copy of the methodology is at Attachment D to this Question on Notice response.

For example, consultation on the Standards to date has comprised:

  • Consultations with jurisdictions, health services, consumers, industry and member organisations and accrediting agencies between 2006 and 2008 on the Standards and their use in a model national accreditation scheme.
  • The development of the draft Standards initially involved a large number of participants who are technical experts, consumers and industry representatives advising Commission programs, and/or members of working groups and/or Commission Standing Committees, including the:
  • Inter Jurisdictional Committee
  • Private Hospital Sector Committee (noting that Catholic Health Australia has two nominees on the Private Hospital Sector Committee)
  • Accreditation Implementation Reference Group
  • Healthcare Associated Infection Implementation Advisory Group
  • Healthcare Associated Infection Surveillance Expert Working Group
  • Medication Reference Group Committee
  • Patient Identification Expert Working Group
  • Clinical Handover Expert Advisory Group
  • Recognising and Responding to Clinical Deterioration Advisory Committee
  • Workshop of key stakeholders involved in Blood and Blood Products
  • Teleconference with jurisdictional representatives responsible for Pressure Ulcers
  • Teleconferences with the National Pressure Ulcers Advisory Panel
  • Workshop of key technical and consumer representatives
  • Release of a consultation paper on the Draft National Safety and Quality Healthcare Standards, November 2009 for public comment, in addition to targeting health services and key industry organisations for their response.
  • Analysis of 183 written submissions on Standards from throughout the health industry.
  • Focus groups involving consumers in Queensland, Victoria, South Australia and Western Australia and New South Wales.
  • Meetings and workshops with all accrediting agencies and standard setting bodies.
  • The first five standards were piloted in 26 health services across Australia and involved nine accrediting agencies.

This level of consultation will be replicated for any review of the standards.

While it is not expected to be required to ensure proper consultation, there are powers provided under section 10(6) of the NHHN Bill that enable the Minister to make rules to be complied with by the Commission in formulating standards, guidelines and indicators. 


Community Affairs Legislation Committee

ANSWERS TO QUESTIONS ON NOTICE

HEALTH AND AGEING PORTFOLIO

Inquiry into National Health and Hospitals Network Bill 2010

9 November 2010

Question no: 3

OUTCOME 10 Health System Capacity and Quality

Topic: National Health and Hospitals Network Bill 2010  

Hansard Page:  CA

Senator Boyce asked:

For an ‘ordinary use’ definition of the term ‘clinician’. It was further requested that any standard (legal or otherwise) definition be provided if such a definition exists.

Answer:

The term ‘clinician’ appears in section 10(2) in the National Health and Hospitals Network Bill 2010 (the Bill) in relation to consultation for formulation of standards, guidelines or indicators.

The Australian Commission on Safety and Quality in Health Care has an established history of wide consultation in the development of such documentation to date. For the purposes of the Bill an ‘ordinary use’ of the term ‘clinician’ may refer to: an individual whose training and qualification is principally related to the provision of health care services and includes, but is not limited to, doctors, nurses, allied and other health practitioners.


Community Affairs Legislation Committee

ANSWERS TO QUESTIONS ON NOTICE

HEALTH AND AGEING PORTFOLIO

Inquiry into National Health and Hospitals Network Bill 2010

9 November 2010

Question no: 4

OUTCOME 10 Health System Capacity and Quality

Topic:  National Health and Hospitals Network Bill 2010

Hansard Page:  CA

Senator asked:

Dr Kathryn Antioch (submission 10, p. 1.) observes that a number of other terms used in the bill should be defined under clause 5. These include:

  •   Standards
  •   Indicators
  •   Guidelines
  •   Model accreditation scheme
  •   Lead clinical groups

Is there any reason why definitions for these terms were not included in the bill? Please provide, where possible, definitions for these terms.

Answer:

The Department notes that these terms should be given their ordinary meaning.  Below are some commonly understood descriptions of standards, guidelines, indicators, model accreditation schemes and lead clinician groups to assist with understanding.

Standards and Guidelines

Clinical safety and quality standards and guidelines are designed to ensure the consistent provision of high quality clinical practice. They are based on evidence and, where necessary, “considered judgement” and relate to best practice and the appropriateness and effectiveness of care.  

Clinical standards act as markers of high quality, clinically cost effective patient care across a pathway or clinical area; are derived from the best available evidence or from the consolidated "considered judgement" of clinicians; and are produced collaboratively with healthcare professionals, organisations and consumers.  A standard provides an explicit statement of the expected level of safety and quality of care to be provided to patients by health services organisations and provide a means for assessing an organisation’s performance.  Elements within a standard may be aspirational.

Clinical safety and quality guidelines are systematically developed statements designed to help practitioners and patients make decisions about the most appropriate health given the specific circumstances in which the care is given.  These guidelines promote and encourage the provision of effective, safe and efficient healthcare.

