Chapter 4 Adult Dental Services National Partnership Agreement framework
4.1
This chapter considers structural aspects of the Adult Dental Services
National Partnership Agreement framework. In considering this the Committee has
identified a number of key principles which it believes should form the
foundation for negotiations between the Commonwealth, and states and
territories. The chapter also examines the broader policy context and the
importance of a coordinated and strategic approach to public dental health
policy and service delivery.
Allocation of funding
4.2
The Commonwealth Government has committed $1.3 billion to state and
territory governments to support additional dental services for adults. This
funding will be provided through a National Partnership Agreement for adult
dental services (the Adult Dental Services NPA). As noted earlier in the
report, the Intergovernmental Agreement on Federal Financial Relations sets out
a framework ‘which will provide a robust foundation for collaboration on policy
development and service delivery and facilitate the implementation of economic
and social reforms in areas of national importance’.[1]
The Adult Dental Services NPA, which will provide funds to the states and
territories to provide public dental services based on mutually agreed outcomes,
will sit under this framework.
4.3
Although the total funding for the Adult Dental Services NPA has been
announced, the allocation of funding to individual states and territories is
yet to be determined. It is anticipated that the allocation of funds will be determined
on the basis of a formula that takes into account a number of factors.
4.4
An example of how funding allocation is determined is provided by the current
Dental Waiting List NPA. The Dental Waiting List NPA provides Commonwealth
Government funding to the states and territories based on the number of health
care and pensioner concession card holders in each jurisdiction. In essence, this
provides states and territories with a share of funding based on the population
of people eligible for public dental services in each jurisdiction (concession
card holders). An additional loading is provided to Tasmania, the ACT and the
NT to account for their smaller populations.[2]
4.5
While basing funding on the concession card holder population is comparatively
straightforward, evidence suggests that the cost of delivering services varies
depending on location (based on the Australian Statistical Geography Standard
(ASGS)), Indigenous status and individual needs.[3]
4.6
For example, the submission from the National Oral Health Steering Group
observes:
The cost and complexity of provision of care in rural and
remote locations is far greater than in metropolitan areas. This should be
reflected in any funding model.[4]
4.7
The Australian Healthcare and Hospitals Association (AHHA) have also
advocated for the NPA to acknowledge the additional costs of providing
treatment to patients in rural and remote locations and for a proportion of
funding to be quarantined for services to Aboriginal and Torres Strait Islander
people.[5] The National Aboriginal
Community Controlled Health Organisation (NACCHO) estimates that a weighting of
30 per cent for Indigenous Australians is necessary to appropriately provide
services to this group.[6]
Committee comment
4.8
Allocation of funding based on the total eligible population numbers in
each jurisdiction ensures that the Commonwealth Government is providing equal funding
for each eligible individual. While being easy to manage administratively this may
not represent the fairest way to allocate funds. Providing funding to states
and territories in this way may unintentionally impose restrictions on
providing services, as it does not take into account variations in state and
territory priority groups that may require funding above average levels to
receive appropriate dental treatment.
4.9
The Committee agrees that there is a need for further consideration of
the formula used to allocate the proportion of funding to the states and
territories under the Adult Dental Services NPA. While not necessarily an
exhaustive list of factors that might be taken into account, the funding formula
could include loadings to reflect differences in the size and distribution of priority
population groups, including:
n concession card
holder population;
n geographic spread of
the population;
n the Indigenous
population; and
n other priority
population groups such as people with disabilities, people with chronic
diseases, people on low incomes or people who are homeless.
4.10
As with the Dental Waiting List NPA, an additional loading for states
and territories with smaller populations may also be appropriate.
Recommendation 6 |
|
The Australian Government, in negotiation with state and
territory governments, develop a formula for the allocation of funding to
state and territory governments under the Adult Dental Services National
Partnership Agreement based on the size and distribution of priority population
groups, including:
n concession
card holder population;
n geographic
spread of the population;
n the
Indigenous population; and
n other
priority population groups such as people with disabilities, people with
chronic diseases, people on low incomes or people who are homeless.
