Health Promotion Charities: Response to the Exposure Draft of the Commissioner’s Interpretation Statement

This submission responds to the exposure draft of the Australian Charities and Not-for-profits Commission (ACNC) Commissioner’s Interpretation Statement on Health Promotion Charities (HPCs), a category that includes many of Research Australia’s members who conduct or raise funds for health and medical research. While generally agreeing with the draft, Research Australia comments on three paragraphs. It recommends clarification of paragraph 3.2, whose sex education example leaves unclear whether it illustrates an HPC, an educational charity or registration under more than one item of the legislation. It objects to paragraph 6.3’s reliance on an Oxford Concise Medical Dictionary definition of disease that excludes physical injury, noting that the Australian Institute of Health and Welfare (AIHW) and the World Health Organization (WHO) both treat injury as disease; AIHW data attribute 10% of the 2010 burden of disease in Australasia to injuries. It recommends deleting the reference so that injury research organisations are not wrongly excluded. Finally, it asks that paragraph 7.1 be reworded to make clear that research is direct engagement in preventing or controlling disease, consistent with the original purpose of the HPC category.