07 th March 2018 Simon Hynes Program Lead ReturnToWorkSA simon.hynes@rtwsa.com Alex Lawrence Policy and Advocacy Advisor Exercise & Sports Science Australia alex.lawrence@essa.org.au Dear Simon, RE: Exercise Physiology Fee Consultation Thank you for providing Exercise & Sports Science Australia (ESSA) with the opportunity to submit feedback to the proposed gazette fees for exercise physiology services for 2018 2019. ESSA has several comments that we would like to table with ReturnToWorkSA regarding the 2018 fee order and exercise physiology fees more broadly. 1. Proposed fee charge ESSA believes that the utility of the Medicare Australia data would be improved with a broader understanding of accredited exercise physiologist (AEP) billing practices. ESSA, in consultation with our South Australian chapter, is satisfied to support ReturnToWorkSA s decision to propose a 0% increase in the allied health hourly rates for 2018 2019, following the 2.3% increase in fees over the previous 3. However, ESSA does not believe that the Medicare Australia data that ReturnToWorkSA uses to calculate the average private charge is an accurate representation of what the average private patient pays for AEP consultations. ESSA s 2015 Workforce Survey [1] shows a discrepancy between bulk billing for Medicare individual client services and individual private consultations. 45% of AEP business report bulk billing Medicare Chronic Disease Management (item 10953) patients compared to an average charge of $80 for an individual private consultation lasting up to one hour. The individual private consultation fee represents a ~53% increase above the bulk billing rate for Medicare Chronic Disease Management patients. This difference suggests that the average private charge (APC) change calculated from the Medicare Australia data, and subsequently benchmarked to represent an industry s growth, may not accurately reflect the dynamics of the AEP industry. Recommendation: We request that ReturnToWorkSA apply the confirmed gazette fee equally to all professions.
2. Parity between all allied health professions Ensure parity in the conditions and processes for AEPs with other professionals within the ReturnToWorkSA scheme. As discussed during our previous teleconference meeting, ESSA is encouraged by ReturnToWorkSA s commitment to parity between allied health professionals. We request that ReturnToWorkSA remain attentive to any future decision that might inadvertently benefit or penalise a single profession. ESSA also encourage ReturnToWorkSA to prioritise amending policies that still see AEPs not receiving equal attention, including the absence of specific case conference and travel item codes. ReturnToWorkSA s expectation that exercise physiology services respect the standards outlined in the Clinical Framework for the Delivery of Health Services (Clinical Framework) are explicit in the Exercise Physiology fee schedule and policy. The Clinical Framework repeatedly recognises the importance of best practice, adopting a biopsychsocial approach, multidisciplinary services and collaboration. Without the adequate provision for services it is not feasible for AEPs to fully integrate the Clinical Framework standards into their services in order foster a patient s independent management of their health. In the absence of specific case conference and travel item codes for AEPs, ESSA does welcome the additional steps that ReturnToWorkSA has taken to allow AEPs to seek prior approval for case conferences with medical providers, employers, case managers and the workers. However, feedback from AEPs who are providing exercise physiology services to workers as part of the South Australian Return to Work scheme have identified several issues with the current system: Underpaid costs I was asked to attend two case conferences by the case manager for the same patient. The fee and dates where approved on 24/8/2017 and 24/8/2017. Both remain underpaid. The reason stated was simply that there was not an item number for AEP s to attend case conferences. Inconsistent payments I have received approval for travel, and depending on the case manager, I have been paid under different item codes. Delaying treatment The prior approval process takes too long and is just another hurdle that detracts from improving patient outcomes. Having better access to timely case conferences encourages a more responsive, collaborative and effective treatment plan. Recognition We want to continue to build our relationships with case managers, General Practitioners and rehab consultants. We need to be part of the treatment
team and not an add on service. I have had patients doubt their treatment plan because I haven t been a part of the case conference. Graduate confidence I am fortunate to be experienced enough that I am comfortable making requests for pre-approved travel. However, there is a concern that the lack of codes might deter new graduates and isolated sole trader operations, for example small rural and remote businesses, from seeking pre-approval for justifiable travel. It is not widely publisised that AEPs can get access to travel. It is reasonable to determine that travel and case conference item codes were initially introduced for all the other allied health professions to facilitate improved outcomes for injured workers. ESSA is pleased to recently hear that AEPs, on average, are completing their treatment plans in 8 sessions two less than the ten-session soft cap proposed by ReturnToWorkSA despite the disparities in the current Exercise Physiology fee schedule and policy. Considering that AEPs generally work with patients with complex and chronic considerations, a cohort who usually require significantly more resources to promote positive outcomes [2, 3], this news is conducive for a costeffectiveness and sustainable scheme. Recommendation: It would be in ReturnToWorkSA s best interest to encourage this trend in service volume by better supporting the AEP industry with the inclusion of a travel and case conference fee. Recommendation: ESSA request that ReturnToWorkSA investigate all possibilities to improve consistency across approved treating allied health practitioner disciplines to simplify processes and reduce red tape. 3. Exercise physiology management plan AEPs need to have access to an Exercise Physiology Management Plan. Feedback from our South Australian AEPs suggests that our members are happy with ReturnToWorkSA s current management plan policy: AEPs only need to provide a management plan if the case manager specifically requests one. However, AEPs are reporting an increase in the frequency of requests for management plans from case managers, and in these occasions, it would be appropriate to have an Exercise Physiology Management Plan. ESSA has previously collaborated successfully with other state workcover authorities to develop a suitable, evidence based management plan template for Exercise Physiology providers. ESSA welcomes the opportunity to assist
ReturntoWorkSA in the development of an appropriate Exercise Physiology Management Plan that will streamline administrative efficiencies for the scheme, case managers and AEP providers, whilst also maximizing quality assurance and an outcomes focused approach to patient interventions. Recommendation: We request that ReturnToWorkSA work with ESSA and our South Australian state chapter to develop an Exercise Physiology Management Plan. Thank you for considering our comments regarding the ReturnToWorkSA fee order. We welcome the opportunity to discuss any of the aforementioned points further. Please do not hesitate to contact alex.lawrence@essa.org.au if you require further information. We look forward to hearing from you and would be delighted to agree a suitable meeting time to discuss this opportunity further. Yours sincerely, Alex Lawrence Policy and Advocacy Advisor Exercise & Sports Science Australia
References: 1. Hetherington, S. 2015 Workforce Survey - Final report. 2015 15 August 2016]; Available from: https://www.essa.org.au/wpcontent/uploads/2015/06/workforce-report-2015.pdf. 2. Deloitte Access Economics, Value of Accredited Exercise Physiologists in Australia.. 2015: Canberra 3. Deloitte Access Economics. The value of accredited exercise physiologists to consumers in Australia. 2016 [cited 2016 30 November]; Available from: https://www.essa.org.au/wp-content/uploads/2016/04/deloitte-value-of-aepto-consumers.pdf.