Submissions

Child Dental Benefits Scheme – Grow Up Smiling .
The Australian Dental Association (ADA) welcomes the opportunity to contribute to the development of the Child Dental Benefit Scheme “Grow Up Smiling” – GUS (the Scheme) as per the Consultation paper. The ADA is encouraged by the Government’s initiative to provide prevention and treatment for children who are most in need and to address the reported decline in children’s oral health.

Scope of practice within workplace policies and new models of care .
The ADA wrote to the Dental Board of Australia stating that the scope of practice defines the construct of any workforce policies and so must define models of care and training. The ADA stated its support for existing DBA scope of practice standard remaining.

Review of the Arrangements for the Scheduling of Medicines and Poisons .
The ADA has provided comments on the process for the scheduling of medicines and poisons – which is particularly relevant in light of inappropriate access to teeth whitening products currently being permitted to non-qualified persons.

AHPRA Data Access and Research Policy .
The ADA has given feedback on AHPRA’s proposed Data Access and Research Policy.

Request for ACCC Confirmation Regarding Take Home Teeth Whitening Kits .
The ADA sought confirmation from the Australian Competition and Consumer Commission’s view in light of the recent decision by the Department of Health and Ageing about take home teeth whitening products.

Inquiry into Adult Dental Services .
The ADA has provided a submission to the Parliamentary Inquiry into Adult Dental Services in Australia and looks forward to being able to engage with governments to advise and assist the development of the appropriate dental service delivery models for all Australians.

Changes to Premarket Assessment Requirements for Medical Devices .
The ADA has provided comment to the Therapeutic Goods Administration about its proposal paper on “Changes to premarket assessment requirements for medical devices".

The ADA seeks ACCC Clarification On Take Home Teeth Whitening Kit Obligations .
DoHA made a decision about existing classifications of teeth whitening products under the Poisons Standard that may impact on dentists’ obligations under the Competition and Consumer Act 2010. The ADA advises members to continue to refrain from giving patients take home whitening kits with >6% hydrogen peroxide and/or >18% carbamide peroxide until we receive an update from ACCC.

Draft HWA Health Professionals Prescribing Pathway .
The ADA gave feedback on the HWA’s draft Health Professionals Prescribing Pathway, which has been developed to support a nationally consistent approach to the prescribing of medicines by health professionals other than doctors.

Development of Governance Standards - Australian Charities and Not-for-Profits Commission .
The ADA has provided a submission to the Department of the Treasury about the coverage and focus of the ACNC's governance standards that are intended to apply to registered charities.

2013-14 Federal Budget Submission .
The ADA has provided its views as to how the Australian Government can improve the oral health of Australians in its upcoming Federal Budget for 2013-14.

Chemical Scheduling Regarding Teeth Whitening .
The ADA has made a further submission to the Advisory Committee on Chemical Scheduling in response to the interim decision on teeth whitening.

DBA's Review of Accreditation Arrangements .
The ADA has given feedback to the DBA about its Review of Accreditation Arrangements. Amongst other things the ADA supported separating accreditation functions from registration of dental practitioners and having an independent external organisation perform accreditation.

PHIAC's Discussion Paper - Competition in the Australian Private Health Insurance Market .
A submission to the Private Health Insurance Administration Council (PHIAC) by the ADA has outlined how private health insurers’ behaviour within the private health insurance market operated to the detriment of consumers and healthcare providers.

Feedback to Cleft Lip and Cleft Palate Scheme Meeting .
The ADA has provided feedback to the Department of Health and Ageing on addressing the anomalies and shortcomings in the Medicare Cleft Lip and Cleft Palate Scheme.

ADA Comment on ALRC's Issues Paper: 'Copyright and the Digital Economy' .
The Australian Law Reform Commission (ALRC) released an Issues Paper for the ADA to provide comment on 'Copyright and the Digital Economy'. The ADA used this opportunity to seek an exemption for dental practices from having to pay copyright licence fees.

ADA makes further Submission on Teeth Whitening Products .
The ADA has made a further submission to the Department of Health and Ageing seeking to have teeth whitening products classified appropriately.

Inquiry into the Dental Benefits Amendment Bill 2012 .
The ADA has provided comment to the Standing Committee on Community Affairs Legislation Committee on the Inquiry into the Dental Benefits Amendment Bill 2012 (the Bill). The ADA is well aware that investing in the oral health of children is a sound and sensible initiative. However, the ADA strongly believes that the input of the profession is critical in order for the new arrangements to operate effectively and to ensure that past mistakes are not repeated.