Indicators

Indicators provide succinct measures that aim to describe as much about a system as possible in as few points as possible.  Indicators help us understand a system, compare it and improve it.  Indicators can be tools to assist in assessing whether or not a standard in patient care is being met.

Model Accreditation Scheme

Health Ministers  have endorsed a Model National Accreditation Scheme developed  by the Commission which builds on the strengths of the current accreditation system and clarifies the respective roles and responsibilities of Health Ministers, regulators, health services, accrediting agencies and the Commission.

Lead clinical groups

Bodies known as Lead Clinicians Groups are ‘Lead Clinicians Groups’ for the purposes of the legislation, and therefore require no further definition.


Community Affairs Legislation Committee

ANSWERS TO QUESTIONS ON NOTICE

HEALTH AND AGEING PORTFOLIO

Inquiry into National Health and Hospitals Network Bill 2010

9 November 2010

Question no: 5

OUTCOME 10 Health System Capacity and Quality

Topic:  National Health and Hospitals Network Bill 2010

Hansard Page:  CA

Senator  asked:

The Mental Health Council of Australia states that: 'The Bill does not refer to a sustained method for better accountability based on consumer outcomes, which must be a key driver in an improved mental health service system.’ (Submission 4, p. 1).

What consideration has been given to this issue?

Answer:

The functions of the Commission, as set out in section 9 of the Bill, provide a framework for the scope of work of the Commission.   As consumer outcomes and experience are key markers of the safety and quality of care, each of the Commission’s programs will be focussed on improved health outcomes for consumers.  The Bill will enable the Commission to take on an expanded range of work, building and continuing on its work in the hospital setting, to expand into primary and mental health care settings.

The current Commission’s work programs have largely focussed on improving safety in the hospital setting. As part of its expanded role, the Commission will set and monitor national quality and safety standards and work with clinicians to identify best practice clinical care, to ensure the appropriateness of services being delivered in a particular health care setting including hospitals, primary and mental health care. 

The setting and monitoring of national safety and quality standards in hospitals, primary and mental health care is integral to promoting better accountability based on consumer outcomes. These national standards will clearly state the high expectations all Australians have of their health care services. 

In its new role, the Commission will build on the work it has already done to promote better accountability based on consumer outcomes through programs such as the evidence based Patient-Centred Care discussion and resource tool document.  This document recognises the centrality of patient and consumer centred care to the National Mental Health Plan, the Australian Safety and Quality Framework for Healthcare, and the Australian Charter of Healthcare Rights and its Consumer Engagement Standard, which is included in the Commission’s accreditation standards.


Community Affairs Legislation Committee

ANSWERS TO QUESTIONS ON NOTICE

HEALTH AND AGEING PORTFOLIO

Inquiry into National Health and Hospitals Network Bill 2010

9 November 2010

Question no: 6

OUTCOME 10 Health System Capacity and Quality

Topic:  National Health and Hospitals Network Bill 2010

Hansard Page:  CA

Senator  asked:

The Consumers Health Forum of Australia argues that clause 58(2), which provides for the protection of patient confidentiality' should be amended to specify that 'consent' should be 'informed consent'.

Can you envisage any problems with such an amendment?

Answer:

The Department does not consider that an amendment of this nature is necessary.  Consent would need to be “informed” in order to be valid consent.


Community Affairs Legislation Committee

ANSWERS TO QUESTIONS ON NOTICE

HEALTH AND AGEING PORTFOLIO

Inquiry into National Health and Hospitals Network Bill 2010

9 November 2010

Question no: 7

OUTCOME 10 Health System Capacity and Quality

Topic: National Health and Hospitals Network Bill 2010  

Hansard Page:  CA

Senator Fierravanti-Wells asked:

Comments from the Department on Professor Woodruff’s evidence.

Professor Woodruff, Australian Council on Healthcare Standards, provided evidence to the Committee, with a focus on the issues of compliance and the issue of the potential duplication with respect to bodies already developing standards and accreditation in the healthcare field.

Answer:

Development of National Healthcare Standards

The Australian Council on Healthcare Standards (ACHS) supports the establishment of a national set of healthcare standards allowing national healthcare services to report against a single, consistent set of standards.  However, the ACHS considers that the adoption of a set of existing standards as the national standards is preferable. 

Health Ministers have endorsed the Commission’s proposed Model National Accreditation Scheme as the Australian Health Service Safety and Quality Accreditation Scheme.  The Scheme will optimise the benefit of a set of National Safety and Quality Health Service Standards being developed by the Commisison that will cover all areas of the health sector. 

In developing the Accreditation Scheme, the Commission undertook a stock take of existing standards and identified that there is no one set of nationally consistent safety and quality standards that is suitable to be applied across all health services.  Relevant elements of standards reviewed during the national stock take are incorporated into a national set of safety and quality standards.  The development of these national safety and quality standards involved extensive consultation with key stakeholders, including accreditation agencies such as the ACHS. 

