In late 2019, all health ministers agreed to consult the public on medical practitioners’ use of the title “surgeon”, including “cosmetic surgeon”, under the Health Practitioner Regulation National Law (National Law).
Currently, all registered medical practitioners in Australia can use the title “surgeon”, including “cosmetic surgeon”, even when they have completed different levels of training or hold different qualifications. This may be confusing for members of the public, who may not have knowledge of medical practitioner qualifications and training. There is also a concern that this confusion may be leading to avoidable and disproportionate risks and harms to the public, resulting from poor cosmetic surgical outcomes.
Health ministers, as part of a collaborative nationwide consultation, are seeking feedback from the public about whether the current framework should be changed or if other options should be considered to help the public better understand medical practitioner qualifications.
Victoria, in consultation with all jurisdictions, has prepared a Consultation Regulation Impact Statement (RIS) to explain the current regulatory framework and the potential issues that may be arising from it. The Consultation RIS also proposes potential reform options which may help to address these issues. These options include:
- maintaining the status quo and existing regulatory and other tools, and using other methods to address issues
- increasing public awareness about the use of titles and provision of cosmetic procedures, and increasing opportunities for patient redress following adverse events
- strengthening the existing regulatory framework, including existing mechanisms designed to protect the public from harm
- restricting the title “surgeon” under the National Law, with feedback sought on which practitioners should be eligible to use the title.
How to participate
Stakeholders are invited to provide feedback on the questions outlined in the Consultation RIS. Responses to each question should include substantial evidence where possible.
An expert health consumer organisation has been engaged to survey members of the public about their experiences, reflecting the fact that sharing those stories is a very personal process. Responses to the Consultation RIS from members of the public can be made through the consumer specific survey hosted by the Health Issues Centre, which will ensure this process is handled sensitively and privacy is maintained for all respondents.
All respondents must consider the relevant collection notices below before completing a submission.
Submissions to this Consultation RIS should be provided as follows:
- individual members of the public must provide responses via this survey link to ensure that the privacy and anonymity of consumer respondents is protected: https://cosmeticsurgeryaus.questionpro.com.au
- workforce organisations, individual health practitioners and other entities are to provide direct submissions to the NRAS Review Implementation Project Team, using the response template in the document library below, via NRAS.Consultation@health.vic.gov.au.
Information provided by respondents will be used by health ministers to determine the most effective option/s to address the issues raised in the Consultation RIS.
The information collected will also inform the development of a Decision RIS which will be approved by Ministers and released to the public in 2022–23. The Decision RIS will outline and explain the preferred option/s for implementation and discuss any potential impacts to the sector.
Individual members of the public survey collection notice
Participation in this consultation is voluntary and by completing this survey, you consent to the Victorian Department of Health (department) collecting and using the information you provide in accordance with this notice.
The information in this survey will be collected and analysed by an external provider (the Health Issues Centre) and the Victorian Department of Health on behalf of all Australian health ministers to inform a Decision Regulation Impact Statement (RIS) for public release.
The results of the survey will be used to generate reports containing aggregated and anonymised information. These reports may be shared with other government entities, in Victoria and other Australian jurisdictions to inform government decisions about regulation of the title ‘surgeon’ under the Health Practitioner Regulation National Law. It may, for example, lead to changes in the law that restrict the range of medical practitioners who will be permitted to use that title.
This survey will ask about your experience of cosmetic surgical products and procedures and other surgical procedures as well as your general demographic (age, gender, and income) information. All the information you provide will be made anonymous and used to better understand general social trends in cosmetic surgery experience. We will not publish any identifying information or individual submissions.
Please do not to provide any information that will identify yourself, a medical practitioner or facility. Any reservations or concerns about the treatment you may have received from a particular medical practitioner, or about a medical practitioner’s conduct should be reported directly to the Australian Health Practitioner Regulation Agency (Ahpra). Any other complaint should be directed to a Health Complaints Commission or similar entity in your state or territory. If personally identifying information is inadvertently provided, we will take reasonable steps to delete it.
As your responses will be made anonymous, it will not be possible for you to access or update them after collection.
Direct submissions collection notice (for workforce and other entities and individual health practitioners)
Participation in this consultation is voluntary and by providing your responses, you/your organisation will be taken to have provided consent for collection and use of the information provided. You/your organisation will also have the option of requesting that your submission remains anonymous.
The Department of Health (department) is committed to protecting your privacy. The department collects and handles the information you/your organisation provide/s in this consultation as part of a Consultation Regulation Impact Statement (RIS) process it is managing on behalf of all Australian health departments and the Australian Health Practitioner Regulation Agency (Ahpra).
When making a submission, you/your organisation will be asked to provide information about patients’ consumption of cosmetic surgical procedures. This information is not intended to compromise patient anonymity, and will be used to better understand general social trends in patient access to cosmetic surgical procedures and patient outcomes.
Your/your organisation’s feedback, including qualitative and quantitative data provided, will inform government decisions about regulation of the title ‘surgeon’ under the Health Practitioner Regulation National Law and contribute to the development of a Decision RIS for public release. It may, for example, lead to changes in the law that restrict which medical practitioners will be entitled to use that title.
The consultation requests information relating to cosmetic and/or other surgery and does not ask organisations to provide any identifying information about patients, practitioners or facilities. You/organisations are asked not to include such information in your/their answers.
Respondents should not include any identifying information such as information about patients, medical practitioners or facilities in responses, as reservations or concerns about the treatment patients may have received from a particular medical practitioner, or about a medical practitioner’s conduct should be reported directly in a notification to Ahpra, or a health complaints commission or similar entity in the relevant state or territory.
Your/your organisation’s feedback will be collected, analysed and interpreted by the National Registration and Accreditation Scheme Review Implementation Project Team (NRAS project team) on behalf of health ministers. It may also be disclosed to health ministers and the health departments of other states and territories for this purpose.
The NRAS project team will not publish organisations’ individual submissions where organisations request to remain anonymous, but may publish information provided by organisations in their submissions in the Decision RIS. Your organisation may be identified in the Decision RIS, unless your organisation advises it wishes to remain anonymous. Where your organisation does not request to remain anonymous, your organisation’s submission may be published by health ministers. Your feedback may be shared with other government entities, both in Victoria and other Australian jurisdictions.
Completion of submissions by organisations is voluntary. There are no consequences for non-completion or for providing submissions which address all or some of the questions presented.
The NRAS project team supervising the consultation can be contacted by emailing NRAS.Consultation@health.vic.gov.au or you may contact the department’s Information Sharing and Privacy team by emailing firstname.lastname@example.org. You can request that changes be made to information you have been provided by contacting us using the above details.