|
Maintenance of effort
4.11
A key principle for the Adult Dental Services NPA is that it provides
funding to state and territory governments to support additional adult dental
services. The importance of maintaining current services in the lead up to
implementing the Adult Dental Services NPA was emphasised by the Public Health
Association of Australia (PHAA) which submitted:
[The NPA] must require states and territories to maintain
their current effort or the potential gains will be minimised by cost shifting.[7]
4.12
However, concern was raised that state and territory governments were
scaling back efforts to support public dental services in anticipation of
receiving additional Commonwealth support through the NPA. For example, the NSW
Oral Health Alliance stated:
Over the past five years, NSW governments' anticipation of
Commonwealth oral health reform has in effect frozen state-level investment in
public dental services.[8]
4.13
While maintenance of funding provides a simple measure to determine
ongoing state and territory financial commitment to dental health services, it
does not necessarily provide the most meaningful measure. This was explained
further in the following testimony by a representative of the Department of
Health and Ageing (DoHA), who observed:
If [state and territory governments] are able to maintain
their baseline activity and do the additional activity we want while spending
less of their own money, then that is an efficiency saving, and that is
probably a good thing.[9]
4.14
Adding to consideration of this issue, representatives of DoHA advised
that Clause 5 of the Dental Waiting List NPA specifies that in order to achieve
agreed outcomes states and territories must maintain existing efforts:[10]
... for this agreement to have the desired impact on public
dental services it is essential that the States’ clinical activity related to
public dental services, child, adult and special needs patients, is maintained
and not withdrawn and redirected away from dental services, and that
investments under this agreement are additional to such effort.[11]
4.15
DoHA explained that ‘effort’ under the Dental Waiting List NPA is
measured in terms of notional units of clinical activity known as Dental
Weighted Activity Units (DWAUs). Assessment of DWAUs supplied to the
Commonwealth prior to state and territory governments signing the NPA provides
a baseline measure. Additional effort is assessed against this baseline.
4.16
Application of this assessment system to the Dental Waiting List NPA was
described by DoHA in more detail as follows:
The [Dental Waiting List] NPA is framed to allow an initial
up-front payment of $69.2 million to assist the states and territories in
building capacity for dental infrastructure and workforce. From June 2013 until
2015, the remaining funds of $274.8 million will be tied to performance targets
measured against the 2011-12 baseline. States will need to achieve at least 65%
of their target to receive a proportion of the total funds available for that
period.
All targets will be expressed in terms of Dental Weighted
Activity Units (DWAU), calculated using the Australian Dental Association three
digit item codes, and a weighting included as a Schedule to the Agreement. The
performance indicators will measure the clinical activity of the states and
territories to ensure that they use the Commonwealth funds to provide services
beyond their current levels.[12]
Committee comment
4.17
Funding provided under the Adult Dental Services NPA is intended to
supplement existing state and territory effort. In providing this additional
funding the aim is to increase access to public dental services for those who
need it most.
4.18
To ensure that funding provided through the Adult Dental Services NPA is
used to provide additional dental services the Committee believes that a
baseline assessment of current effort is essential. Establishing agreed
benchmarks for expansion of dental services and processes for monitoring
progress thereafter is clearly critical to assessing whether additional
services are in fact being provided.
4.19
The Committee believes that the Adult Dental Services NPA should include
a ‘maintenance of effort’ clause, similar to the clause included in the Dental
Waiting List NPA, that measures increased effort in terms of higher levels of
dental activity and improved clinical outcomes against an established baseline.
Recommendation 7 |
|
The Australian Government include a ‘maintenance of effort’
clause in the Adult Dental Services National Partnership Agreement, similar
to that included in the Dental Waiting List National Partnership Agreement.
This clause should specify that state and territory governments must maintain
public dental clinical activity for adults, so that additional funding
provided under the Adult Dental Services National Partnership Agreement is
used to increase current effort.
|
4.20
While acknowledging concerns expressed that state and territory
governments might reduce their own expenditure on dental services, the
Committee notes that equating effort to level of expenditure only will provide
an overly simplistic representation of the public dental system. A more
meaningful assessment of effort should take into account levels of service
provision and clinical outcomes. As long as agreed service delivery and
clinical activity benchmarks are being met, expenditure decreases may reflect
efficiencies in service delivery.
4.21
Accountability and reporting requirements are considered in more detail
below. Further consideration will be given to DWAUs and how these units might
be used to assess changes to the levels of clinical activity and types of
dental services provided by states and territories.
Accountability and reporting
4.22
State and territory governments, and those responsible for delivery of
adult dental services, have indicated that the NPA should not include ‘onerous
and difficult reporting’[13] and that there ‘be a
reduction in administrative burden’.[14] In relation to this, Ms
Prue Power, Chief Executive, AHHA, stated:
It is critical that the data collection and reporting of
activity levels required by the Commonwealth are not excessive. That is a key
principle of the National Health Reform Agreement—to reduce the burdens of
administration.[15]
4.23
However, given the nature of the NPA framework and the financial
requirements related to it, agreed benchmarks and key performance indicators (KPIs)
are needed to measure progress and outcomes.
