Submission to the Independent Hospitals Pricing Authority on The Draft Activity-Based Funding Pricing Framework February 2012 1 2 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Contents Introduction 4 Diseconomies of scale 5 Cost factors beyond the control of the ACT Government 7 Quality and Safety 9 Block funding 10 Management of private patients 10 In-scope public hospital services 11 Cost indexation 12 Cross-border issues 13 Timing issues 14 Appendices First Minister correspondence in relation to loading for ACT specific costs 15 In-scope public hospital services 21 3 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Introduction The ACT supports the establishment of a pricing framework that will deliver on the commitment made by first Ministers to provide for an efficient price for the delivery of hospital care. The ACT is also strongly supportive of the work of the Independent Health Pricing Authority in the development of a nationally consistent counting and funding system for Australian public hospitals. However, the ACT is concerned that the draft pricing framework suggests an approach that, in parts, extends beyond the commitment made by first Ministers or, in parts, is inconsistent with those commitments. The ACT would also like to note a number of other issues of concern in relation to the draft framework. In summary, our concerns comprise:  The lack of flexibility in the proposed pricing framework to consider issues such as diseconomies of scale in smaller jurisdictions, where a range of services are provided as community service obligations in order to meet community needs;  The lack of flexibility in the proposed pricing framework to consider cost impositions that are outside of the control of a jurisdiction;  The expansion of the role of the IHPA to consider quality and safety issues;  The proposed treatment of privately-referred non-admitted patient services where such care is provided in a multi-disciplinary environment. The ACT submission also includes details of the Territory’s proposed approach in relation to block funding as sought by the IHPA in January 2012. This submission provides a summary of the issues the Territory would like to see reflected in the pricing framework. The ACT Health Directorate would welcome the opportunity to provide further evidence or to discuss these issues further if required. 4 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Diseconomies of scale The ACT Government, as with other state governments, has made a commitment to provide a comprehensive health service for the ACT Community. As a result, 95% of hospital services required by ACT residents at public hospitals are provided within the ACT. This commitment and the diversity of the services required leaves the ACT vulnerable to diseconomies of scale. The population of the ACT and nearby Southern Area part of NSW cannot support the throughput required to ensure certain speciality areas achieve benchmark costs. However, the lack of such services within the ACT region would increase the hardships faced by patients and their families during difficult times. DRGs recording less than 20 separations per annum account for 37% of all public hospital activity in the ACT. Services with less than 50 separations per annum account for 63% of all activity. However, a full operational service is required to provide the (almost) full range of hospital services for ACT residents. A comparison of The Canberra Hospital’s (TCH) Round 13 (2008-09) data with other hospitals from its NHCDC peer group reveals that TCH had below average volumes for 31% of its DRGs. High cost DRGs in the ACT (average DRG cost over $10,000) account for only 12% of ACT’s inpatient separations. The Canberra Hospital effectively operates a hospital system within a hospital. It is the principal referral hospital for the ACT and region. It also provides resources to enable the functions of a women and children’s hospital, acute geriatric care, specialised trauma, regional cancer services, cardio thoracic surgery, renal medicine, adult and neonatal intensive care, psychiatry, subacute care and rehabilitation medicine. Collocation has only a marginal impact on reducing diseconomies of scale of the various clinical specialities. Diseconomies of scale interact with the cost of providing appropriate teaching and research facilities which create an extraordinary burden on the ACT. Achieving teaching accreditation is a means of attracting clinical staff to the region. In addition to the expenditure on research and training, to achieve teaching accreditation hospitals are required to have more infrastructure, facilities and staff than other hospitals. The significance for the ACT is that it disperses those costs not only over minimal throughput in each service category but also over patient profile with an acuity approximating that of relatively inexpensive non-teaching hospitals (see Table 1 below). 