- That the impact of the proposed
changes to the Australian Government Health Technology Assessment (HTA)
system approved by the Australian Government be evaluated within three
years of the Government’s response to this review.
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- That the rigorous consideration
of evidence be consistently applied across all Australian Government HTA
processes to ensure sustainability of the Australian Government’s health
financing arrangements.
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- That the Australian Government
HTA system be guided by the vision, goal, objectives and principles
articulated in the Review of Health Technology Assessment in
Australia (HTA Review) Report.
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- That DoHA establish a website for
Australian Government HTA processes by July 2010 which:
a) describes the
roles, responsibilities and relationships between the different HTA
processes;
b) facilitates
access to all related Australian Government HTA websites to ensure that
policy and guidance for all Australian Government HTA processes are easily
accessible; and
c) regularly
publishes reports on agreed performance and activity data to clearly
demonstrate the performance of the system and focus attention on areas
requiring performance improvement.
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- That the procedural fairness and
consistency of Australian Government HTA processes be improved by 2011,
by:
a) establishing
independent review mechanisms and opportunities for re-submissions in a
consistent manner for Australian Government HTA processes (where they are
currently not available);
b) updating
operating procedures for administering Australian Government HTA processes,
including publishing specific milestones and timeframe targets for each
individual HTA process;
c) improving
public disclosure of Australian Government HTA processes, including advisory
committee membership, performance and activity data, and assessment and
appraisal outcomes (including the rationale for those outcomes);
d) establishing
and publicising specified communication points with applicants throughout
each process, including providing opportunities for pre-lodgement meetings;
and
e) adopting and
implementing transparent and consistent policies and procedures for the
management of conflict of interest for all external parties involved in Australian
Government HTA processes.
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- That in order to improve the
efficiency of HTA, DoHA establish a single entry point (SEP) by July
2010 to receive applications for subsidy under the Medicare Benefits
Schedule (MBS), Pharmaceutical Benefits Schedule (PBS) and Prostheses
List. The role of the SEP will be to:
a) provide a
single point of contact to help applicants throughout the HTA process;
b) determine the
most appropriate advisory committee(s) to appraise the technology;
c) identify the
most appropriate assessment pathway for an application, including maintaining
and reinforcing current processes where these are the most efficient for the
technologies submitted to a particular process;
d) conduct an
initial risk and impact assessment and determine the most appropriate
methodology to be used in assessing the technology;
e) ensure the
timely assessment and appraisal of co-dependent and hybrid technologies, or
technologies being assessed concurrently for both public and private
reimbursement and coordinate the provision of comprehensive advice to the
Minister for Health and Ageing (the Minister);
f) achieve
synergies through sharing and sustaining HTA expertise across the advisory
committee secretariats; and
g) develop and
report on the achievement of performance targets for HTA reimbursement.
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- That applicants have the option
of applying to different HTA processes concurrently. Finalisation of
each HTA process may be subject to the completion of a critical
antecedent process (such as inclusion on the Australian Register of
Therapeutic Goods (ARTG) prior to MBS or Prostheses List listing). This
will require procedures to be put in place by July 2010 to allow the
efficient flow of information between HTA processes (including from the
TGA to other HTA agencies, subject to confidentiality constraints).
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- That the Therapeutic Goods
Administration (TGA), in the context of international harmonisation:
a) continue its
role as the independent national regulator solely responsible for assessing
the safety, quality and efficacy of therapeutic goods for entry on The
Australian Register of Therapeutic Goods (ARTG) and marketing in Australia;
b) respond to the
issues raised in consultations regarding third party conformity assessment by
July 2010, with a view to implementing changes agreed by government by 2011;
c) increase the
rigour of regulatory assessment of higher risk medical devices by 2011, to
ensure an appropriate level of evidential review is undertaken to ensure
safety, quality and efficacy of these devices prior to entry on the ARTG and
to provide a sound evidence basis for Australian Government HTA processes;
and
d) develop
protocols by July 2010 for sharing information with other HTA agencies
through the SEP (subject to commercial-in-confidence constraints) on the
outcomes of its safety assessments.
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- That by July 2010, MSAC
strengthen and streamline its operations and improve the flexibility of
its regulatory processes by:
a) providing
advice to the Minister based on a critique of an applicant’s comparative
clinical and economic evaluations, as an alternative to the current process
and in the context of agreeing specific timeframes for assessment with the
applicant;
b) ensuring that
data collection requirements supporting a recommendation for interim funding
for a professional service for listing on the MBS are sufficiently rigorous
and reliable to provide a sound basis for a final decision on funding;
c) ensuring that
its advice to the Minister addresses all aspects of the proposed change to
the MBS, especially in regard to the proposed MBS item descriptor and fee;
and
d) streamlining
current processes for accessing expert advice to improve timeliness of
assessment processes and set a target of all advisory panels being
established within six weeks of accepting an application.
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- That in order to reduce
regulatory costs:
a) the terms of
reference for the Prostheses and Devices Committee (PDC) and its
subcommittees be revised by July 2010 so that it is clear that its
assessments of prostheses only consider clinical effectiveness (including
comparative cost and comparative safety); and
b) channels of
communication between the TGA and PDC should be formalised to ensure that any
concerns the PDC encounters regarding the intrinsic safety of prostheses are
immediately referred to the TGA and dealt with appropriately.
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- That the PDC be restructured by
July 2010 to ensure that its membership is balanced and:
a) includes
individuals with expertise in current clinical practice, health policy and
health economics;
b) includes
representation from health consumers, health service providers, and the
health insurance and health technology industries; and
c) has an
independent chair.
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- That the arrangements for the
Prostheses List be changed by 2011, with appropriate consultation, to:
a) accept
applications on a continuous basis, but still make the Prostheses List every
six months;
b) establish and
maintain groups of products with similar clinical effectiveness;
c) abolish the
negotiation of benefits for individual listed products, and instead establish
and maintain a single (benchmark) benefit for the products included in each
group, with sponsors being required to accept this benefit in order to be
listed;
d) abolish the
negotiation, setting or publication of maximum benefits, to eliminate the
potential for gap payments for patients who have Private Health Insurance
(PHI); and
e) permit the
establishment of new product groups (or sub-groups) where a sponsor
establishes clear superiority of their product compared to those in an
existing group.
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- That, in order to improve the
contribution of post-market surveillance to patient safety, the TGA take
steps to increase the rate of reporting of adverse events, including by
health service providers and consumers.
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- That, in order to improve the
contribution of post-market surveillance to the sustainability of the
health system and the longer-term regulatory efficiency of HTA
processes, DoHA explore options for consideration by government in 2011
to facilitate the expansion and use of post-market surveillance data to
inform safety, effectiveness and reimbursement decisions for devices and
procedures.
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- That registers for high-risk
implantable medical devices and/or procedures be established, with:
a) key
stakeholders such as clinicians, health consumers and industry to participate
in governance of and contribution to registries;
b) establishment
of mechanisms to apply data from the register to future HTA;
c) the
feasibility, benefits and methodologies for data linkage to be explored in a
pilot project in regard to a particular device identified by the high-risk
implantable devices register;
d) consideration
of how developments in e-health and data linkage could improve the efficiency
of the post-market surveillance of medical technology more generally; and
e) the
development of criteria, the identification of opportunities and the
consideration of strategies for improvements in public investment in medical
devices.
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- That the Australian Health
Ministers’ Conference be asked to consider the need for a national
approach to HTA processes, including processes required to evaluate
blood and blood products.
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