4.24
For example, performance and monitoring under the Dental Waiting List
NPA requires states and territories to report on the following KPIs:
n Number of patients
receiving dental services;
n Number of patients on
dental waiting lists;
n Waiting time for
patients on public dental waiting lists;
n Number of children
and adults receiving specialist or general anaesthetic services;
n Number of dental
occasions of service provided; and
n The number of
additional Dental Weighted Activity Units (DWAUs).[16]
4.25
Clearly, specific benchmarks and KPIs for the Adult Dental Services NPA
will need to be developed and negotiated. However, evidence to this inquiry has
questioned the validity of one of the commonly used measures of dental need; that
is, the number of patients on dental waiting lists.[17]
4.26
For example, the submission from Dental Health Services Victoria states:
Public dental waiting lists in Victoria do not reflect the
true or potential demand for care by the eligible population. Across Australia,
waiting lists have been used as demand management tools and have assisted to
suppress the true need for dental care of the eligible population.[18]
4.27
As explained further in the submission made by the NSW Ministry of
Health:
Waiting lists are poor measures of unmet demand for dental
services as they do not include adults who for various reasons are not seeking
access to dental care even when they need it. In NSW this includes adults with
poor dental health, who are not eligible for public dental services and cannot
afford private dental care.[19]
4.28
Additionally, the Loddon Mallee Region Oral Health Network states:
The public dental waiting lists potentially do not account
for those people who [are] unaware of the importance of dental care or their
eligibility for public dental services or those that experience access barriers
such as lack of public and private transport options, mobility issues, cultural
reasons etc.[20]
4.29
Services for Rural and Remote Allied Health (SARRAH) provides the
following perspective on dental waiting lists:
SARRAH believes it is time that political parties of all
persuasions realise that waiting lists are a political measure, not a measure
of access to dental care. Waiting list times and lengths can be manipulable to
suit political ends. For example, methods of creating a short waiting list may
include instructing dental practitioners:
n not to do full oral
examinations and provide a very limited range of dental services;
n not to inform
patients that there is a waiting list;
n to inform patients
who become aware of a waiting list that it is many years long;
n to audit the waiting
list by contacting patients and removing those who do not respond within a
short period of time from the list; and
n to redefine the waiting
list into a number of lists such as placing those who have had treatment in the
last year on a recall list, not a waiting list.[21]
4.30
An additional concern in relation to the use of waiting lists as a
measure of demand is that those treated in the public dental system includes
those individuals in need of emergency treatment.[22]
These patients are generally triaged and provided an appointment in a short
space of time.[23] These patients usually
do not appear on waiting lists. Furthermore, triaging and responding to
emergency cases also has effects on waiting times for those already on public
dental waiting lists.[24]
4.31
However, and as illustrated by the Dental Waiting List NPA, it is usual
practice to have a range of KPIs, rather than a single measure to assess
outcomes.
4.32
The submission from Queensland’s Minister for Health, Hon Lawrence
Springborg MP, advocates for:
… performance benchmarks based on improvements in service
outcomes, not just increases in service activity for example, questioning if
waiting times for routine dental care are reducing, or if access to emergency
care has improved.[25]
4.33
The Consumer Health Forum (CHF) has proposed that a range of KPIs be
developed for the Adult Dental Services NPA under the following items:
n community-wide oral
health promotion and community education;
n planning for and
provision of dental services for high-risk consumers according to need,
including provision of general services, emergency care and more complex
treatments;
n dental health service
infrastructure and programs for hard to reach populations;
n water fluoridation,
particularly in centres with populations of 1000 or above;
n the elimination of
co-payments for pensioner and Health Care Card holders; and
n reducing the number
of emergency presentations by pensioner and health care card holders and
increasing the percentage of card holders receiving regular check-ups and
preventive care.[26]
4.34
Whatever the agreed benchmarks and KPIs, collection of dental data and
statistics remains a fundamental challenge. As noted by DoHA:
There are currently gaps in existing dental and oral health
data sources. Specifically, there is a lack of data about adults accessing
publicly-funded dental services and visits to private dental services.[27]
4.35
To address some of the concerns associated with dental waiting list data
specifically, DoHA noted that the Australian Institute of Health and Welfare
(AIHW) has developed the Public Dental Waiting Times
National Minimum Data Set (PDWT NMDS). The PDWT NMDS will ‘collect
information on waiting times for people placed on public dental service waiting
lists in all states and territories, measuring the time between placement on
the list and the date an offer of care is made, or care received.’ The PDWT
NMDS will be implemented from 1 July 2013.[28]
4.36
Also, as noted earlier in this chapter, the Dental Waiting List NPA
includes a KPI which measures progress toward clinical activity benchmarks in
terms of DWAUs. Evidence suggests that the use of DWAUs as a measure to more
accurately assess clinical activity and outcomes is subject to ongoing
development:
… we are still looking at the data set which is going to best
inform the Commonwealth, as essentially funder or purchaser of services under
the expanded package. This is the first time we have actually engaged with
states and territories on this notional unit called DWAU. It would be fair to
say that we are all learning how to use it and how it can be best applied to a
monitoring regime. … That is something we are being very open about in our
discussions with states and territories—that we are feeling our way into this
space and look to do so collaboratively.[29]
4.37
In order to maximise reporting efficiency, it was proposed that
consideration be given to the use of existing data collection and reporting
systems.[30]
Committee comment
4.38
To support the principle of accountability the Commonwealth Government
must have appropriate oversight of the NPA and the services delivered under it.
