More than 5000 GPs are about to receive a letter from the Department of Health about their pathology requests.

Female GP holding referral letter
More than 5000 GPs are about to receive a letter from the Department of Health about their pathology requests.

The latest ‘nudge’ letter will target GPs who are above the 90th percentile for rates of pathology requests through the Medicare Benefits Schedule (MBS) between 1 July 2019 and 30 June 2021.


The pathology requests under examination include thyroid stimulating hormone (TSH), thyroid function tests (TFTs), vitamin B12, iron studies and vitamin D.


Only services rendered and claimed under the MBS by a pathologist are included in the rate calculations, while letters will not be sent to GPs who practice primarily in remote or very remote areas (Modified Monash Model regions 6 or 7).


Correspondence sent from the Department of Health (DoH) to the RACGP flagging the campaign says the activity aims to ‘reduce GP requesting of combinations of MBS pathology items where there is no clinical indication of a serious illness and where pathology tests are unlikely to support diagnosis or management of the patient’s health concern’.


Practice owner and RACGP Expert Committee – Funding and Health System Reform (REC–FHSR) member Dr Cathryn Hester told newsGP that while she appreciates the need for practice improvement initiatives, the timing of the letter is not ideal.


‘My biggest concern is whether the data is genuinely representative of what GPs would normally do in their day-to-day practice, because a large proportion of the data collection period coincides with the pandemic,’ she said.


‘That may have prompted some GPs to order additional tests during a time where clinical information was rapidly evolving, and GPs were trying their best to keep up to date and do what was in the best interests of their patients.’


This is not the first time that questions have been raised about the timing of ‘nudge’ letters, and similar campaigns have attracted criticism in the past for being unnecessarily intimidating and unfairly targeting certain GPs – prompting the college to call for change in a submission to the DoH in December 2019.


In the submission, the college flagged there was a ‘growing perception that compliance activities are designed to monitor and target statistical outliers, as opposed to targeting fraudulent activity’, among a long list of other issues.


Dr Hester still shares some of these concerns and says another consideration is the sheer number of GPs included in the campaign.


‘Over 5000 GPs is a really large number, so we’re not even looking at a small number of clear outliers,’ she said.


With an estimated 31,000 practising GPs across Australia, more than 5000 letters means over 15% of the workforce will be targeted.


‘Even if it’s worded sensitively, a lot of those GPs are going to feel anxious and probably even a little bit intimidated,’ Dr Hester said.


The college has remained firm in its position that while it supports activities that preserve ‘the integrity of Medicare’ and prevent ‘wrongful and fraudulent claiming’, such activities should ‘prioritise education over punitive measures’.


RACGP advocacy has previously seen the DoH commit to adopting a more educational approach when conducting compliance campaigns, and the department has been working closely with the college and other key stakeholders more recently in the development of its new activities.


In its correspondence to the RACGP about the campaign, the DoH acknowledged that pathology requests ‘are influenced by many factors’, which is why they partnered with Wiser Healthcare and sought advice from the college and other peak healthcare groups.


It has also sought feedback from individual GPs and patient representatives in the design and development of the letters, which it describes as a ‘project’, rather than compliance activity.


‘Some RACGP members may receive a letter from the department providing feedback on their pathology requesting and information regarding supporting resources and tools,’ the DoH correspondence stated.


‘Members who receive this letter are not being contacted as part of an audit or practitioner review compliance activity and are not required to provide information to the department about their pathology requests.’


In an attempt to shift the focus towards education, the DoH letters will also provide links to a number of resources and tools, and says it is keen to ‘better understand how different ways of presenting personalised feedback and educational information’ supports GPs in reflective practice.


The college maintains it plans to continue ‘working 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 the advice of the RACGP and other representative bodies, but still has some concerns.


‘As we enter into the next phase of pandemic management where we’re encouraging patients to reengage with their GP and to reengage with preventive and primary healthcare, we really don’t want to be sending the message that GPs should be limiting their care for patients,’ she said.


‘So while I agree with the general premise of choosing the best and most appropriate pathology tests for patients, and certainly not over-requesting, this really may not be the most ideal time for such a campaign.


‘I am concerned GPs will still find the letters very anxiety provoking.’


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