Category: Submissions

Mental Health and the role for research in improving outcomes

Research Australia has made a submission in response to the Productivity Commission’s Draft Report on Mental Health. Our submission has focused on recommendations related to the role of the National Mental Health Commission (NMHC), evaluation and mentoring of programs, and the role for research in improving mental health outcomes and the delivery of mental healthcare services.

We have highlighted the significant expertise in program evaluation that exists in the health economics research and health services research community, and the role it could play in supporting the NHMC in evaluating programs. Our recommendations include a role for the NHMC in sponsoring research into gaps in knowledge relating to service delivery and improving the adoption of evidence based care. We have also called for researchers to be given access to data collected and used by the NHMC.

Research Australia’s submission is available here.

Pre Budget submission calls for renewed investment in R&D (December 2019)

Research Australia’s submission to the Treasurer ahead of the 2020-21 Budget has used the Government’s own figures showing a drop in R&D investment by Government and business to call for a renewed focus on research and development, including health and medical research. In addition to greater investment in R&D across the board, Research Australia has called for increased funding for the research programs of the NHMRC and ARC; action to make better use of data; and investment in prevention.

To read Research Australia’s submission and the full list of recommendations, click here.

Data Sharing- developing new legislation

Research Australia has responded to the Australian Government’s latest Discussion Paper on the development of Data Sharing legislation. The legislation aims to improve the sharing of data by Australian Government departments and agencies.

Research Austrlaia’s submission has urged further consideration be given to how public benefit and commercial use are to be defined and how tests for these might be applied. It has also supported the approach to the accreditation of research institutions and individuals, and  cautioned against ethics approval by an HREC becoming a default requirement for all data sharing applications.

Research Australia’s submission is available here.

The next stage will be the release of draft legislation for consultation, expected in early 2020.

Better regulation of complementary and unconventional medicine and emerging treatments

Health and medical research enjoys strong public support because people recognise that health and medical research leads to safer, higher quality and more effective healthcare. Research Australia’s members work hard to contribute to an evidence-based healthcare system that is continually improving the healthcare delivered to patients. This is achieved through the development of new treatments based on scientific evidence which have been rigorously tested and evaluated to ensure they are safe and effective.

In doing so, our members have helped create the impression that all existing healthcare is evidence-based, safe and effective. When this is not the case, we have an obligation to ensure that people are aware that what they are receiving is not routine care, and to alert them to the associated risk and other matters they should consider. Research Australia’s submission to the Medical Board of Australia has called for clear and prominent consumer warnings to be provided when consumers are being offered complementary and unconventional medicine and emerging treatments by medical practitioners that aren’t part of a registered clinical trial.

Research Australia’s submission

 

 

Supporting Clinical Quality Registries – towards a national strategy

Clinical Quality Registries (CQRs) collect and use data about patients’ treatments to improve the delivery of healthcare. CQRs already play a vital role in helping Australia deliver safer, higher quality healthcare, but the approach to CQRs in Australia is ad hoc and fragmented. The Australian Commission for Safety and Quality in Healthcare has been working for more than a decade to improve this situation and the Australian Government has recently released a draft National CQR Strategy for the next 10 years.

Research Australia made a submission in response to the Draft Strategy, welcoming the progress being made in this area, and making suggestions for how the Draft Strategy could be improved. These include broadening the focus from the clinician/patient relationship to capture other patient interactions with staff that affect health care. Accreditation of CQRs and a sustainable national funding model with the support of state and territory governments are also critical elements for the Strategy.

Research Australia’s submission is available here.

The Commonwealth Department of Health subsequently released the final National Clinical Quality Registry and Virtual Registry Strategy 2020-2030 in February 2021, available here. The nomination of key target areas for CQRs and a sustainable funding model for these are no longer part of the Strategy, although funding for key areas is still likely, possibly from the MRFF.

A new Framework for Clinical Trials

Research Australia has responded to the draft National Clinical Trials Governance Framework developed by the Australian Commission on Safety and Quality in Health Care. The subject of an extensive consultation, Research Australia is confident the final Clinical Trials Governance Framework will be an important step forward in improving Australia’s capacity to undertake clinical trials and to improve safety, quality and effectiveness. Research Australia’s submission addresses three areas where further clarity can be provided and improvements made.