The Committee understands that this is achieved by placing reporting
requirements on jurisdictions to monitor progress towards agreed outcomes. At
the same time, the Committee is also aware of the need to ensure that reporting
is not unnecessarily onerous.
4.39
With regard to the Dental Waiting List NPA, the Committee notes that the
current KPIs are not solely based on public dental waiting list numbers. Given the
concerns expressed in relation to limitations of this KPI as a measure of unmet
demand for services, inclusion of a wider suite of KPIs would seem justified. The
Committee is optimistic that work being undertaken by the AIHW to establish a
PDWT NMDS will alleviate these concerns.
4.40
As the Dental Waiting List NPA and the Adult Dental Services NPA will
overlap by 12 months, it will be important to ensure that any reporting
requirements over this period are managed appropriately. In particular, consideration
should be given to making use of dental data and statistics already collected by
states and territories to streamline reporting for the two NPAs, maximising
administrative efficiency and minimising reporting burden.
4.41
Establishing benchmarks and KPIs for the Adult Dental Services NPA will
need to be negotiated between the Commonwealth and the states and territories. The
Committee also recognises that to be effective, KPIs must be clearly defined,
measurable and based on outcomes that are achievable.
4.42
While the KPIs used for the Dental Waiting List NPA could provide a starting
point for negotiations, development of an altered or expanded range of KPIs that
address the unique objectives of the Adult Dental Services NPA will be
essential. In addition to assessing increases in clinical activity over
baselines, the Committee would like to see the inclusion of KPIs that have the capacity
to monitor agreed outcomes, including shifts in the type of service being
delivered (e.g. from emergency to preventive) and delivery of services to
specific population groups.
4.43
To monitor shifts in the type of services delivered or targeting of services
it may be possible to adapt DWAUs by applying weighting to agreed priority
outcomes. The Committee notes that work on the use of DWAUs as a tool to
monitor clinical activity is still in progress. The Committee also supports the
collaborative approach that has been adopted to progress this.
Recommendation 8 |
|
The Australian Government develop
a performance and reporting framework for the Adult Dental Services National
Partnership Agreement that will accurately and objectively assess progress
towards achieving agreed benchmarks for service delivery and clinical
outcomes.
In consultation with state and
territory governments, and with private providers of dental services, consideration
should be given to a range of key performance indicators that will allow for
monitoring of:
n changes
to the levels of clinical activity;
n preventive
services as a proportion of all services delivered; and
n targeting
of services to specific population groups.
In developing the performance
and reporting framework, consideration must be given to making use of
existing data collection and reporting systems to maximise administrative
efficiency and minimise reporting burden.
|
Consistency across jurisdictions
4.44
A number of submissions have observed that the type of dental services, eligibility
requirements for access, and co-payments for services differ between states and
territories. As noted by SARRAH:
There is also limited coordination of dental services between
State and Territory Governments. The State and Territory Governments have
different rules and systems for supplying dental care. A meeting between these
government oral health administrators is needed to develop a consistent set of
rules for supplying public dental care across Australia.[31]
4.45
The submission from the Australian Dental Association (ADA) observes:
There is no consistency in the eligibility criteria for those
entitled to treatment in the public sectors. Some offer dental care to all
children, some only to a subset of children. All state and territories provide
dental care to those that hold a form of concession card. In some
states/territories, patients are required to make a co-payment for services
while in others there is no additional charge to the patient.[32]
4.46
Also noting that co-payment practices vary considerably between states
and territories, a representative of DoHA provided the following testimony:
Queensland do not have any co-payments—that might be why they
have the longest waiting lists; New South Wales have co-payments for some
specialist dental services and some dentures; Victoria has a range from $25 for
emergency, $100 for general course of care, up to $120 for dentures; Tasmania
hits everybody for $25 up to maximum of $366 for course of care … [t]he
Northern Territory does not have any; WA has a sliding scale; ACT has an annual
maximum …[33]
4.47
Differences between states and territories in relation to scope of
practice limitations that apply particularly to dental and oral therapists were
also raised. Inconsistency in scope of practice restrictions means workforce
limitations are more significant in some jurisdictions than in others. As
submitted by the Australian Dental and Oral Health Therapists’ Association (ADOHTA):
Currently, limits are placed on dental and oral health
therapists based upon the level of tertiary training in the state they work in.