5 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework TABLE 1: AVERAGE COST PER SEPARATION, PATIENT ACUITY AND ACUITY ADJUSTED COST PER SEPARATION, 2008-09 Average Cost Acuity Acuity adjusted average cost ACT $4,533 0.9969 $4,547 Teaching hospitals $4,624 1.0955 $4,221 Non-teaching hospitals $3,594 0.8954 $4,014 Source: National Hospital Cost Data Collection Cost Report Round 13 (2008-09) The effect of low average acuity is that teaching accredited hospitals in the ACT such as Canberra Hospital must achieve far greater throughput to attain the same economies of scale as other teaching hospitals. Without this extra throughput the cost per weighted separation remains high to accommodate the expenditure on the facilities and infrastructure that are necessary to provide a teaching accredited hospital. The small ACT population base also affects the capacity of private hospital providers to provide a comprehensive range of services. Based on estimates of hospital separations per 1000 population, ACT private hospitals offer about 26% less admitted patient services than their interstate counterparts, principally due to the size of the ACT population. The diseconomies of scale that the ACT experiences, due to its small population, places increased pressure on the public sector which is required to provide some of the services not offered in private hospitals. The National Health Reform Agreement also directs the IHPA to consider potential loadings for hospital type, size and location. This clause covers the issues noted above in terms of the location of the ACT and the impact of that location on the provision of public hospital services. While some have suggested that the reference to “location” refers to remote or rural hospitals, it is not defined as such in the NHRA. The ACT does not accept subsequent attempts to define terms within the NHRA. The ACT’s position is further strengthened by commitments made to the Territory by the current Prime Minister, and her immediate predecessor, in relation to the consideration of the ACT’s unique situation as a former Commonwealth entity with a responsibility to provide a full range of public hospital services to its citizens. 6 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework ACT Chief Ministers accepted those commitments in good faith in signing up to the NHRA. Copies of the relevant correspondence are at Appendix A The pricing framework needs to take into consideration the provision of specialised “costly” services in smaller jurisdictions in making a determination of an efficient price. Consideration should be made in providing loading at hospital level, for example teaching hospital loading. Cost factors beyond the control of the ACT Government The ACT became a self-governing Territory in 1989. The transfer of public servants from employment by the Commonwealth to employment by the ACT Government included the transfer of a range of costs required to be met by the Territory. Benefits and provisions available to Commonwealth public servants were traditionally higher than those offered by state governments. The primary additional cost related to the Commonwealth’s defined benefit superannuation schemes. These legacy costs increase the cost of providing services within the ACT. There is an argument that the ACT is responsible for the additional costs by maintaining the links with the Commonwealth Superannuation Scheme for almost 20 years from self-Government to the establishment of a payment-based superannuation scheme in 2006 (following the closure of the Commonwealth’s defined benefits scheme). However , the ACT Self Government (Consequential Provisions) Act 1989 (Cth) provides that “transitional staff shall be persons appointed or employed under the Public Service Act 1922” (Cth). As such, maintenance of access to Commonwealth superannuation schemes was part of the transitional arrangement provided for at at self-Government to ensure formerly Commonwealth employees would not be made worse-off as a result of the transfer to the ACT Government. Maintenance of the scheme was essential for the ACT Government to maintain and attract staff within a Territory in which the Commonwealth Government provided the main employment base. The capacity to move from the Commonwealth’s scheme to a payments-based scheme occurred only prospectively from the time of the Commonwealth’s decision to close the previous defined-benefits arrangements for Commonwealth employees. 