In addition, the review of existing safety and quality standards revealed that the standards against which a service is assessed are determined by the sector in which the health service operates and the accrediting agency chosen by the health service.

Collaboration between the ACHS and the Commission

The ACHS is supportive of a permanent Commission but is seeking assurance that the Bill will not preclude ACHS’s collaboration with the Commission.

It is acknowledged that ACHS is a major provider of accreditation services and there is nothing in the Bill that will preclude the ACHS from continuing to provide these services.  The Commission will not deliver or develop another set of accreditation services that would overlap with the role of the ACHS or other accreditation agencies.  Furthermore, there is nothing in the Bill that would prevent the ACHS from continuing to provide accreditation services.

The ACHS is one of a number of organisations that develop various standards in specific areas of health care that have been extensively consulted in the ongoing processes of National Safety and Quality Health Service Standards development.  Their input continues to be of value.  This is supported by section 10(2) of the Bill, which requires that before formulating standards, guidelines or indicators, the Commission must consult broadly with a range of stakeholders.  The Commission has an established history of extensive consultation in the development of its guidelines and standards and it is expected that this would continue.

“Teacher and Policeman”

The ACHS noted that in the past the ACHS has had the dilemma of being both the teacher and the policeman.

ACHS has indicated that it believes that the roles of standards developer and accreditation services provider should be conducted by the same organisation.

As there are multiple accreditation providers in the market it would follow that there would be multiple standards set by those accreditation providers. 

While there are many accreditation standards, none of these meet the need for a single set of nationally consistent safety and quality standards that can operate across all hospital and non-hospital health services.  The development of one national set of standards will:

  • Reduce the variation and costs associated with multiple sets of standards;
  • Reduce limitations in the current sets of standards; and
  • Increase transparency and access to standards.

The separation of standards setting and standards assessment is a key requirement of a robust national accreditation scheme.  Health Ministers have endorsed the Commission’s proposed Model National Accreditation Scheme which builds on the strengths of the current accreditation system and establishes clearly defined and separate roles and responsibilities for:

  • The Commission;
  • Health Ministers;
  • Regulators;
  • Health services; and
  • Approved accrediting agencies such as the ACHS.

Under this model, the Commission will not be involved in the process of assessment or awarding certificates of accreditation.  The Commission will develop a set of nationally consistent safety and quality standards.  Accreditation agencies would use the standards in their accreditation and assessment processes. 

The Bill supports the clear separation of standard setting and standards assessment processes by providing the Commission with the standards setting function, while accrediting bodies will continue to undertake standards assessment. 

Quality Improvement

The ACHS considers that the met/not met basis as an indicator of further need does not provide sufficient means for quality improvement. 

The Model National Accreditation Scheme is designed to ensure that standards developed by the Commission are a key element of a quality improvement cycle for health services. In addition, identified risks and issues will be addressed at a national level to enable appropriate improvements to measurements, actions and data.  This method will focus on improving the safety and quality of patient outcomes. 

Meeting standards will achieve a range of purposes including

  • improving safety systems,
  • standardising processes;
  • implementing quality improvement practices; and
  • providing a quality basis on which funding can be made.

Achieving better outcomes

The ACHS are concerned that there is no evidence that the Commission will provide any better outcomes than what is already in place.

The Bill will enable the Commission to continue to develop national safety and quality standards, guidelines and indicators that address known safety and quality issues.  These are selected on the basis that:

  • they impact on a large number of patients;
  • there is a known gap between the current situation and best practice outcomes; and
  • improvement strategies exist that are evidence based and achievable.

The establishment of the Commission as an independent body will enable it to take a national perspective in systematically assessing and addressing gaps in safety and quality.

Inter-relationship between the Commission and IHPA and NPA.

The ACHS expressed concerns about the relationship between the Commission and the IHPA and NPA.

The National Health and Hospitals Network Agreement sets out the inter-relationships between the Australian Commission on Safety and Quality in Health Care, the Independent Hospital Pricing Authority and the National Performance Authority. In setting the state-specific and nationally efficient price to be used for Commonwealth funding, the Independent Hospital Pricing Authority will consider reasonable access to public hospital services, clinical safety and quality, efficiency and effectiveness and financial sustainability of the public hospital system (clause E3).

The National Performance Authority will produce Hospital Performance Reports and Healthy Communities Reports which will include selected clinical and safety measures drawn from the safety and quality standards developed by the Australian Commission on Safety and Quality in Health Care (clause D3).

We expect close and collaborative relationships between these three national governance bodies, that will, in partnership with existing agencies, ensure that the new funding arrangements are efficient yet clinically safe, and that safety and quality are reported on in a manner that ensures innovative practices are shared nationally and that poor performance can be identified early and remedied quickly.

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