Additional Comments by the Australian Greens
1.1
The Australian Greens strongly support vaccination as an evidence-based
approach to population health. Immunisation is one of the great success stories
of modern medicine and public health. Vaccinating against illness and disease
is the easiest way a GP can protect all ages of society from
vaccine-preventable infectious disease.
1.2
Vaccination against preventable disease is a proven method of reducing
the incidence of - and deaths from - diseases such as measles, tetanus,
diphtheria, and Haemophilus influenza type B. Australia's comprehensive
vaccination program means that the occurrence of vaccine-preventable diseases
(VPD) is now very rare.
1.3
This, coupled with substantially improved vaccination rates in the last
20 years means Australia has an excellent record of achievement in the
prevention of disease through immunisation.Vaccines
protect against a range of viral diseases, bacterial infections, insect-borne
and parasitic infections, and blood borne infections and Australia has
an excellent record of achievement in the prevention of disease through
immunisation.
1.4
The Bill requires that families are up to date with their immunisations in
order for parents or guardians to be eligible for Family Tax Benefit Part A
(FTB-A) supplement, Child Care Benefit (CCB) and Child Care Rebate (CCR).
1.5
In the 2015-16 Budget, the Government announced it would seek to
introduce 'No Jab, No Pay' rules that would remove immunisation exemption
categories for access to CCB, CCR and FTB-A supplement. As part of this
measure, the Government announced it would provide a $26m boost to the Immunise
Australia program 'to encourage doctors and immunisation providers to identify
and vaccinate children in their practice who are overdue'.
1.6
This Bill doesn't remove the right to make a conscientious decision
not to immunise. We all have that choice. What it does do is put a financial
cost to that decision. The disincentive of no longer
being eligible for Centrelink payments may result in some parents reassessing
their 'conscientious objection' or anti-vaccination stance.
1.7
There are some people, who for one reason or another aren't fully
vaccinated. The majority of these families are not conscientious objectors. In
fact of the roughly eight percent who don't have vaccines Professor Julie Leask
told the inquiry that at the moment, 1.52 per cent register as a conscientious
objection. In her opinion, the remaining 6.5 per cent could perhaps benefit
from other measures. The best way to tackle these people is through supporting
local health professionals and of course education.
1.8
Professor Leask told the inquiry that there needs to be strategies to tackle
those who at present don't have fully vaccinated children. She said these
should target people at the margins of vaccine acceptance—the hesitant parents,
the fence-sitters—with community-based interventions, provider-based
interventions, which we are working on at the moment, incentivising the
interaction between those parents and the healthcare system, which currently
happens by that obligation to get their forms signed by a provider, and looking
at the prenatal environment, where parents are making decisions about
vaccination, and raising awareness of the existence of adverse events clinics
in the major capital cities.
1.9
We note that the Government has made a provision for $26m in funding for
Immunise Australia that will include incentive payments to GPs who identify
under-vaccinated children and initiate a catch-up schedule, improving public
vaccination records and reminder systems and communications strategies to
promote the benefits of vaccinations. We welcome this recognition of the
importance of these reminder and recall strategies and look forward to seeing
evidence of how these measures have led to increasing the numbers of population
vaccinated, reducing barriers to access, improving the reliability of the
Immunisation Register and their capacity to target Aboriginal and Torres Strait
Islander communities.
1.10
The Bill provides that a child meets the immunisation requirements if a
GP has certified in writing that the immunisation of the child would be
medically contraindicated under the specifications set out in the Australian
Immunisation Handbook.
1.11
Likewise if the child has - in the opinion of the GP - contracted a
disease or diseases and, as a result, has developed a natural immunity.
1.12
Of course it is also critical that GPs are able to use their clinical
judgement in assessing children who are eligible for a medical exemption. As Dr
Kidd testified, medical exemptions are rare, but with the guidance provided by
the Immunisation Handbook, and their own clinical judgement, GPs are well
equipped to identify the small number of children who should not receive
vaccination.
Recommendation 1
1.13
The Senate recognises the critical importance that GPs remain able to
use their clinical judgement in assessing children who are eligible for medical
exemption.
1.14
We agree with the AMA's view that:
All children have the right to be protected from vaccine
preventable diseases. This includes infants who are too young to be immunised
as well as those infants and children who are medically unable to receive
immunisations. Immunising as many infants and children as possible affords
these vulnerable infants and children the protection they deserve.