In Victoria a dental therapist is allowed to treat patients up to the age of
25, whereas dental and oral health therapists in Queensland are restricted to
working on patients from between four and 18 years of age.[34]
4.48
While there was general support for greater cross-jurisdictional
consistency, the context of the Dental Reform Package as part of the Federal
Financial Relations Framework provides flexibility for state and territory
governments to determine priorities for services and service delivery. In
relation to this, DoHA provides the following advice:
The [adult dental services] NPA’s deliverables will be
customised for each state and territory depending on the demonstrated local
needs and progress under the 2012-13 Dental Waiting List NPA.[35]
4.49
Similarly the submission from ACT Health emphasises that in order to
comply with the principles of the Intergovernmental Agreement on Federal
Financial Relations, the Commonwealth Government should focus more on agreed
outcomes and be less prescriptive in relation to service delivery, stating:
The ACT Health Directorate expects the Commonwealth uphold
its commitment to move away from prescriptions on service delivery in the form
of financial or other input controls, which inhibit state service delivery and
priority setting, and instead, focus on the achievement of mutually agreed
outcomes, providing the states and territories with increased flexibility in
the way services are delivered.[36]
Committee comment
4.50
While acknowledging that variations to the type of dental services, eligibility
requirements for access, and co-payments between jurisdictions exist, the
Committee believes that the most important consideration is to increase
availability and access to public dental services for those who need it most. Although
national consistency would ensure that all Australians have access to the same public
dental services wherever they are and whatever their age, the Adult Dental
Services NPA is being developed in a framework which aims to provide states and
territories with maximum flexibility for delivering services.
4.51
In the context of this framework, the Committee understands that there
is some scope, albeit rather limited, for the Adult Dental Services NPA to
promote a degree of national consistency for adult dental services. For
example, this may be achieved through an NPA which includes benchmarks and KPIs
to promote the delivery of particular service types or prioritises access for particular
population groups. However, the benefits of national consistency need to be
offset against the basic principle that supports the rights and
responsibilities for states and territories to prioritise and shape services to
meet particular and localised needs.
Sustainable funding
4.52
Although the Dental Waiting List NPA and the Adult Dental Services NPA
provide substantial additional funding to extend state and territory public
dental services, concerns have been raised about the sustainability of the
funding. This is particularly significant given that NPAs have defined
end-dates, while the dental and oral health needs of the population will be
ongoing.[37]
4.53
With regard to this issue, the NSW Ministry for Health observed:
… a long term sustainable funding mechanism needs to be put
in place to ensure that those who cannot afford private health insurance have
access to basic preventive and treatment dental services.
Unfortunately National Partnership Agreements may not provide
a secure funding mechanism. The current arrangement is time limited and like
the Commonwealth Chronic Disease Dental Scheme (CDDS), creates a situation
where service activity is increased with no certainty of that capacity being
able to be sustained.[38]
4.54
Similarly, the Tasmanian Department of Health and Human Services
emphasised the importance of sustained funding, explaining:
In terms of structure of future programs, states and
territories always have problems with national partnership agreements basically
because they are there for limited terms, probably three years, and especially
where your investment is going to be in recurrent expenditure. If you are going
to employ more dental staff, what happens at the end of three years if the
funding ceases? … National partnership agreement: while we commend the
investment, in the longer term it actually needs to move into something like a
national agreement so that there is ongoing commitment of funding.[39]
4.55
The ADA (NSW Branch) expressed concern about longer-term funding, saying:
Furthermore, the funding that has been announced under the
National Partnership Agreement for adult public dental services is only
committed up to the end of 2017-18. As noted, there is already a level of
uncertainty around this funding given the impending election later this year.
This uncertainty makes it very difficult for state and territory public dental
services to efficiently and effectively plan dental programs around this
funding, particularly in the medium to long term.[40]
4.56
Also acknowledging the time and expense involved in establishing public
dental services, the submission from Mr Lawrence Springborg MP states:
… an NPA that does not provide certainty of funding, both
within and beyond the NPA period, risks the development of short-term, temporary
'band-aid' strategies, that ultimately do not address the oral health needs of
adults requiring public dental services in Queensland.[41]
4.57
To address this concern Mr Springborg MP suggests:
The [Adult Dental Services] NPA should have provisions for
State and Federal Governments, and private dental providers, to discuss ongoing
funding for dental services at least 12 months prior to the expiry of the NPA.[42]
Committee Comment
4.58
The issue of funding sustainability is clearly an important one and is
likely to affect all states and territories, particularly when undertaking
infrastructure or workforce planning. The Committee recognises that in order to
build on improvements in dental and oral health arising from the Dental Waiting
List NPA and the Adult Dental Services NPA, an approach that supports a commitment
to ongoing funding is necessary.