7 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework In the lead up to the signing of the National Health Reform Agreement in July 2011, the Prime Minister, the Hon. Julia Gillard MP, wrote to the then Chief Minister of the ACT, Mr John Stanhope MLA, noting: I recognise the unique characteristics that differentiate the Australian Capital Territory health system including issues relating to scale, the impact of legacy arrangements from the time of self government and cross border impact on health services The Prime Minister went on to note: In the new national health reform agreement, I fully intend to recognise parallel arrangement for the [ACT] .... and the unique characteristics of the [ACT] that formed part of the National Health and Hospitals Network Agreement (NHHNA) In the lead up to the agreement of the NHHNA, Prime Minister Rudd noted It is our intention that the IHPA will also take the specific legacy costs in the ACT – arising from the Commonwealth’s former responsibilities for hospital services – into account in the calculation of efficient prices The National Health Reform Agreement, provides: B13. In determining adjustments to the national efficient price, the IHPA must have regard to legitimate and unavoidable variations in wage costs and other inputs which affect the costs of service delivery, including: a. Hospital type and size; b. Hospital location, including regional and remote status; and c. Patient complexity, including indigenous status It appears that the term “location” has been narrowly defined in the development of the pricing framework, well beyond the original intent of the NHRA. The NHRA reference to hospital location is inclusive of regional and remote status, but clearly not confined to it. In addition, the body of paragraph B13 refers directly to legitimate and unavoidable variations in wage costs, which the legacy superannuation costs from the Commonwealth administration of hospitals in the ACT clearly are. Therefore, both the reference to wage costs in the body of B13, and the ACT hospitals being “located” in a Territory and thus incurring these legacy costs from the Commonwealth argue for an interpretation of the NHRA and hence IHPA’s obligations to include consideration of a specific adjustment , or loading for these legitimate and unavoidable costs in the ACT. 8 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework The ACT is concerned that IPHA may be inclined towards relying on the Commonwealth Grants Commission (CGC) process as an alternative to incorporating appropriate loadings. The IPHA is tasked with determining the efficient price of hospital services delivered by LHNs. This should, in principle, involve determination of the cost at which a bundle of services can be efficiently delivered. In principle, this should take into account any disabilities an LHN faces, or unavoidable costs it may incur above the efficient cost. While the IPHA should have regard to the assessment made by Commonwealth Grants Commission, a more granular approach to determining the efficient price should be pursued. The Commonwealth Grant Commission assessment is based on providing “states” with capacity to deliver an average level of services, based on average policy. This will not identify at the ABF funding level differences in disabilities between LHNs, nor would it consider differences in service delivery policies. Further, it should be noted that the CGC assessment is not designed to directly funds states or LHN for the disabilities they face, rather it is a retrospective compensation payment made in the form of united revenue assistance. It would not be transparent for the IPHA to take a narrow approach to loadings and fund each hospital on a similar basis. States will be required to explain and adjust their funding contributions to LHN’s to reflect their actual costs. There is also risk that the national efficient price will become irrelevant as it will bear no resemblance to actual LHN costs. The pricing framework needs to take into consideration costs that are beyond the control of a jurisdiction in making a determination of an efficient price. Quality and safety The draft pricing framework, at Section 7.5, proposes an addition to the pricing framework that would adjust funding based on the quality outcome of services. The ACT does not support this approach. The National Health Reform Amendment (Independent Hospital Pricing Authority) Act 2011 clearly defines the role of the IHPA. That role is based on the development of a model to enable the Commonwealth to determine its funding commitment for public hospital services based on levels of activity. The role does not extend to the determination of the quality and safety of public hospital services. 