Research Australia’s response to the Clinical Trials Governance Framework

Research to support Victorian Mental Health Royal Commission

Research Australia has responded to the Victorian Government’s consultation on the Terms of Reference for the Victorian Royal Commission into Mental Helath.

Research Australia has recommended the adoption of two specific Terms of Reference. Firstly, we recommended a Term of Reference to identify how health and medical research can be better utilised to:

• identify quality, effective mental health interventions (including for prevention and

early intervention);

• support the more rapid and comprehensive adoption of evidence-based

interventions and models of care in Victorian mental health services;

• improve the safety and effectiveness of Victorian mental health services; and

• develop effective quality care indicators and quality assurance mechanisms.

Secondly, we have recommended the adoption of a Term of Reference requiring the Commissioners to identify specific areas, where it becomes evident during the course of their Inquiry, that more research is needed. Research Australia’s submission is available here.

Research Australia is now awaiting the commencement of the Royal Commission, and the opportunity it provides to highlight the role research can play in improving the mental health of all Victorians.

Pre-Budget Submission calls for smart investments in research and innovation

Research Australia’s Pre-Budget submission to the Australian Treasurer recognises the positive policy developments in the last 12 months and the not so positive. It provides 16 recommendations across 8 broad themes for implementation in the 2019/20 Budget.

These include fully capitalising the MRFF; reversing funding cuts to NHMRC and ARC funding programs and the research block grants; finalising and implementing the Digital Economy Strategy; and leaving the R&D Tax Incentive alone.

Better use of data is once again a key theme of Research Australia’s submission. If we are to make the most of our national investment in digital health we need to increase data capability in Government departments and agencies. Beyond this we need to raise levels of digital health literacy across the community to enable all Australians to better manage their health and avoid exacerbating existing health inequities in Australian society.

Read Research Australia’s submission

Research Australia opposes cuts to R&D Tax Incentive

In the May 2018 Budget the Government  proposed a series of changes to the R&D Tax Incentive which would further reduce the support it provides to private sector R&D activity. While advocacy by Research Australia and others has succeeded in having clinical trial expenditure by small companies exempted form the cuts, several of the other changes remain a concern. Research Australia’s submission to the Senate Inquiry on the new legislation has put the case for why the cuts should be rejected by the Senate.

Research Australia’s submission

On 11 February 2019, the Senate Committee handed down its report. It recommended that ” that the Senate defer consideration of the bill until further examination and analysis of the impact of schedules 1–3 is undertaken. In particular, the committee recommends that:
• the approach to the cap on the refundable portion of the Research and Development (R&D) tax incentive is refined, noting investment decisions already taken; and
• the formula for R&D intensity is refined, noting inherent differences in R&D intensity across industries and impacts on businesses with large operating costs.”

Research Australia welcomes the decision and is pleased the legislation is not proceeding in its current form.

 

No place for exaggeration in advertising medicines

The advertising of medicines in Australia is subject to strict controls. The new Therapeutic Goods Advertising Code, due to commence on 1 January 2019, emphasises the importance of truthfulness and accuracy in all claims made in advertising for medicines, and the need for advertising to support consumers’ informed decision making.

The TGA has developed draft guidance to assist with the interpretation of the new Code, and discusses ‘puffery’, a claim so exaggerated that no reasonable person could take it seriously. The Guidance suggests that puffery may be permissible in the advertising of medicines. Research Australia’s position is that this should not be the case. It is both inconsistent with the Code and the low levels and wide variability of health literacy in Australia.  Some vulnerable consumers can be misled and unduly influenced by exaggerated claims that would be dismissed by most consumers as unbelievable and just ‘marketing’. It is our position that puffery should not be permitted in the advertising of medicines.

Research Australia’s submission

Update: The TGA issued a final version of the Guidance on the Advertising Code (and an amended Therapeutic Goods Advertising Code) on 31 October. The new Guidance states ‘Puffery by its nature is not truthful. It is exaggerated, inaccurate and unsubstantiated and should not be used in advertisements for therapeutic goods.’ 

The Code and the Guidance are available from the TGA website.