1.15
Under the current system, in order to register as a vaccine refuser (and
still receive government payments), parents must discuss the risks of their
decision with a health professional. Health professionals report that
occasionally this discussion ends in the parent changing their mind and consenting
to receipt of at least some recommended vaccines. We do have some concerns that
removing the incentive for such an encounter deprives health professionals with
the opportunity to encourage parents to reconsider their decision.
1.16
We heard in the inquiry evidence from the AMA's Dr Richard Kidd who said
the rates of severe reaction - depending upon what severity you are talking
about, are somewhere between one in a million and one in 100,000. We were told
that yes, there are minor reactions that are fairly common, like some redness
and pain at the injection site, but, in terms of severe anaphylactic reactions
or other severe reactions, they are very, very rare.
1.17
We are pleased to see that the AMA have provided more detail about how
the Australian Immunisation Handbook (currently 10th Edition, updated in June
2015) provides clinicians with guidance about exemptions to immunisation. We
note that the Handbook provides information on a range of contraindications and
precautions that need to be taken with certain groups such as those who are at
risk of anaphylaxis, those who are immunocompromised, those who are receiving
immunoglobulin or other blood products etc. We note that further material on at
risk groups or possible exemptions is also provided under each listed
individual disease name.
1.18
We are, however, concerned about the accuracy and the quality of the
data upon which the requirements for immunisation are enforced. The policy has
used the Australian Childhood Immunisation Register, (ACIR), data as the prime
data source. We acknowledge concerns expressed by Public Health Association
Australia around flaws in this current system that were developed in the 1990s.
We note that in relation to the credibility of the ACIR, as part of the ANAO's
performance audit of the ACIR in 2014-15 the ANAO has reported that:
Overall Human Service’s administration of the ACIR has been
generally effective. The department has generally met or exceeded performance
targets. These targets include measurements for data accuracy.
1.19
In evidence submitted on notice the Department of Human Services wrote
that:
In accordance with the phased expansion of the ACIR into a
Whole of Life Australian Immunisation Register (AIR), a range of improvements
will be implemented to the Register’s functions and operations. This includes
new functionality to enable providers to correct errors online through the AIR
secure site, such as correction of an incorrect dose number or incorrect
vaccine recorded. This will begin to be implemented in September 2017.
1.20
This is concerning. The Australian Greens can't understand why we would
have a scheme that is reliant upon quality data to see who is and isn’t fully
vaccinated if the systems aren’t going to be fully ready until 2017.
Recommendation 2
1.21
The Senate agrees to delay implementation of the legislation until 1
January 2018 so that data systems are ready to provide confidence that
immunisation data is accurate and providers are resourced to undertake
extensive history checking and be able to correct errors online through the AIR
secure site, such as correction of an incorrect dose number or incorrect
vaccine recorded.
1.22
The Public Health Association of Australia (PHAA) told the committee
that the Government should seek to address the structural and practical
barriers to vaccination that exist, including socioeconomic reasons that
children are not vaccinated. We would like to see evidence from the $26m
investment in addressing this issue that these structural and practical
barriers are being addressed. We note that the Royal Australasian College of
Physicians (RACP) suggested home visiting programs would be one way of
overcoming practical barriers to vaccination.
Recommendation 3
1.23
The Senate recognises the need for supportive systems to help reduce
barriers to access, improve the reliability of the Immunisation Register and
further strategies that are specific to Aboriginal and Torres Strait Islander
communities. That in doing so it accepts that reminder and recall strategies
should include a national immunisation reminder system, catch-up campaigns,
local initiatives to improve coverage, home visiting programs and actions to
address access barriers to health care.
1.24
Finally, evidence provided to the committee indicated that there is
significant confusion as to which vaccines are mandatory for eligibility. There
appears to be different information provided on each of DSS, the Department of
Human Services (DHS) and the Department of Health (DoH) web sites. The
Australians Greens are concerned that notes on the DHS website states that
'most of the immunisations on the National Immunisation Program Schedule are
linked to family assistance payments'. We would like to seek clarification as
to what is and what isn’t mandatory for eligibility.
Recommendation 4
1.25
The Senate calls on the Australian Government to clarify which vaccines
are mandatory for eligibility for being up to date with the National
Immunisation Program Schedule and make this clear on all their relevant
websites and publicly available material.
Senator Richard Di Natale
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