4.59
To alleviate concerns about sustained funding, and assist state and
territory governments and private sector partners to make longer-term planning
decisions, the Committee recommends the inclusion of a provision in the Adult
Dental Services NPA which requires negotiations about continued funding for
adult dental services to commence at least 12 months prior to the NPA’s
expiration.
Recommendation 9 |
|
The Australian Government include provision in the Adult
Dental Services National Partnership Agreement that requires all signatories
to commence negotiations for a new National Partnership Agreement (or
alternative funding model) at least 12 months prior to its expiration.
|
4.60
The Committee comments further on the need for sustainability in the
context of a strategic approach to dental and oral health policy.
A coordinated approach
4.61
As outlined in Chapter 2, responsibility for dental services is shared
by Commonwealth, state and territory governments, and the private sector.
Funding for dental services is also shared, with the majority of services being
paid for by individuals with or without assistance from private health
insurance. However, evidence to the inquiry suggests that coordination is a
significant area of weakness.
4.62
Several submissions indicate that coordination between the two tiers of
government in relation to dental policy and service delivery is inadequate.
Some have noted in particular that a lack of clarity around roles and
responsibilities has resulted in ‘buck passing’ between the Commonwealth, and
states and territories. Furthermore, evidence indicates that inadequate
coordination extends to government engagement with private dental services.[43]
4.63
As noted in the submission from the Tasmanian Department of Health and
Human Services:
Dental services funded or provided by state/territory
governments, the Australian Government and by the private sector tend to
operate independently from each other with no linkages to an overall national
dental care strategy. Given that fund holders for dental services are both
tiers of government, individuals through out-of-pocket expenses and private
health insurance companies, it is not surprising that there is very little
coordination of services. Improved coordination of dental services may lead to
more cost effective dental programs and better targeting of government funded
services to people who would most benefit from dental treatment.[44]
4.64
The NSW Oral Health Alliance observed:
[t]he Alliance is concerned about on-going fragmented policy
and funding responsibility for dental services between the two tiers of
government, and the scope and coverage of services funded under the package.
The Alliance is concerned about the lack of a clear,
comprehensive national framework for oral health policy and funding. The
current shared approach between the states and the Commonwealth is piecemeal
and fragmented. Blurred responsibilities between the two tiers of government in
the absence of a comprehensive framework leave the system exposed to gaming and
perverse incentives.[45]
4.65
The AHHA also expressed concern about inefficiencies and the potential
for duplication, observing:
After many years of minimal involvement in the funding of
dental programs by the Australian Government there are now a myriad of programs
being administered by a range of Departments and Agencies. There is a
significant risk of inefficiency, duplication and waste as a result of an
uncoordinated approach to the planning and implementation of new initiatives
and integration with existing programs.
4.66
Some contributors to the inquiry have recommended appointing a
Commonwealth Chief Dental Officer or an independent oral health advisory body
to improve coordination across the two tiers of government, increase engagement
with the private providers of dental services and to provide independent policy
advice.[46]
4.67
DoHA already has a Chief Medical Officer, a Chief Nursing Officer and,
as noted by the AHHA, has recently appointed a Chief Allied Health Officer.[47]
The AHHA also notes that DoHA currently has independent advisory bodies to
cover areas such as mental health, aged care funding, influenza, suicide
prevention, dementia, pathology, pharmaceuticals, preventive health and
marketing of infant formula.[48]
4.68
Responding to these proposals, DoHA commented:
I suppose for me it would be about what value [a Commonwealth
Chief Dental Officer] might add. There is already a lot of engagement with the
industry that occurs anyway. You do not necessarily need a specialist in the
Department of Health and Ageing—you can get advice from many sources, as we do.
For example, on dental issues, the Department of Veterans' Affairs runs a
dental scheme for veterans, and they have a panel of dental experts that we
use. We think that is probably a cheaper and more efficient way of accessing
expertise. Also, I am sure that the Australian Dental Association, if we asked
them, would be more than happy to give us advice for free. So it would be up to
government to decide whether it wanted to do something like that. We have quite
a lot in place already which allows us to get expert advice on dental policy.[49]
Committee comment
4.69
The Committee understands concerns regarding a lack of coordination
between the two tiers of government, and the private sector, in relation to
dental health policy and services. The Committee has commented elsewhere in this
report on the importance of increasing engagement with the providers of private
dental services, particularly in areas where public services are not available
or are oversubscribed.
