May 2015 Proposed Changes to Practitioner Fees Payable to the Medical Sciences Council of New Zealand

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CONSULTATION

DOCUMENT

Proposed Changes to Practitioner

Fees Payable to the Medical Sciences

Council of New Zealand

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RELEASED ON 22

ND

_{MAY 2015}

SUBMISSIONS DUE 17

TH

_{JULY 2015}

Purpose of this Consultation

The Medical Sciences Council (the Council) is proposing an increase to various practitioner fees and this document sets out the proposed fees schedule in detail and the reasons for those changes. Practitioners and key stakeholders are invited to comment on the proposed fees. All comments will be considered by the Council prior to a final decision being made.

The proposed fees changes will not take effect until the Council’s 2016-2017 financial year which commences on 1st_{April 2016.}

Practitioner Fees in Context

The Council operates within the health regulation framework under the Health Practitioners Competence Assurance Act 2003 (the Act). As a not-for-profit body the Council’s operational revenue is derived from fees (such as registrations and annual practising certificates) and those fees are set in alignment with the Council’s annual budgets. There is no general taxpayer contribution to any of its operations. Practitioner fees are set by the Medical Sciences Council under sections 130 and 131 of the Act.

The Council continually reviews its operations to ensure it provides best-value-for money and does this within the good practice guidelines of both the Office of the Auditor General and the Treasury. A conscious effort is taken to minimise costs without compromising the Council’s responsibilities in performing its functions under the Act. It is critical for the Council to be fiscally reliable so it can continue to meet its legislative responsibilities into the future.

Proposed Fees Changes

Practitioner fees set by the Council have remained unchanged since 2008 despite a steady increase in operating costs over successive years. The Council has achieved this by funding operating costs from its accumulated operational surplus. However the level of available funds is now at a point where the Council can no longer continue to meet its operational costs whilst maintaining the same level of income. Subsequently the Council is proposing to increase the various fees for practitioners so it can continue to meet its responsibilities in protecting the health and safety of the New Zealand public.

The following table provides a summary overview of the current fees set by the Council and the fees it is proposing to introduce.

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Fees Table 1: Annual Practising Certificate and Registration

Scope of Practice Fee Type Current Proposed

Annual Practising Certificate

Anaesthetic Technician

Issued between 1 Apr – 31 Mar

$345.00 $345.00 Issued between 1 Oct – 31

Jan (new registrant)

$172.00 $172.00 Issued between 1 Feb – 31

Mar (new registrant)

$0.00 $0.00 Late Renewal $483.00 Medical Laboratory

Scientist

$175.00 $275.00 Issued between 1 Dec – 31

$0.00 NA Issued between 1 Oct – 31

$137.50 Issued between 1 Feb – 31

$0.00 Late Renewal $385.00 Medical Laboratory

Technician

$140.00 $275.00 Issued between 1 Dec – 31

$0.00 NA Issued between 1 Oct – 31

$137.50 Issued between 1 Feb – 31

$0.00 Late Renewal $385.00

Scope of Practice Fee Type Current Proposed

Registration

Anaesthetic Technician

New Zealand $390.00 $350.00 Overseas $529.00 $550.00 Work Based Assessment $3,400.00 Medical Laboratory Scientist New Zealand $230.00 $350.00 Overseas $480.00 $550.00 Medical Laboratory Technician New Zealand $120.00 $350.00 Overseas $350.00 $550.00

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Fees Table 2: Other

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Supply of Documents

Fee Type Current Fee Type Proposed

Medical Laboratory Science

Issue of a certificate of registration $45.00 Issue of a certificate of registration (additional to initial confirmation of registration)

$60.00 Issue of a certificate of registered

information

$45.00 Any other document certifying registration status or standing

$60.00 Supplying a medical laboratory scientist or

medical laboratory technician with any document for the purposes of seeking registration overseas

$100.00 Supply of documents for the purpose of seeking registration overseas

$120.00

Issue of a replacement annual practising certificate declared lost

$50.00 Issue of a replacement and/or duplicate annual practising certificate

$60.00

Anaesthetic Technology

Issue of a certificate of registration (additional to initial confirmation of registration)

