Submission on health legislation amendment Bill
The AMA's submission to the health legislation amendment Bill (Improving Choice and Transparency for Private Health Consumers) supports the intent of the Bill. However, it details serious concerns about aspects of the Bill relating to the Medical Costs Finder website.
The AMA holds significant concerns about the Department of Health, Disability and Ageing’s proposal to publish a single annual “average fee” for each medical practitioner. The AMA is not convinced a single figure will deliver meaningful or fair transparency for consumers, given the diversity of clinical practice. This is because:
- average fees may be misleading
- certain practitioners may be disadvantaged
- insurer–hospital agreement dynamics sometimes drive out‑of‑pocket costs
- supervised services may skew a supervising practitioner’s published average fee.
The AMA is particularly concerned the department has not consulted the medical profession on the scope of information that can be published on the website including the methodology underpinning the single fee, despite the clear risk of unintended, misleading, or harmful consequences.
The submission broadly supports the department's suggested approach to product phoenixing, noting it also agreed private health insurers should retain the ability to close or terminate products to manage prudential risk, while being prevented from using such product closures to facilitate phoenixing.
However, the AMA’s support comes with several caveats with respect to the need for legislated definitions of the terms ‘public interest’ and ‘exceptional circumstances’, neither of which are currently defined in the Private Health insurance Act 2007. Neither of these concerns are appropriately addressed in the subject Bill.