4.70
With regard to improving coordination, the Committee considers that the
Adult Dental Services NPA provides an opportunity for significant progress. Clearly
defining roles and responsibilities for the Commonwealth, and for states and
territories, is a fundamental element of any NPA, and as such will be integral to
dialogue and negotiations.
4.71
While acknowledging the views expressed by DoHA, there is precedence for
appointments such as a Chief Dental Officer or an independent advisory body to improve
coordination across the tiers of government and the private sector, and to
provide policy advice. On this basis, the Committee believes that suggestions
to appoint a Commonwealth Chief Dental Officer or an independent advisory body
for oral health warrant further consideration.
Recommendation 10 |
|
The Department of Health and Ageing, in consultation with
state and territory governments and other key stakeholders, examine the case
to appoint a Commonwealth Chief Dental Officer or establish an independent
advisory body to:
n improve
coordination between the Australian Government, and state and territory
governments;
n increase
engagement with the private sector, particularly private providers of dental
services; and
n provide
independent policy advice on dental and oral health.
|
A strategic approach
4.72
Evidence notes inconsistent government approaches over the years to
dental policy and to responsibility for funding and provision of dental
services. This has resulted in a history of dental policy and services characterised
by changing priorities and sporadic, short-term funding.[50]
4.73
History has shown that there is a need for a national strategic approach
to dental health service provision.
4.74
In the following testimony Dental Health Services Victoria outlined the
effect of the changing policy frameworks on waiting lists for public dental
services:
The Government needs to consider long term sustainability.
Oral Health has suffered over the years with on-off funding. Over a decade ago
the Commonwealth Dental Health Program was axed resulting in a number of people
unable to access care. This has been repeated with the closure of the Chronic
Dental Disease scheme. Both of these events resulted in significant increases
in waiting lists as the resultant increase in demand through the success of
these Commonwealth schemes led to additional eligible people, who might not
previously had accessed public dental care, now demanding care with no other
options than already lengthy public dental waiting lists.[51]
4.75
Commenting on the consequences of closing the CDDS, Dr Kerrilee Punshon of
the Australian Society of Special Care in Dentistry and the Australian and New
Zealand Academy of Special Needs Dentistry described the implications on
continuing of care for dental patients:
… I have a pool of patients at the moment that have just finished
the Chronic Disease Dental Scheme. Some of them had come to me with very poor
oral health several years ago. We have cleaned them up and got them tidied up.
We now have a lot of them under control and they are ticking along nicely, but
there is a lack of continuity. Some of them are staying on in the practice but
I do not know how long for, even though their costs are less now because they
are coming in more for check-up and cleaning rather than comprehensive work,
because that was done. Others are going back to the private sector and others
are saying it is all too hard and they have just given up. What concerns me is
that you have spent this basket of money on getting these people's oral health
better and sorting out the backlog of problems they had, and now we have just
dropped them and things are just going to break down again for a lot of them.[52]
4.76
The implications for individual patients is also illustrated in personal
testimony from a patient with long-term and ongoing dental care issues:
My name is Sally and I received the dental health plan when
it was up and running and now am in desperate need of this again. I have
suffered from anorexia for the past 28 years and never anticipated that it
would result in my losing most of my teeth which now leaves me five up top. I
am in need of having two of them pulled and a denture so that I can at least
feel more normal. It is difficult trying to emotionally cope with the loss of
my teeth and not being able to afford private dental care. I am in chronic pain
because of my teeth and am on a two year waiting list for public dental care
but by that stage I don't know what will happen.[53]
4.77
With regard to strategic planning for dental and oral health, DoHA
advised that the process of developing an updated National Oral Health Plan has
started. The National Oral Health Plan 2014-2023 will replace the National Oral
Health Plan 2004-2013. The updated plan is expected to be finalised by the by
the end of 2013.
