Catholic Health Australia Submission: Prescribed List — Clarifying definitions under the current Grouping Scheme

Introduction
The Department of Health and Aged Care (DoHAC) is clarifying some definitions under the current Prescribed List (PL) grouping scheme. The goal is to help stakeholders understand the correct grouping for different types of devices.

Concerns with the consultation process
The consultation process for clarifying and refining some definitions and descriptors for different categories of the PL has been notably flawed. Firstly, the DoHAC released the consultation and announced the proposed amendments on 23 December 2024 without prior notice. This sudden release has significantly hindered the ability of stakeholders to engage meaningfully with their members for comment. The timing, right before the holiday season, further exacerbated the issue, as many stakeholders were unavailable to review and respond to the proposed changes.
Secondly, while DoHAC has characterised the current consultation on clarifying definitions under the grouping scheme as ‘administrative’, this characterisation is both inaccurate and potentially misleading. The proposed changes in definitions could arbitrarily alter the PL, undermining its role in ensuring patient access and sustainable care provision. By labelling these changes as merely administrative, DoHAC downplays the substantial impact they could have on the healthcare system, including potential disruptions to patient care and access to necessary treatments.
Finally, many of the proposed definitions have already been implemented by Expert Clinical Advisory Groups (ECAGs) without prior consultation. This pre-emptive implementation bypasses the essential step of stakeholder engagement, which is crucial for ensuring that the definitions and descriptors are both accurate and fair. The lack of consultation with stakeholders not only undermines the transparency of the process but also raises concerns about the legitimacy and acceptance of the new definitions.