9 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework All jurisdictions are committed to improvements in the quality and safety of our public hospitals services. The Commonwealth and the states and territories also agreed to the establishment of the Australian Commission on Safety and Quality in Healthcare in 2011. The Commission was established to further improve national consistency in the safety and quality of the health services delivered to our community. The efforts to improve the safety and quality of our services have also resulted in greater openness from clinicians to report adverse events. The introduction of any scheme at this time, particularly as part of funding model rather than as a quality and safety approach, could result in a reduction in the reporting of adverse events by clinicians (despite the proposed modest approach). As such, the ACT believes that any consideration of linking the funding of health services to the quality of that care should be managed through processes and arrangements being established under the auspices of the Commission, rather than through the IHPA. Consideration of any price discount related to quality and safety issues should not be considered in the early phases of the ABF. Further consideration of the linking of funding for services to the quality of those services should be considered by the Australian Commission on Safety and Quality in Healthcare, rather than by the IHPA Block funding The ACT and the Commonwealth agreed to block funding teaching, training and research and Queen Elizabeth II (QEII) hospital. It was also confirmed that the Equipment and Appliance Scheme will be block funded. The ACT’s estimate of proportion of TTR cost over total in-scope hospital services is about 1.3%. In addition to this, a further 1% of the ACT’s hospital services for block funding (QEII and Equipment Scheme). It should be noted that these estimates of allocation for 2012-13 were derived based on 2010-11 actual cost and not on what will be the likely IHPA funding model and pricing principles. Block funding arrangement should be revisited in line with issues discussed above; ie hospital loading and diseconomies of scale. Analysis of each service units affected by “availability” cost factor and low throughput level will be required upon release of the national efficient price and the pricing framework. It is of concern to the ACT that there is short timeframe allocated to internalise and assess the impact of the national efficient price, funding model and pricing framework. 10 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Management of private patients The proposed management of private patients under the pricing framework removes an incentive for public hospital systems to maximise patient revenues. Under the current special purpose payment arrangements, for the support of public hospital services by the Commonwealth, funding for state and territory health funding is based on a formula that does not consider the mix of patients treated within the public hospital system. The SPP paid to the ACT is not reconciled against the number of patients who are funded via third-party sources. As such, the proposed management of private patients under the pricing framework will remove any incentive for public hospitals to increase the level of private patients as under the proposed new arrangements the revenue from the Commonwealth for private patient care will be net of the contribution provided by the third-party source. The ACT does not accept that all privately referred outpatient services should be excluded from funding under ABF arrangements. Increasingly, non-admitted patient services are provided within a multi-disciplinary approach which includes more than the services of a doctor. Where other services are provided as part of a multi-disciplinary privately-referred outpatient service, and where those subsequent services are provided by public hospital employees, those services should be considered as a cost of a public hospital service within the ABF pricing framework. The draft pricing framework suggests that the adoption of ABF will not change incentives in relation to private patients. However, as this is not the case, the report should be amended. Privately-referred non-admitted services that are provided as a multi-disciplinary service with more than one clinician should be considered for inclusion within the ABF arrangements where the second or subsequent service(s) is provided by a hospital employee (eg in the case of an allied health consultation) In-scope services for ABF funding Clause A11 