$57.50 Issue of a certificate of registration (additional to initial confirmation of registration)

$60.00 Any other document certifying registration

status or standing

$57.50 Any other document certifying registration status or standing

$60.00 Supply of documents for the purpose of

seeking registration overseas

$115.00 Supply of documents for the purpose of seeking registration overseas

$120.00 Issue of a replacement and/or duplicate

annual practising certificate

$57.50 Issue of a replacement and/or duplicate annual practising certificate

$60.00

Accreditation

Medical Laboratory Science

Fee for carrying out an accreditation review of an undergraduate degree programme

$12,000.00 Council does not set a standard fee for carrying out an accreditation review of a New Zealand education provider, training hospital, or examination provider, but will instead issue an itemised invoice for reimbursement of costs associated with the accreditation review. All such invoices are calculated

on a cost-recovery basis only.

No pre-determined fee

Fee for carrying out an accreditation of laboratory-based medical laboratory technician training courses provided by a single education provider

$1,500.00 NA (included in definition above)

Anaesthetic Technology

Council does not set a standard fee for carrying out an accreditation review of a New Zealand education provider, training hospital, or examination provider, but will instead issue an itemised invoice for reimbursement of costs associated with the accreditation review. All such invoices are calculated

No pre-determined fee

1_{The fees contained in this table are applicable to all scopes of practice within the professions of medical laboratory science and}

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Considerations When Setting the Proposed Fees Changes

The Council noted a number of factors when considering whether practitioner fees should increase:  The Council has a responsibility to ensure it remains fiscally strong to continue to meet its

legislative functions and responsibilities.

- Practitioner fees have remained at the same level since 2008 despite increased costs over this 7-year period. The Council made a conscious decision during this time to make every effort to avoid any increase to practitioner fees. Managing any shortfall between each successive year’s income and expenditure was achieved through using money ordinarily tagged for special projects and contingency purposes.

- Subsequently the level of “special projects and contingency” funds held by the Council has decreased significantly over the last few years. The Council’s current level of revenue (inclusive of both annual fees income and cash reserves) cannot sustain the required level of expenditure over the next 3-year period.

- In addition to annual budgets being set to accommodate increasing compliance costs, the Council’s income has been impacted by a reduction in registrant numbers which is a reflection of the ongoing rationalisation of health workforces nationwide.

- Budget projections identified that a relatively small amount of accumulated operational surplus would be carried forward into the 2016-2017 business year. However after that, the annual year-end projections are that the Council will have no operational surplus and the annual income generated through practitioner fees would be less than the expenditure required for the Council to meet all of its required business activities.

- Cost efficiencies are being achieved through the single secretariat (Medical Sciences

Secretariat) which the Council jointly owns with the Medical Radiation Technologists Board. - Annual practising certificate fees for anaesthetic technicians remain unchanged. This is due to the relatively small number of practitioners within this profession and the need to keep the bulk of annual income at a level that aligns with the forecasted expenditure for this profession for the next three years.

- Currently fees within the medical laboratory profession are set at different levels. This is based on a historical decision of the Medical Laboratory Science Board to set medical laboratory technician fees at a lower rate than medical laboratory scientists due to differentials in the salary structures for those two practitioner groups.

- It is inappropriate to continue to set fees based on workforce salaries. The resources required to manage practitioner applications vary according to the type of application and this is irrespective of the particular scope of practice. Subsequently all proposed fees for the medical laboratory science profession are based on the particular type of application and then applied to each scope of practice.

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- Proposed fees include the introduction of a partial fee for practising certificates for the medical laboratory science profession (this is already in place for anaesthetic technicians). Currently registrants are issued with their first APC following registration at no cost if applied for between December and March. This is a continuation of the previous Medical

Laboratory Technologists Board pre the HPCA Act in an effort to lessen the financial burden for new registrants. The Council is proposing to charge all practitioners the appropriate fee for a practicing certificate to avoid cross subsidisation of fees from other practitioners. Issuing of practising certificates incurs costs for the Council irrespective of whether it is a first certificate or renewal of a certificate and the time of issue. While the Council operates within a not-for-profit framework that does not mean they can be expected to operate at a loss. The issue of all practising certificates should therefore be subject to a fee. However a partial fee allows for a degree of recompense for those new registrants applying for their first APC close to the end of the relevant APC year.