ACCC Submission on Private Health Insurance .
The ADA has provided a submission to the ACCC in belief that there are many anti-competitive practices by health insurers in Australia. The ADA feels that these should be brought to the attention of the Commission and the Senate, and therefore has addressed the issues that the Commission is required to address in its report to the Senate.

Response to DoHA's Letter Regarding The Cleft Lip and Cleft Palate Scheme .
The ADA has written to the Department of Health and Ageing (DoHA) providing feedback on its approach to reform the Cleft Lip and Cleft Palate Scheme.

The Draft 'Mandatory Data Breach Notification in the eHealth Record System' Guide. .
The ADA has responded to the Office of the Australian Information Commissioner's (OAIC) consultation paper on the draft 'Mandatory Data Breach Notification in the eHealth Record System' guide. The ADA understands that this guide is designed to help entities comply with their obligations.

Building a National Clinicians Network .
The ADA has provided a submission of support to the Australian Government in response to its discussion on establishing a National Clinicians Network (NCN). The ADA conceives that such an initiative's effectiveness and acceptance will depend on adequate communication and consultation across all levels of the health sector.

The Revised Open Disclosure Standard and Framework .
The ADA has expressed its concern to the Australian Commission on Safety and Quality in Healthcare (ACSQHC) regarding the revised Open Disclosure Standard and Framework.

International Criminal History Checks .
The ADA has provided feedback to the Australian Health Practitioner Regulation Agency (AHPRA) on the four options provided for refining international criminal history checks.

International Criminal History Checks .
The ADA has provided feedback on options for the refining international criminal history checks as outlined in the AHPRA Public Consultation Paper issued in June 2012.

Teeth Whitening Interim Policy .
The Dental Board of Australia has begun a process to review and consolidate its interim policy on teeth whitening/bleaching.

Copyright licence fees for dental practices .
The ADA has requested that an exemption be provided to dental practices that broadcast copyright works and recordings from having to pay licence fees to Copyright Collecting Societies under the Copyright Act 1968.

Dental Board of Australia Acupuncture Endorsement .
The ADA has written to the Dental Board of Australia supporting the DBA's proposed process for the endorsement for acupuncture under section 97 of the Health Practitioner Regulation National Law.

Response to evaluation report .
The ADA has made suggestions to the Secretary of the Department of Health and Ageing regarding over the counter teeth whitening products that contain hydrogen peroxide or carbamide peroxide and relevant restrictions.

Amendment to ACCS/ACMS application re: Teeth Whitening .
The ADA wishes to significantly amend its application as set out in its letter dated 14 February 2012 that was sent to the Advisory Committee on Chemicals Scheduling and Advisory Committee on Medicines Scheduling

DBA Interim Policy - Teeth Whitening .
Letter to Ms Tanya Vogt, Executive Officer of the Dental Board of Australia, regarding the interim policy on teeth whitening.

Inquiry into the Health Insurance (Dental Service) Bill 2012 [No.2] .
The Senate, on the recommendation of the Selection of Bills Committee, has referred for inquiry the Health Insurance (Dental Service) Bill 2012 [No.2] (the Bill) by the Standing Committee on Finance and Public Administration Legislation Committee.

Letter to DoHA regarding PCEHR Legislation Issues Feedback .
This letter outlines the Australian Dental Association Inc. (ADA)’s submission to the Department of Health and Ageing on the Personally Controlled Electronic Health Record System (PCEHR System) Regulations and Rules.

ADA responds to ACCC’s view re dentists obligations on supply of teeth whiteners .
The ADA has responded to the ACCC’s letter of 16 March 2012 outlining concerns about the restrictions placed on dentists with respect to the issuing and prescribing of teeth whiteners.

Australian Charities and Not-for-profits Commission: Implementation Design Discussion Paper Submission .
The ADA welcomes the opportunity to provide comment on the Australian Charities and Not for Profits Commission (ACNC) Discussion Paper on Implementation Design.

ADA submission to the Advisory Committee on Chemical Scheduling (ACCS) .
This letter outlines the ADA's submission to the Advisory Committee on Chemical Scheduling for consideration at the meeting July 2012.

Submission to Australian Commission on Safety and Quality in Healthcare .
The ADA welcomes the opportunity to provide comment on the Australian Commission on Safety and Quality in Health Care (ACSQHC)’s Consultation Paper Australian Safety and Quality Goals for Health Care (ASQGHC).

ADA Pre Budget Submission .
Equity & Timely Access of Dental Care for Vulnerable & Underserviced Populations

Review of not-for-profit governance arrangements Consultation Paper Submission .
The Consultation Paper seeks to review the governance obligations appropriate for registered not-for-profits (NFPs) (regardless of entity type), taking account of the findings of the Final report of the Scoping Study of a national NFP Regulator.

