Writing a submission to MBS Review Taskforce

We strongly recommend that as many psychologists as possible put in a submission to the Medicare Task Force.  Reform APS has already sent one in recommending a single rebate for psychologists. Here is an example of a submission

The Medicare Benefits Schedule (MBS) Review Taskforce is considering how services can be aligned with contemporary clinical evidence and practice and improve health outcomes for patients – find out more here. The email address for submissions is mbsreviews@health.gov.au

We have provided a number of arguments that you could make, but you need to select which ones you feel strongly about and write them up in your own words. 
A submission needs to be in your own words  – not just a copy and paste from the website. They will not accept this point form as a submission.

We now have some suggestions for how to write a submission – download here 

Your submission needs to be kept concise and clear. You can learn how to write a submission – download here

Here are some arguments you can use in our submission:

  • The MBS benefits should be paid for the provision of the service and not for the practitioner’s background or qualification.
  • The efficacy and the outcome of the treatment should be the prime and only reason for applying a Medicare rebate and not the emolument of the practitioner.
  • There is no evidence that clinical psychology services provide better patient outcomes than general psychology services
  • Better Access funding could have provided crucial psychological services to hundreds of thousands more Australians than it did, due to the higher costs of the clinical rebate.
  • Preferential treatment contradicts research based on the Department of Health and Ageing’s own figures. Read more here
  • A single tier would align far better with the psychiatrists’ model, who are the other mental health experts in Australia. They have a matrix of item numbers for e.g. type of sessions but not type of psychiatrist.
  • The GP model does not make sense. We are all mental health specialists according to Medicare. We don’t need General Psychologists because medical GP’s will not give up being the referrers.

A single rebate would:

  • increase the availability of psychological services to the public at less cost
  • significantly increase the number of Australians able to access psychological support
  • rein in the cost of psychological care delivery and prevent the financial blow-out of the Better Access initiative
  • redress the systemic bias against those patients who receive treatment from non-endorsed psychologists in clinical practice under the lower-tiered rebate.
  • redress the partisan bias that favours one group of psychologists over others – unprecedented in Western countries ­and unsupported by any evidence of superior outcomes.
  • utilise and uphold the extensive depth and breadth of clinical practice expertise found within the broad scientific community of psychologists registered to practise in this country.
  • ensure an increased availability of affordable, more effective psychological assistance and reduce numbers of the millions of Australians being forced out of desperation onto the over-stretched public health system.
  • There is strong professional support for the removal of the two-tier system as shown on the change.org petition which has been supported by 2289 signatories.

We will be happy to accept more suggestions – send them to us at: apsreform@gmail.com



10 thoughts on “Writing a submission to MBS Review Taskforce

  1. The APS allowed psychologists to choose either the 4+2 system or the 6 yr system. Therefore they endorsed that both were equally good for clients and for the profession. By doing this it seems logical that regardless of the system you trained under the society acknowledges both AND TREATS BOTH EQUALLY. If this isn’t occurring then the society needs to address this inconsistency immediately.

  2. Can any one recall a document – I think we got it through RAPS – which looked at the cost of Better Access and broke it down into clinical psych, other psychs and GP? I recall it had a graph and actually showed a large expense was incurred in GP administration of the system.
    If so can someone direct me where to find it?

  3. Yes, Olive, your proposed outcome would be an ideal situation but that’s not going to happen in the current political and economic climate. Your proposed strategy has been tried and failed. The clinicals through the APS (see the now APS president Cichello’s 2013 email on this website) howled down any notion of all psychologists being on the same higher rebate. It appears to have offended the unjustified and false sense of superiority that the clinicals feel so entitled to. There are legitimate budget savings to be made with a one tier system that cuts back the clinicals over-inflated rebate. The clinical rebate has no support in the scientific literature. If you, or anyone else, remains in any doubt that non-clinicals were betrayed by the APS I would direct you to Littlefield et al 2006 submission to government (RAPS website obtained under FOI) advocating that only clinicals get any rebate. I would also direct you to Littlefield’s published responses (APS publication February and May 2017 and RAPS website). If you believe that then neither I nor anyone else can help you.

  4. I’m late to the conversation. I don’t understand what the goal is? When you refer to having a single tier system, are you proposing that the rebate for Clinical Psy is reduced to the current Registered Psy rate or that the Registered Psy rebate is raised to equal the Clinical Psychology rebate?

      1. Thanks for the info. I don’t think -given an open option – any government will choose to increase funding and increase their costs so therefore if successful, the most likely outcome is a single tier system will reduced the clinical psych rebate and there will be no change to non clinical psychs. If that outcome occurs, how will that advance the cause for non clinical psychs? Shouldn’t the argument be to raise the rebate so everyone is on the equal but higher rebate ?

        1. Unfortunately, Olive Pink, the insecure Clinical lobby cling to their false sense of superiority based on the overly-inflated rebate that the APS lobbied for in 2006, as if a two year Masters or PhD gives them any better training then we who have spent twenty years working with clients. I have had more then one clinical psychologist start their presentations at my place of work by saying “As Medicare acknowledges my superior training in the form of higher Medicare rebates, I am sure no one will question the clinical diagnosis I am about to present”. (Amusingly each time, I was able to find multiple errors in their “clinical diagnosis”, leaving them red-faced and spluttering when I pointed them out). If the inflated rebate gifted to clinical psychologists needs to be reduced to what the general psychologists have to make do with, that is a small price to pay to unify our profession and to stop generalists suffering under the disadvantage of the massively lower rebate. This is why I will donate to RAPS as only by ensuring that no book-educated clinical psychologist enjoys a higher Medicare rebate then an experienced and socially adept 4+2-trained psychologist can we unite our profession.

        2. I think it makes better ‘treating sense’ that all Psychologists are placed on the lower rebate with potential savings being redistributed by increasing the number of rebateable sessions in a calendar year.

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