of the National Health Reform Agreement stipulates “States will provide the IHPA with recommendations for other services that could reasonably be considered to be a public hospital service and which are not captured by clause A10 11 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework (a) and A10 (b) that they consider should be eligible for a Commonwealth funding contribution”. Clause A12 of the NHRA further states “The IHPA will develop and publish criteria for assessing services for inclusion on a general list of hospital services eligible for Commonwealth growth funding. The IHPA will consider each State’s recommendations against the published criteria and establish a general list of other services eligible for a Commonwealth funding contribution”. Clauses A10 (a) and A10 (b) define all admitted services and all emergency department services to be eligible for a Commonwealth funding contribution under activity basis or block funded basis. The table at Appendix B provides a general list of ACT public hospital services that are considered eligible for a Commonwealth funding contribution, as assessed against the draft criteria published in Table 5.1 of the Activity Based Funding Pricing Framework. Cost indexation The ACT supports the suggested method of determining indexation under the pricing framework. However, as the Government Final Consumption Expenditure (GFCE) reported by the AIHW for health services, which is the basis for the recommended index, is only available publicly up to 2008-09, the ACT would like the IHPA to include the actual value of deflators to be used for the calculation of a 2012-13 price for hospital services. Clause A34 of the National Health Reform Agreement states: “In 2014-15, 2015-16 and 2016-17, the Commonwealth’s funding for each ABF service category will be calculated individually for each State by summing: a. Previous year amount: the Commonwealth’s percentage funding rate for the relevant State in the previous year multiplied by the volume of weighted services provided in the previous year multiplied by the national efficient price in the previous year; b. Price adjustment: the volume of weighted services provided in the previous year multiplied by the change in the national efficient price relative to the previous year multiplied by 45 percent; and c. Volume adjustment: the net change in volume of weighted services to be provided in the relevant State (relative to the volume of weighted services provided in the previous year) multiplied by the national efficient price multiplied by 45 per cent. 12 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework The draft Activity Based Funding Pricing Framework is deficient in its articulation and interpretation of this Clause A34. The Framework clearly states that in 2012-13 and 2013-14, the Commonwealth payments are fixed, and for 2014-15 and beyond, the Commonwealth will contribute additional funding for extra patients treated. While Clause A34 (c) is clear with regard to growth funding, what is unclear is how Clauses A34 (a) & (b) will translate into Commonwealth funding to States. It seems the intention of these two clauses is to produce a funding contribution that would equate to at least the Specific Purpose Payment amount that otherwise would have been paid under the previous arrangements, though adjusted for cost indexation. To this end, it will be prudent to set the national efficient price at a level that achieves this result and intended consequence. The ACT is seeking further clarification on this issue to better understand the likely Commonwealth funding contribution for base activity starting in 1 July 2014. The ACT would like to bring to IHPA’s attention Clause A68 of the NHRA that guarantees States will receive at least the amount of the funding it would have received under the former National Healthcare SPP. Our interpretation and the correct interpretation of this we think should be that the base funding constituting ABF funding from 1 July 2014 should at the very least equate to the SPP amount in 201314 that has been cost indexed for the next year. Growth funding would be added to this component to make total Commonwealth funding contribution under ABF payments. There should be a clear statement within the pricing framework in relation to the method for indexation of the SPP into the future. Cross-border issues Approximately one –quarter of cost-weighted activity at ACT public hospitals relates to services to patients resident in NSW. NSW patients in many DRGs have longer lengths of stay than ACT patients due to issues with discharging patients to services back in their home state. The delays are not due to comorbidities