Dear members,
A small number of psychologists will soon receive a letter from the Department of Health (DOH) as part of a campaign in relation to Better Access review and referral matters. We know that such letters can raise concern so we are writing to reassure you that the DOH has advised the purpose of this campaign is educational and it will not be taking further compliance action at this time.
We would also like to remind you about the APS position on Better Access referral requirements and outline what we are doing to address the issues members are experiencing with referrals.
We encourage you to read through this email for more information about our position on this DOH campaign and the current referral requirements, as well as our advocacy for change.
Why is the Department of Health writing to practitioners?
The DOH will write to a small number of psychologists (474) relating to claiming Better Access Initiative Items without a valid referral. This sample represents a tiny proportion of our community of psychologists. However, we understand that receiving such a letter can be a concerning and stressful experience and we have outlined some information below about what you should do if you receive a letter.
The Department has confirmed this campaign is an educational activity only, not an audit.
The focus of this DOH activity is the post-review for the second (or subsequent) course of treatment without a doctor review. The intent is to ensure that review reports are completed and sent to the referring doctor and that the doctor completes a review prior to the second (or subsequent) course of sessions. When additional sessions are permitted, they cannot exceed the standard maximum allowed without a doctor review.
The letter also states that the specific number of sessions needs to be documented on the referral, however the Department has confirmed psychologists can use clinical judgement about how many sessions are necessary, as long as it is within the available number of sessions for that course of treatment (see below for more information).
What is the APS position on this Department of Health campaign?
This awareness-raising campaign contradicts APS advice to the Department of Health. We have argued that such activity causes concern for practitioners and ultimately impacts adversely on patients, even if it is only intended to be educational. We have advocated that the current referral requirements are overly complex and often administrative without clinical benefit. Furthermore, the obligation on psychologists to follow up with doctors who do not correctly complete their referral does not benefit patient, psychologist or referring practitioner and ultimately adversely impacts patients.
What is the APS position on the current referral requirements?
The APS does not support the current referral requirements. We have long advocated for the removal of the review requirement at 6 sessions.
It is also our firm view that following up with the referring practitioner regarding compliance should not be the responsibility of the psychologist. This is an unnecessary administrative burden, and it can adversely impact patient outcomes because it can lead to the delay or cancellation of appointments, or significant out of pocket session costs for the patient. We know this creates conflict between psychologist and referrer (doctor), with the former required to essentially ‘audit’ their referring colleagues.
The treating psychologist is in the best position, together with their patient, to determine the most appropriate number of sessions in a course of treatment.
It is our priority to ensure that the DOH understands that the current referral requirements impose an unwelcome and unnecessary administrative burden on referring practitioners and psychologists, without significant addition to the quality of client care.
What is the APS doing to address the issue?
We have repeatedly advised the DOH that these referral requirements are not practical, reasonable or beneficial.
We have been communicating to the Department about this since January 2021. We have highlighted the serious implications for patients who face significant out of pocket expenses or may have their appointments delayed or cancelled due to psychologists’ inability to accept a referral or obtain a review under the current arrangements.
We have written to the Federal Minister for Health Mark Butler MP requesting he intervene to reduce the administrative burden and change the referral requirements.
What should I do if I receive a letter from the Department of Health?
If you receive a letter, read the information outlined in the letter and the associated fact sheet and ensure future claiming is consistent with the rules.
This activity is intended to be educational only, and there is no requirement to explain the claiming to the Department, but you may contact the Department via the contact details contained in the letter or at [email protected] should you wish to ask questions or provide feedback.
Do I need to follow up with the referring GP if the referral letter is not complete?
In January 2021, the Department of Health advised that psychologists were obliged to ensure that Better Access referrals received from GPs specify the number of sessions to be provided.
The Department overturned this in November 2021, following many months of APS advocacy. At that time, the Department advised where a referral does not specify the number of sessions, the psychologist can use their clinical judgment to provide sessions up to the maximum amount allowed for that particular course of treatment.
We have again confirmed this advice in July 2022.
Please know we will absolutely continue to prioritise this work and keep members informed.
We know that the last two years have been challenging for you and your clients and many of you are already feeling overburdened. Further uncertainty around issues such as this has an impact on you and your clients, and the administrative burden takes away from the time available for important clinical care and treatment. We are here to support our members and we can assure you we are responding to this matter.
If you have questions or feedback about this process, please contact the Australian Government Department of Health via email at [email protected]