4.78
While evidence was generally supportive of updating the National Oral
Health Plan, CHF expressed concern that implementation of the first plan had
been poor, observing:
The patchiness of funding, coupled with the lack of
coordination, has contributed to the lack of progress under the National Oral
Health Plan 2004-2013. The document was ratified by the Australian Health
Ministers' Advisory Council in 2004, and in the decade since, minimal progress
has been made under several of its key indicators.[54]
4.79
A longer-term strategy that was strongly supported in evidence was for
implementation of a universal dental care scheme funded by Medicare.[55]
4.80
For example, Dr Thomas Higgins, a Tasmanian-based periodontist, suggested:
The answer to ensuring better access [for] all adult
Australians to better dental health is to transfer the provision of general
dental services to the private sector insisting upon quality guidelines,
standards and practice accreditation. The financing of these services would be
via taxation arrangements and an increase in the Medicare levy by a realistic
percentage, with built-in 3 year reviews.[56]
4.81
Testimony indicated that a universal dental care system would make best
use of services available through the private sector and public system. As
explained by the Association for the Promotion of Oral Health (APOH):
Were Medicare to fund dental treatment in a similar way to
medical service, then most people currently unable to access timely treatment
in the public dental service could receive near immediate treatment by private
dentists. This would greatly reduce demand for public dental services, and
provide opportunity for the public dental service to improve the quality of
treatment delivered.[57]
4.82
Several submissions noted that the issue of universal dental care has
been gaining momentum recently, referring to the National Health and Hospitals
Reform Commission (NHHRC), which put forward an option of a universal dental
scheme ‘Denticare’, in its 2009 report to Government.[58]
In responding to the NHHRC’s recommendation for ‘Denticare’, the Government
advised only that it was committed to the aim of increasing access to dental
services by proving a package of dental reforms to better target services to
those Australian most in need.[59]
4.83
Recognising the financial implications of introducing a universal dental
care scheme, the majority of proponents supported a phased approach to
implementation. The Dental Reform Package and the Commonwealth Government’s
commitment to fund an extension to adult dental services under the NPA were viewed
as an opportunity to progress toward the goal of a universal dental care scheme.[60]
Committee comment
4.84
It is clear that the approach of successive governments to dental policy
has been inconsistent. This has resulted in a changeable policy environment that
has not been compatible with a sustained commitment to improving the dental and
oral health for all Australians.
4.85
The Committee notes evidence relating to the CDHP and the CDDS which
illustrates the impact of the ‘stop-start’ funding on patients. Patients impacted
by closure of these schemes have had few options available to them. While some
who can afford to do so have sought treatment through the private system,
others have had to join lengthy waiting lists to access public dental services.
Some patients, unable to afford private treatment and discouraged by lengthy
waiting times to access public services, have discontinued treatment
altogether. For governments responsible for the provision of public dental
services, the changeable policy environment compromises their ability to plan
services and support the necessary workforce to deliver services in the longer
term.
4.86
Notwithstanding the policy decisions to close these schemes, there are
some key lessons to be learned which should inform the development of future
policy. The Committee believes that many of these issues could have been
avoided if both tiers of governments adopted a longer-term strategic approach
to dental policy and funding of dental care.
4.87
To achieve the best possible outcome and level of commitment necessary,
the Committee recognises the need for the Commonwealth to work closely with
state and territory governments and other key stakeholders to develop a
strategic plan to underpin longer-term dental policy endeavours.
4.88
Although the Committee is encouraged to note that develop of the updated
National Oral Health Plan for 2014-2023 has involved stakeholder consultation,
it also notes evidence which suggests that implementation of the National Oral
Health Plan 2004-2013 was disappointing. Therefore, to complement development
of the National Oral Health Plan for 2014-2023, the Committee recommends a
process of negotiation with state and territory governments and other key
stakeholders, to establish and commit to an implementation strategy.
Recommendation 11 |
|
The Australian Government commit to a robust dental policy
framework that guarantees the long-term sustainability of the public dental
sector as a provider of dental services through ongoing funding support.
|
Recommendation 12 |
|
The Australian Government, in consultation with state and
territory governments and other key stakeholders, establish and commit to an implementation
strategy for the National Oral Health Plan 2014-2023.
|
4.89
In considering the evidence, the Committee notes the general enthusiasm
for the introduction of a universal dental scheme delivered through a
combination of public and private dental services. While a universal dental
scheme is a worthy goal to work toward in the longer-term, the Committee
understands the substantial cost that a universal scheme would present.
4.90
The current public dental system provides important and necessary
services to the eligible population, and its contribution to the oral health of
Australians should not be undervalued. However, there are evidently issues in
providing access to the eligible population as illustrated to some degree by
long waiting lists and delays in accessing public dental services.
4.91
In the shorter-term, the Committee agrees that effort should be focussed
on how to prioritise access to publicly funded dental services to ensure that
those most in need are able to access care. However, in the longer-term the
Committee is keen to support a strategic policy approach for phased
implementation of a universal dental care scheme.
Recommendation 13 |
|
The Australian Government adopt a strategic policy approach
which supports deliberate and phased progress toward a universal access to
dental services scheme for Australia.
|
Ms Jill Hall MP
Chair
4 June 2013