or acuity but simply due to access to appropriate step-down or community-based care in Southern NSW. As such, the DRG will not change, but the cost to the Territory will be higher than would otherwise be the case. NSW also pays a capital charge for the use of ACT public hospital services given the significant proportion of NSW patients using those services. It is not clear how these costs would be managed under ABF arrangements. The efficient ACT price needs to take into consideration the additional impost on ACT services through the management of NSW patients There needs to be greater clarity to how the current capital charge for the use of ACT services by NSW patients will be managed under ABF arrangements 13 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Timing issues While the IHPA does not have the authority to amend the agreed timeframe for the implementation of the pricing framework, the ACT remains concerned about the capacity of all jurisdictions to implement the necessary legislative arrangements to give effect to the new national health funding arrangements by 1 July 2012. This timetable is further at risk for jurisdictions such as Queensland, where the election timing provides additional logistical issues. Without the necessary legislative infrastructure, no funding will be able to be paid to Local Health Networks from 1 July. The absence of the legislation would result in an inability of health services to pay for public health services (including wages) without supplementary appropriation processes. The ACT believes that a “Plan B” needs to developed to provide certainty for health services, should there be any delays to the implementation of the legislation required to enact the new funding arrangements across the nation. The ACT is also concerned about the operation of the model from 1 July 2012 when Ministers will not have access to national comparisons of the impact of the pricing framework until May 2012. The ACT has some concerns about the application of the costing framework across all jurisdictions based on draft national average cost figures available in late 2011. The timing of the release of national comparisons provides little time for fine tuning or auditing of costing arrangements to ensure consistent application The ACT will seek to bring this issue to the relevant national fora. 14 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Appendix A 15 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework 16 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework 17 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework 18 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework 19 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework 20 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Appendix B Activity Basis Acute Admitted Services Canberra Hospital & Health Services Calvary Public Hospital Alcohol & Drug Anaesthetics Anaesthetics Cardiology Cardiology Dental Cardio-Thoracic Surgery Ear Nose and Throat Dental Emergency Medicine Dermatology General Medicine Ear Nose and Throat General Surgery Emergency Medicine Gynaecology Endocrinology Haematology Gastroenterology Head & Neck Surgery General Medicine Neonatology General Surgery Neurology Gynaecology Obstetrics Haematology Oncology Immunology Ophthalmology Infectious diseases Oral Surgery Neonatology Orthopaedics Neurology Paediatrics Neurosurgery Plastic Surgery Nuclear Medicine Psychiatry Obstetrics Urology Oncology Vascular Surgery Qualification Criteria Criterion 1 Ophthalmology Oral Surgery Orthopaedics Paediatric Surgery Paediatrics Plastic Surgery Psychiatry Radiation Oncology Radiology Renal Medicine Respiratory Medicine Rheumatology 21 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Thoracic Surgery Urology Vascular Surgery Emergency Department Services Triage categories 1 to 5 Triage categories 1 to 5 Criterion 2 Outpatients’ Services AborigLiaisonOfficer Adolescent health AborigMedicalServCaseload Aged care Criteria {3, 4 or 5} ACRS - 12B Circuit Class Allergy Acute ED caseload Antenatal After Hours Anti-coagulant Aged Care Caseload Assisted reproduction, infertility Antenatal Clinic Asthma Antenatal Ward Asthma education AntenatalClinic&PostNatalFollowup Audiology Audiometry Breast Birthing centre Burns Burn & Scar caseload Cardiac Burns Cardiac catheterisation Cardiac Caseload Cardiac rehabilitation Cardiac Rehabilitation Nurse Cardiac stress test Cardiac Surgery Cardiology unspecified Cardiology Cataract extraction Central Outpatients Audiology Clinic Chemotherapy Children's Feeding Clinic Childbirth education Clinical Haematology Clinical measurement Clinical Pharmacology Clinical Pharmacology