- Introduction of a late renewal fee reflects the additional work required to manage late applications for renewal of an annual practising certificate.

- Fee increases also reflect the increased volume and complexity relating to competence, conduct and health activities.

- Over the last 1-2 years there has been an increase in the level of scrutiny required in respect of overseas applications especially as a significant number of these are from countries with non-comparable healthcare systems.

Alignment of Proposed Fees with Annual Budgets

The proposed fees have been calculated in accordance with the Council’s budget projections for the 3-year period commencing 1st_{April 2015 through to 31}st_{March 2018.}

It is proposed that fees would remain static for the current financial year (that is, 1st_{April 2015 to}

31st_{March 2016), with the proposed fee changes coming into effect for the Council’s 2016-2017}

financial year.

Subsequently it is intended that the proposed fees would remain in place until the close of the Council’s 2018 business year (that is, 31st_{March 2018). This is based on an assumption that there}

will be no significant increase in respect of the expenditure allocated to cover professional standards activities such as disciplinary investigations and hearings.

That said, the Council will continue to review its financial status at regular intervals and should there be a strong likelihood for expenditure to be significantly lower than forecasted, consideration will be given to a reduction in fees for the next financial year.

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Budgets 2015 - 2018

Income 2015 - 2016 2016 - 2017 2017 - 2018 Annual Practising Certificates $648,082 $1,036,022 $1,036,022 Registrations – Overseas $22,980 $29,636 $29,636 Registrations - NZ $31,400 $115,2162 _$54,416 Registrations - Other $1,000 $1,000 $1,000 Interest $28,000 $25,000 $20,000 Education - accreditation reviews $29,200 $29,200 $29,200 Examinations - $11,828 $11,828 Total Income $760,662 $1,247,902 $1,182,102 Expenditure 2015-2016 2016-2017 2017-2018

Council Fees and Expenses $317,918 $320,804 $352,550 Competence Conduct and Health $122,800 $135,080 $148,588 Secretariat Operations $536,739 $538,648 $549,419

Projects from strategic plan

$231,771 $38,750 $32,810

Total Expenditure $1,209,228 $1,033,282 $1,083,367

Net Surplus/(Deficit)3 _($448,566) _$214,620 _$98,735

2_{2016-2017 NZ registration income based on assumption of inclusion of new group of registrants}

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Key Budget Assumptions

The Medical Sciences Council 2015-2018 budgets have been based on a number of key assumptions including:

- Fees paid to Council members and advisors engaged by the Council will remain static for the 3-year period.

- Expenses-related costs include an annual 2% general increase (with the exception of Competence Conduct and Health related activities).

- Competence Conduct and Health related activities include an annual increase of 10%. This is to allow for potential increases in the volume and/or complexity of competence, conduct, and/or health notifications. This measure is aimed at avoiding having to introduce an increase via a disciplinary levy.

- The number of projects is significantly higher in 2016-2017 compared to other years within this 3-year budget cycle. This is due to the need to re-invest in strengthening core

infrastructure including improvements in technology and secretariat facilities.

- While APC fees for anaesthetic technicians has been held constant for the next three-year period annual income is still lower than total forecasted expenditure for this profession. The shortfall will be managed through reducing the current level of accumulated operational surplus as tagged against anaesthetic technician income and expenditure.

Conclusion

The objective of this consultation is to seek feedback from stakeholders to help the Council make a final decision in respect of the proposed fees schedule for the professions of medical laboratory science and anaesthetic technology.

The Council invites written comments on the proposed fees by Friday 17th_{July 2015}_{after which all} submissions will be considered by the Council at their meeting on 26th_{August 2015.}

Please email your comments to the following address: admin@medsci.co.nz

Yours sincerely

Mary Doyle