House Standing Committee: Specialist Affordability - Options to Address Excessive Fees

ACCESS to medical specialists is a whole-of-system issue. It cannot be resolved by treating workforce supply, referral pathways, affordability, patient outcomes and models of care as separate problems. Each depends on the other.

Patients will not benefit from better referral information if there is no available specialist to accept the referral. Additional specialists will not improve access if Medicare billing rules prevent them from practising where care needs to be delivered. Benefit reform will not restore affordability if hospital services remain financially unsustainable. New models of care will not succeed if they are designed without the workforce, funding and governance settings needed to make them safe and viable.

The Commonwealth has direct levers available to improve specialist access. APHA urges the Committee to recommend reform of section 19AB of the Health Insurance Act 1973 (Cth), including removal or substantial redesign of the 10-year moratorium as it applies to medical specialists. APHA also recommends reform of the District of Workforce Shortage framework so that it measures actual service need and patient access, rather than relying on geographic proxies that no longer reflect where hospital-based care is delivered.

Reform must also address the cost of delivering specialist-led care in the private system. Private hospitals cannot maintain services where insurer contracting, second-tier default benefits and MBS settings do not meet the cost of safe care. Patients cannot access affordable specialist treatment where those settings force costs onto them or make services unavailable altogether.

Stronger insurer accountability, a mandatory code of conduct for hospital and insurer contracting, and benefit settings that support hospital-based specialist care are essential to improving both affordability and access.

Private hospitals must also be recognised as part of the specialist workforce solution. They deliver a substantial proportion of Australia's planned surgery, mental health, rehabilitation and other admitted care, and must be embedded in national workforce planning, specialist training placements and the design of emerging care models. Excluding private hospitals from these settings weakens the future workforce pipeline and limits the system's ability to use existing private infrastructure to meet patient need.

The Department's 2026 workforce modelling makes this point clearly. Australia may have enough doctors in aggregate, but not the right mix of specialists, registrars and hospital-based doctors in the right settings. A policy response that focuses only on headline workforce numbers will miss the structural bottlenecks that determine whether patients can access specialist care when and where they need it.

The Committee has an opportunity to recommend practical reforms that will unlock existing specialist capacity, improve affordability, strengthen the future workforce and reduce pressure on public hospitals. APHA encourages the Committee to adopt a comprehensive approach that treats private hospitals not as peripheral providers, but as essential partners in improving access to medical specialists for all Australians.

APHA's full submission is available at: Specialist Affordability - Options to Address Excessive Fees.

Previous Submissions:
24/8/2026 Senate Committee submission on changes to PHI for 65+ Australians