Community Clinic MidwifeGungahlin Colorectal Continence Caseload Cystic fibrosis CSII Therapy Caseload Dementia Cystic Fibrosis Dental Cystic Fibrosis Caseload Dermatology Delivery Suite Development disability Dermatology Diabetes Diabetes Diabetes education Diabetes and Pregnancy Caseload Dialysis Diabetes Antenatal Clinic Dietetics Diabetes Clinical Trials Doppler Craniofacial 22 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Diabetes Education Inpatient Ear, nose and throat Diabetes GDM caseload ECG Diabetes GDM Nutrition Group Endocrine Diabetes HighRiskFoot caseload Endoscopy Diabetes New Start Insulin caseload Epilepsy Diabetes Nutrition Falls Diabetes Nutrition Carbohydrate Counting Group Family planning Diabetes Nutrition Clinic Gastroenterology Diabetes Nutrition General medicine Diabetes Periodic Review Nutrition Group TCH General practice Diabetes Podiatry Diabetes Puzzle Group Diabetes Social Work Fracture General surgery Genetic Gestational diabetes Diabetes Starting Insulin Group Gynaecological oncology (excluding chemotherapy) Diabetes SW Adult caseload Gynaecology Diabetes Type 2 New Starting Incretins Haematology/Haemophilia Diabetes Visit DiabetesNutritionAdult caseload Ear Nose & Throat Clinic Endocrine Endocrinology(Diabetes Education) Evening Service Falls - Physiotherapy Clinic Fastrack caseload Fastrack Physiotherapy Foetal Medicine Unit Fracture Clinic & Orthopaedics Gastroenterology Hand Hepatobiliary Home based palliative care Hyperbaric medicine Hypertension Imaging Immunology, HIV Infectious diseases Lens insertion Lymphoedema Melanoma Menopause Mens health GDM - New Starting Insulin Caseload Metabolic GDM/ Diabetes in Pregnancy Caseload Neck of femur General Caseload General Medicine General Paediatric Clinic General Surgery Genetic Gestational Diabetes Nutrition Clinic Metabolic bone Neonatology Nephrology, renal; excludes dialysis Neurology/Neurophysiology Neuropsychology Neurosurgery Infectious diseases/communic 23 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Gynaecology Obstetrics Gynaecology Caseload Occupational medicine Gynaecology Oncology Occupational therapy Haematology Oncology Hand Clinic Occupational Therapy Ophthalmology Hands caseload Optometry Head and Neck Caseload Oral Hospital In The Home Orthopaedics surgery Hospital in the Home Orthopaedic Program Orthotics Hydrotherapy caseload Otitis media Immunology Pacemaker Infectious Diseases Paediatric medicine Initial Home Visit Paediatric surgery Juvenile Arthritis Caseload Pain management Lymphoedema Caseload Pastoral Care Medical Oncology Pathology Midcall (OFF CAMPUS) Pharmacy Midwives Pre-Admission Clinic Physiotherapy Musculoskeletal Plastic surgery Musculoskeletal Student Podiatry Neonatal Int Care Unit Postnatal Nephrology Pre-admission Neurology Pre-anaesthesia Neurology Caseload (except CNC) Primary care Neurosurgery Prosthetics Neurosurgery Caseload Psychology Nutrition Allergy Clinic Pulmonary Nutrition Disability Visit Radiation oncology Nutrition Gastroenterology Clinic Radiology Nutrition Refugee clinic Nutrition Oncology Caseload Renal medicine/Nephrology Nutrition Paediatric Clinic Respiratory (excludes tuberculosis) Nutrition Renal Clinic Rheumatology Nutrition Renal Multidisciplinary Clinic Scoliosis Nutrition TPN Nutrition Visit Oasis Clinic Obstetric caseload Other medical Sexual health Sleep Social work Speech pathology Spinal 24 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Occupational Therapy Stoma therapy Occupational Therapy Visit Thoracic surgery Ophthalmology Thyroid Oral & Maxilliofacial Surgery Transplants Orthopaedics Caseload Upper GI surgery Other caseload Urology Videofluoroscopy Vascular Paediatric Wound dressing clinic Paediatric Arthritis caseload Paediatric CSII Education Clinic Paediatric CysticFibrosis Clinic Paediatric Diabetes caseload Paediatric Diabetes CGMS caseload Paediatric Diabetes Group Paediatric Diabetes New Children Paediatric Diabetes Nutrition Clinic Paediatric Diabetes Periodic Review caseload Paediatric Diabetes SW caseload Paediatric Diabetes Transition Clinic Paediatric Diabetic Clinic(Paediatric Nurse) Paediatric Feeding Clinic Paediatric Multidisciplinary Diabetes Clinic Paediatric Nutrition Follow-up Clinic Paediatric Orthopaedic caseload Paediatric Respiratory caseload Paediatric Surgery PaediatricDiabetesPodiatryClinic Paediatrics Paediatrics Caseload Paediatrics Diabetes Nutrition Clinic Pain Management Pain Management - Psychology Clinic Pain Management caseload Pain Management Unit - CBT Full Time Program Pain Management Unit - CBT Part 25 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Time Program Parent Educ Unit PDS Diabetes CSII Therapy