SA Medical Imaging new RAH Outpatients Consultation Feedback 1
Contents Contents 2 Executive Summary 3 Consultation Process 3 Summary of Consultation Feedback 4 2
Executive Summary KPMG was commissioned by SA Health to provide a report into the options for the management of outpatient radiology at the new Royal Adelaide Hospital (new RAH). As you would recall, radiology at the new RAH is a distributed imaging model with separate outpatients, emergency department and inpatient areas. The KPMG review team was asked to assess the impact of outpatient imaging services being delivered by current in-house resources, or, alternatively, the services being delivered by an external provider. The use of an external provider would enable staff to focus on delivering services to patients in ED and inpatients. Consultation Process In preparing the report, KPMG consulted with staff, referring clinicians and unions about the requirements, referral patterns and operating models for medical imaging services at the new RAH. Consultation on the report from KPMG commenced on 23 June 2017 and provided an opportunity for staff and unions to seek clarification, provide input and feedback on the options and issues identified in it. As a consequence of the KPMG report and concurrent to consultative processes, SAMI released a tender specification seeking responses for the provision of imaging services. The release and timing of the tender specification was of concerns to Unions and this process is on hold at the present time. 3
Summary of Consultation Feedback A summary of the issues/feedback raised has been addressed by SAMI and responses are grouped by common themes Deskilling of staff, Training and Accreditation Concern - training and accreditation of Medical Officers and any impact to SAMI if the outpatient service is provided by a private provider. There was also a query as to how training for Radiographers would occur if the outpatient services are outsourced and that this approach will lead to deskilling of the workforce. Registrar training requirements will be maintained and are in line with public sector expectation. The private provider will need to meet the requirements of the Royal Australian and New Zealand College of Radiologists. These are public sector requirements for training and accreditation. Specifically, the private provider must provide 1 FTE radiologist consultant per 1.5 FTE registrar trainees and activity is capped at 9,500 studies per radiologist consultant. These requirements will allow SA Medical Imaging and SA Health to maintain its training and accreditation. The private provider will also be expected to attend multidisciplinary meetings as required. Radiographers are registered professionally through the Australian Health Practitioner Regulation Agency (AHPRA). Their registration is not reliant on patient type, that is, emergency, inpatient and outpatient. Notwithstanding this, SAMI will explore options for multiple site rostering to allow staff who wish to maintain their outpatient skill set. Mammography staff rely on activity to maintain their accreditation. SAMI will look to placing these staff into sites that perform these studies. Any solution will require additional consultation processes as there will have flow on effects for other SAMI sites. 4
Radiation Safety Concern - the tender documents did not contain strong enough requirements regarding radiation safety. SAMI will be maintaining ownership of the equipment at new RAH and the Medical Physics staff will be expected to maintain the equipment as they currently do. Impact to patient care Concern - that patient care is optimised by having all imaging performed at one high-performing integrated centre. Outpatient work provided by an external provider may impact on patient care The private provider will adhere to referrer expectations and protocols. The private provider will be using all SAMI and SA Health infrastructure and information systems. The Safety Learning System will be utilised to capture incidents. The expected quality of the service will be governed through Key Performance Indicators and Service Level Expectation documents. These will be monitored through a formal governance contract management arrangement. Following a period of stabilisation there will be an assessment to determine that our resources (both human and capital) are providing a safe quality service. (Further response to be provided) Previous Reviews Concern - previous recommendations/reports have not been actioned or followed. SA Health engages consultancies for various reasons and as circumstances change, SA Health may further investigate or progress or otherwise, recommendations of previous and current reports. 5
Research Opportunities Concern - outpatient work provided by an external provider may impact on research opportunities The Chief Investigator of the research project will need to agree with the private provider their requirements and research protocols. Additionally fees may apply. Revenue Concern - outpatient work provided by an external provider may impact on revenue generation for SAMI and SA Health. SAMI will enter into a commercial agreement that is in the best interest of SAMI and SA Health. As SAMI will be retaining the equipment if in the event the contract become unviable the service could be returned to SA Health. Collaboration between clinical and radiological services Concern - the outpatient work provided by an external provider may impact on the clinical interface with non-radiologist clinicians throughout the rest of the new RAH Referrers and the private provider will collaborate as required to ensure the highest possible care to our patients. The private provider will be expected to provide a service in line with core business hours of the outpatient clinics. 6