ACNC Exposure Draft Legislation Submission .
The Bill will create the legislative framework to support the establishment and implementation of an Australian regulator for charities and the not-for-profit sector.

PCEHR Legislation Submission .
The ADA welcomes the opportunity to provide comment on PCEHR Bill 2011 and the PCEHR (Consequential Amendments) Bill 2011.

Inquiry into the factors affecting the supply of health services and medical professionals in rural areas .
The ADA agrees with the Senate Committee’s Terms of Reference’s assertion that there are factors which limit the supply of dentist practitioners in rural/regional areas.

ADA submission to Exposure Draft Legislation – Third party procured GST-Free Health Supplies .
The ADA supports the exposure draft legislation which extends the GST-free treatment to other health related supplies arising under other types of multi-party arrangements.

PCEHR Exposure Draft Legislation Submission .
ADA submission to the Department of Health and Ageing on the Exposure Draft PCEHR Bill 2011 and the Exposure Draft PCEHR (Consequential Amendments) Bill 2011.

Submission to Health Workforce Australia .
Rural and Remote Workforce Innovation and Reform Strategy Background Draft Paper

Draft Guidelines on Conscious Sedation Area of Practice Endorsement .
The ADA has been provided with the opportunity to comment on the DBA's draft Guidelines on Conscious Sedation Area of Practice Endoresement.

Submission to the ACCC regarding Private Health Insurance .
The ADA has provided recommendations for immediate remedial action to bring Private Health Insurance in line with the intereset of their members.

Senate inquiry into the administration of AHPRA .
The ADA has submitted to the federal Senate Inquiry into the administration of AHPRA. The ADA sought feedback from members and Branches in developing the submission.

Submission to HWA Draft Framework for Innovation and Reform .
The ADA reinforces the uniqueness of dental practice in its submission to Health Workforce Australia’s National Innovation and Reform Strategic Framework.

DBA Supervision Submission .
In general terms the ADA agrees that the expectations of supervisors and the practitioners with limited registration need to be clearly set out.

Submission ACCC Report to the Australian Senate on anti-competitive and other practices by health funds and providers in relation to private health insurance .
There is considerable disquiet felt by both members of the public and the dental profession with private health insurer conduct in recent times.

Submission to the Australian Commission on Safety and Quality in Health Care .
The ADA has continued to be actively engaged in the practice accreditation process.

Submission to the Productivity Commission Disability Care and Support .
The ADA commends the Productivity Commission for undertaking this review as it demonstrates an important stage in a concerted effort to improve the quality of life of the disabled and those with special needs who for too long have had to endure not only general health issues but also poor oral health and a poor quality of life including dental pain and discomfort.

Advertising Therapeutic Goods in Australia: Consultation Paper .
The Australian Dental Association Inc. (ADA) writes with reference to the Department of Health and Aging, Therapeutic Goods Administration (TGA), Advertising Therapeutic Goods in Australia: Consultation Paper

Submission to the Productivity Commission: Caring for Older Australians .
The ADA recommends changes focused on early detection and prevention for older Australians' dental health.

Submission to the Senate Education, Employment and Workplace Relations Committee: Inquiry into industry skills councils .
The ADA raises an inquiry into committee council.

Submission to the Department of Health and Ageing .
Development of a Quality Framework for the Medicare Benefits Schedule June 2010

Submission to the Industry Skills Council - Consultation Paper on NQC required changes to high use qualifications from HLT07 Health and CHC08 Community Services training packages .
The ADA objects to the proposed draft packaging rule changes to the HLT31807 Certificate III in Dental Assisting.

Response to Dental Therapist Regulations Working Party Report .
The ADA provides the following response to the letter from the Government of South Australia seeking feedback on the Dental Therapist Regulations Working Party Report.

Oral Health Workshop Project-Developing Oral Health Care Competencies for the Community Services and Health Industries .
The Australian Dental Association Inc. has commented on the Industry Skills Council’s paper entitled: Oral Health Workshop Project-Developing Oral Health Care Competencies for the Community Services and Health Industries.

Professional Attributes and Competencies of the Newly Qualified Dentist .
This document describes the type of dentist [“dental practitioner”] needed in Australia. The Australian Dental Council (ADC) will use this document as a reference point in carrying out its key functions of: accreditation of education and training programs for dentists; and assessment of international dental graduates for practice in Australia.

Australian guidelines for the prevention and control of infection in healthcare .
Despite what is said in the Scope on page 180 about including office based practices involved in invasive procedures such as dental practice, overall the document has a strong hospital focus and appears not to have been written to address the needs of office-based practice.