caseload Physiotherapy Hydrotherapy Physiotherapy Physiotherapy Paediatric Physiotherapy Pulmonary Rehab Physiotherapy Respiratory Physiotherapy Visit Physiotherapy Women's Health Planning Plastic Surgery Plastics Caseload PMU Physiotherapy Podiatry Pre-admission Pre-Diabetes caseload Primary care Primary Joint Replacement Caseload Psychology QEII Caseload Radar OT Case Management Radar OT Cognitive/Perceptual Assessment Radar OT Consultation/Liaison Radar OT Equipment Planning Radar OT Functional Assessment/Retraining Radiation Oncology Radiology Rador OT follow up visit/phone call Rador OT Home assessment Renal Medicine Respiratory Caseload Rheumatology Rheumatology Caseload Scar Management School Clinics Caseload Social Work Social Work Visit 26 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Speech Pathology Speech Pathology Visit Starting Insulin Group (Nutrition) Stroke Unit Caseload Thoracic Dietician Clinic Thoracic Medicine (Respiratory) Thoracic Medicine-CPAP Clinic Type 1 - New Starting Insulin Caseload Type 1 Caseload Type 2 - New Starting Insulin Caseload Type 2 Caseload Urology Vascular Surgery Vision Screening Service Voice Caseload VPI and cleft caseload Walk-In Centre Mental Health Services: Designated PSU psychiatric ward - Admitted Patients - ED Patients Ward 2N Criterion 1 Older Persons Mental Health Unit Psychiatric/social problem/other presentation URG Psychiatric/social problem/other presentation URG Criterion 2 Psychiatry Criterion 3 Mental Health Assessment Unit - Outpatients Clinical Psychiatry - Non-Admitted Specialised Mental Health Care Patients Adult Step Up Step Down Unit Criterion 7 Belconnen - Adult Mental Health Service Better General Health Programme Brian Hennessy Rehabilitation Centre CAMHS Consultation And Liaison CAMHS Cottage CAMHS Dialectical Behaviour Therapy Program CAMHS Early Intervention 27 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework CAMHS Intake CAMHS Northside CAMHS Perinatal Program CAMHS Southside Crisis Assessment Treatment Team CATT AFP Communications Team City - Adult Mental Health Service Clozapine Consultation Liaison Dept of Psychological Medicine Dual Disability Service Eating Disorders Program Forensic AMC MH Service Forensic Bimberi MHS Forensic CA Service Forensic CO Service Headspace ACT MHS Neuropsychology Mobile Intensive Treatment Team/North Group Houses Mobile Intensive Treatment Team/North Medication On Call Doctor Older Persons Mental Health Service Triage Tuggeranong - Adult Mental Health Service Woden - Adult Mental Health Service Subacute and Non-Acute Services: - Admitted Patients Rehab in designated unit Rehab in designated unit Rehab as designated program Rehab principal clinical intent Rehab principal clinical intent Palliative in designated unit Palliative principal intent Palliative principal intent Geriatric evaluation and management Geriatric evaluation and management Psychogeriatric care Psychogeriatric care Maintenance care Maintenance care Geriatric Gerontology Criterion 1 Criterion 3 28 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework - Outpatients - Non-Admitted Community Based Patients Palliative Care Nurse Practitioner Geriatric Palliative Care Psychologist Home based palliative care Rehab Co-Ord Palliative care Rehabilitation Rehabilitation; excludes cardiac Geriatric Home based palliative care Geriatric Medicine Palliative care Criterion 6 Palliative Care Clinical Nurse Consultant Palliative Care Nurse Practitioner Palliative Care Registered Nurse Rapid Assessment of DeterioratingPt At Risk (RADAR) - Geriatric Medicine Rehabilitation Rehabilitation Care Coordinator Rehabilitation Nurse Practitioner Residential Aged Care Liaison Nurse Vocational Assessment Rehabilitation Service Other Aged Care Nurse Practitioner Non-Admitted Services: Aged Day Centre Care Coordinator North - Community Based Patients Aged Day Centre Care Coordinator – South Criterion 8 Continence Service CRC Dementia Group Breast Cancer Treatment Rapid Assessment of DeterioratingPt At Risk (RADAR) - Aged Care Nurse Practitioner Independent Living Centre Registered Nurse Falls - Registered Nurse - North 29 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework Block Funded Basis Canberra Hospital & Health Services Calvary Public Hospital Qualification Criteria Admitted Services Queen Elizabeth II Mothercraft Hospital Criterion 1 Other Medical Equipment and Oxygen & Sleep Apnoea Scheme Criterion 8 Non-Admitted Services Admitted, ED, Outpatients & Non-Admitted Specialised Services Teaching, Training & Research Criteria {any 1-8} 30 ACT Submission to the Independent Health Pricing Authority on the draft activity-based funding pricing framework