Quality Improvement Concern - outpatient work provided by an external provider may impact on the quality improvement within the Radiology Department at the new RAH and across SAMI The private provider will adhere to referrer expectations and protocols under an outsourced model. The private provider will be using all SAMI and SA Health infrastructure and information systems. incidents. The Safety Learning System will be utilised to capture The expected quality of the service will be governed through Key Performance Indicators and Service Level Expectation documents. These will be monitored through a formal governance contract management arrangement. The private provider will be expected to provide a high quality and safe service to our patients including time consuming and complex patients. This also extends to any after care that may be required. The outpatient service will be monitored through the contract arrangements which may include patient and referrer satisfaction surveys. Rights of Private Practise (RoPP) Concern - outpatient work provided by an external provider will impact on the ability of new RAH Radiologists to meet their RoPP thresholds and may impact retention. Response SAMI are working to establish a state-wide cross site reporting policy which capitalises the ESMI system. This would allow radiologist to pool their revenue across SAMI and will act as a retention strategy. This will also enable radiologists to be exposed to the full spectrum of radiology examinations. 7
Comparators Concern - comparators used in the KPMG report were not useful as TQEH and FMC see different patient types, complexity and workloads and the three sites are not the same, hence to make comparisons between the sites is inaccurate and not useful. In particular the RAH see very complex patients that external providers will not be used to managing. The private provider will be expected to provide a safe and high quality service. The private provider will be governed through KPI s and formal contract management arrangements. Loss of jobs Concern outpatient work undertaken by an external provider will result in a loss of FTE at the new RAH. With respect to existing staff at the RAH, regardless of the outcome, current employees will be retained to provide imaging services. There is no proposal to reduce staff and in fact the new imaging model will require additional nursing and allied health staff. Impact to Radiation Oncology Patients Concern - regardless of the final model for outpatient imaging at the new RAH, there must be no impact to Radiation Oncology patients The private provider will maintain the current service that we provide to these patients. Radiotherapy technicians will continue to provide the support as they currently do now. 8
Probity of the Tender Process Concern - how probity was achieved in the stakeholder consultations, given that many of the radiologists consulted would have a financial interest in the private providers invited to tender. SA Health staff are bound by the Code of Ethics for Public Service Employees. This applies equally to the radiologist that may have outside interests. KPMG Report Risk Assessment Concern - how the risk assessment for the use of a private provider was derived within the KPMG report which has 13 high risks and 3 extreme risks. Concern was raised that very little detail is given on the treatment of these risks and the residual risk rating seems overly optimistic. Furthermore, concern was raised that there are a lack of benefits regarding the private provider option within the KPMG report and the financial information is unsupported. << response to be provided>> 9
Expenses incurred in delivering the outpatient service A query was raised whether there would be access to orderlies and interpreters if the outpatient services were provided by an external provider and if so who would pay. All expenses incurred by the outpatient service in the delivery of patient care will be charged to the private provider. Expense to patients Concern - if patients are bulk billed can a private provider still make the money it wants to or will SA Health need to bridge the financial gap and therefore create an added expense to the public health purse. No patient will have an out of pocket expense for services within the outpatient department. SA Health will not bridge any financial gap. Current arrangements for dedicated patient cohorts, such as prisoners will be maintained and worked into the contract arrangements with the private provider. This also includes other non-rebatable patients. The private provider will be bound by the contract to ensure that waiting lists are managed appropriately and consistent with the KPIs. Integrated ICT Systems Concern - that integrated ICT systems are integral to the efficient running of the service and staff seek confirmation that the external provider will use the same ICT systems. The private provider must use all SA Health and SAMI ICT systems. The private providers staff will bound by the Code of Ethics for Public Service Employees under these arrangements. 10
Risk of Harm to Staff Concern - the loss of outpatient imaging will mean the primary case load of RAH radiographers will be patients in emergency, those in theatre, and those with health concerns requiring inpatient admission. There are numerous risks identified with working with this cohort, including increased exposure to radiation, increased need for patient handling and the associated physical demand on staff. The concern is that because of the lack of rotation between inpatient and outpatient that these risks become greater. SAMI has committed to undertake a Work Health and Safety risk assessment within 3-6 months of the new RAH move to assess any staff impacts this includes infection control processes in imaging. In regards to manual handling, patient lifters will be available. SAMI will also be transferring its current lifter from the old RAH. Lifters will be assigned to appropriate areas. For staff on return to work plans that require light duties consideration will be given to offering these staff rostered shifts in the Chest Clinic and Cath Labs. Differing Employment Conditions for Radiologists Concern - all the major teaching hospitals have consultants that also work in the major private practices. If outpatient services are provided privately, there is a risk that one of these major private practices will achieve the tender. This then creates an untenable situation where consultants attending the hospital are doing so under different conditions which create inequity. Staff are bound by their individual employment contracts and conditions applying to the work they undertake and the employer party. 11
For more information John Kolovos Executive Director SA Medical Imaging john.kolovos@sa.gov,au Department for Health and Ageing, Government of South Australia. All rights reserved 12