Proposal to the Australian Government on the regulation impact statement on TGA and NICNAS proposed regulation of disinfectants. .
In response to recommendation 4.61 contained in the Report of the Commonwealth Government's Taskforce on Reducing the Regulatory Burden on Business (the Banks Report), released in April 2006, the Therapeutic Goods Administration (TGA) and the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) have released a consultation regulatory impact statement, for public comment.

Draft Review by Peers in Professional and Administrative Processes - Submission by the Australian Dental Association Inc. .
The ADA Inc. is supportive of actions and processes that are being demonstrated to improve the safety and quality of dental care in Australia and as long as there is a positive cost-benefit.

2010 Environmental scan for health and community services online consultation .
This survey seeks to obtain industry intelligence on skills supply and demand, workforce development priorities, analysis of implementation of current Training Packages and recommendations for changes to the Packages through the Continuous Improvement Plan.

Consultation Process on the Draft National Safety and Quality Healthcare (NSQH) Standards .
The ADA comments on the draft National Safety and Quality Healthcare (NSQH) Standards.

Federal Budget Submission 2010-2011 .
The ADA is pleased to present its Pre-Budget Submission to the Federal Government for the 2010-11 financial year. This submission contains a range of recommended budget and policy initiatives for the consideration of Government and provides the context and background that have led to these recommendations.

Australian Dental Association Inc. Response to Dental Board of Australia's Consultation Paper on Registration Standards and Related Matters .
This submission deals with each of the Mandatory registration standards as listed in chapter 2 of the Consultation paper.

Submission to the AQF Council on the Strengthening the AQF: An Architecture for Australia’s Qualifications .
The Australian Dental Association Inc responds to the Strengthening the AQF: An Architecture for Australia’s Qualifications.

Proposal for a National Dental Foundation Year Program .
The Australian Dental Association Inc. has advocated the introduction of a dental intern or residency year to the Commonwealth Government on a few occasions, and the Federal ADA President, Dr Neil Hewson, recently gave an undertaking to the Minister for Health and Ageing, Hon Nicola Roxon, to provide a submission.

Submission to the Australian Government on the National Compact Consultation Paper .
The ADA would like to make the following comments in relation to the National Compact Consultation Paper.

Submission to the Australian Commission on Safety and Quality in Health Care - Discussion Paper on achieving the directions established in the proposed National Safety and Quality Framework .
The Australian Dental Association Inc (ADA) thanks the Australian Commission on Safety and Quality in Health Care (the Commission) for the opportunity to comment on the proposed National Safety and Quality Framework.

Submission to the Dental Board of Queensland - Guidelines on the Practice of Dentistry by Dental Therapists and Dental Hygienists – Nitrous Oxide .
The Australian Dental Association Inc (ADA) thanks the Dental Board of Queensland for the opportunity to provide comment on guidelines on the practice of dentistry by dental therapists and dental hygienists with regard to nitrous oxide.

Submission to the Australian Competition and Consumer Commission (ACCC) - Report to the Australian Senate on Anti-Competitive and Other Practices by Health Funds and Providers in Relation to Private Health Insurance .
The Australian Dental Association Inc (ADA) thanks the Australian Competition and Consumer Commission (ACCC) for the opportunity to provide comment as it prepares to write its 11th report to the Senate on health insurance and related issues.

Submission to the Australian Communications and Media Authority on the Children’s Television Standards Review .
The Australian Dental Association (ADA) has a commitment to the delivery of oral health care for children. The focus of this submission will be on the impact to children of television advertising in so far as it will concern children’s dental health.

SUBMISSION TO THE AUSTRALIAN ASSOCIATION OF NATIONAL ADVERTISERS .
The Australian Dental Association Inc (ADA Inc) is pleased to respond to the Australian Association of National Advertisers’ review of its Code For Advertising To Children

2007-2008 Pre-Budget Submission .
The oral health of the Australian population is neither very good nor very bad. Many in the community enjoy good oral health, aided by timely access to high quality dental care. By contrast, others in the community suffer from poor oral health, spending excessive periods – sometimes years – waiting to receive basic dental care in our public system. For a country with the financial means such as Australia this situation reflects poorly on our health system.

The COAG Health Working Group .
The ADA is pleased to respond to COAG's request for information as to how COAG can implement the establishment of a single national registration and single national accreditation scheme in the health sectors.

Criteria for Specialist Registration .
The Australian Dental Association (ADA) response to the invitation to comment on the document “Criteria for Specialist Registration”.

Privacy Bill .
The Australian Dental Association's response to the Senate Legal and Constitutional Legislation Committee on the inclusion of health information in the Privacy Bill.