More than 5000 general practitioners are about to receive a letter from the Ministry of Health regarding their pathology requests.
The last letter of “nudge” will be target general practitioners who are above the 90th percentile for pathology claim rates through the Medicare Benefits Schedule (MBS) between July 1, 2019 and June 30, 2021.
Pathology applications under review include thyroid stimulating hormone (TSH), thyroid function tests (TFT), vitamin B12, iron and vitamin D studies.
Only services rendered and claimed under the MBS by a pathologist are included in rate calculations, while letters will not be sent to GPs who practice primarily in remote or very remote areas (regions 6 or 7 of the model of Modified Monash).
Correspondence sent by the Department of Health (DoH) to RACGP noting the campaign indicates that the activity is intended to ‘reduce GP requests for combinations of MBS pathology items when there is no clinical indication serious illness and when pathology tests are unlikely to support the diagnosis or management of the patient’s health problem”.
Dr. Cathryn Hester, owner of the practice and member of the expert committee of the RACGP – Financing and reform of the health system (REC-FHSR), said newsGP that while she understands the need for practice improvement initiatives, the timing of the letter is not ideal.
“My biggest concern is whether the data is truly representative of what GPs would normally do in their day-to-day practice, as much of the data collection period coincides with the pandemic,” she said. .
“This may have prompted some GPs to order additional tests at a time when clinical information was changing rapidly, and GPs were doing their best to keep up to date and do what was in the best interests of their patients. .”
It’s not the first time questions have been raised about the timing of ‘nudge’ letters, and similar campaigns have drawn criticism in the past for being unnecessarily intimidating and unfairly targeting some GPs – prompting the college to request a change in submission to DoH in December 2019.
In the submission, the college reported that there was a “growing perception that compliance activities are designed to monitor and target statistical outliers, as opposed to fraudulent activities,” among a long list of other issues.
Dr Hester still shares some of these concerns and says another consideration is the number of GPs included in the campaign.
“Over 5,000 GPs is a very large number, so we’re not even looking at a small number of clear outliers,” she said.
With an estimate 31,000 practicing general practitioners across Australia, over 5,000 letters means over 15% of the workforce will be targeted.
“Even though it’s worded sensitively, a lot of these GPs are going to feel anxious and probably even a little intimidated,” Dr Hester said.
The college has remained firm in its position that while it supports activities that preserve “Medicare’s integrity” and prevent “wrongful and fraudulent claims,” such activities should “prioritize education over to punitive measures.
RACGP advocacy has already seen the DoH commit to taking a more educational approach when conducting compliance campaigns, and the department has worked closely with the college and other key stakeholders more recently in developing of his new activities.
In correspondence with the RACGP about the campaign, the DoH acknowledged that pathology requests “are influenced by many factors,” so they partnered with Wiser Healthcare and sought guidance from the college and d other leading health care groups.
He also sought input from individual GPs and patient representatives in the design and development of the letters, which he describes as a “project”, rather than a compliance activity.
“Some RACGP members may receive a letter from the department providing feedback on their pathology request and information regarding support resources and tools,” the DoH correspondence reads.
“Members who receive this letter are not being contacted in connection with any audit compliance or practitioner review activity and are not required to provide any information to the department regarding their pathology inquiries.”
To emphasize education, DoH letters will also provide links to a number of resources and toolsand says he is keen to “better understand how different ways of presenting personalized feedback and educational information” support GPs in their reflective practice.
The college maintains its intention to continue to “work collaboratively” with the DoH to “develop, [and] improve or promote education and resources for providers regarding Medicare compliance”.
Dr Hester says she appreciates that the DoH has listened to advice from the RACGP and other representative bodies, but still has some concerns.
“As we enter the next phase of managing the pandemic where we encourage patients to re-engage with their GP and re-engage with preventative and primary healthcare, we really don’t want to send the message that GPs should limit their patient care,” she said.
“So while I agree with the general principle of choosing the best and most appropriate pathology tests for patients, and certainly not asking too much, this may not be the most ideal time. for such a campaign.
“I’m afraid GPs will still find the letters very anxiety-provoking.”
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