Consultation - Private Health Insurance Reforms, Tiers of Cover and Sleep Studies.
The Sleep Health Foundation recently became aware that the Department of Health is seeking public feedback on their planned reforms of private health insurance, due to come into effect from 1 April 2019. The reforms include mandating 4 tiers of hospital products – Gold, Silver, Bronze and Basic. We were not invited to have any input into the process and have only just become aware of the outcomes. Along with the ASA we are concerned that with these reforms, cover for sleep studies will be limited to Gold level cover policies.
The Foundation Board has submitted a formal response to this consultation (see below). However, we advise members and other interested parties to make their own individual responses. The documentation is available at: http://www.health.gov.au/internet/main/publishing.nsf/Content/exposure-draft-subordinate-legislation-private-health-insurance-reforms-amendment-rules-2018 .
Dear sir/madam
Private Health Insurance Reform Amendments
I am writing to you on behalf of the Sleep Health Foundation (‘The Foundation’), of which I am Chair, to express our serious concerns with the proposal to restrict access to private insurance rebates for sleep studies to the proposed Gold tier of health insurance.
The Foundation (www.sleephealthfoundation.org.au), as the major national advocate for sleep health, is very disturbed about restricting access to investigation of sleep disorders, which are common and associated with serious impacts on health, safety, productivity, well-being and mood.
Sleep disorders are one of the major health concerns in Australia. Until recently, their health and economic effects have been seriously underestimated and it is particularly disturbing that just as these impacts are becoming widely appreciated there is this move to restrict access to an important aspect of their diagnosis.
It is estimated that 22.4% of the Australian population have a sleep disorder, including 8.3% having obstructive sleep apnoea (OSA), a condition where study of overnight sleep is an essential component of diagnosis. OSA is associated with an increased risk of cardiovascular disease, stroke, dementia, depression, motor vehicle accidents and increased mortality1. The amount spent on investigating and treating this problem, and other sleep disorders, is little relative to the huge costs of leaving them untreated in terms of the cost of managing medical co-morbidities (heart d, stroke, diabetes, depression, workplace and vehicle accidents), non-medical accident costs, costs of informal care, productivity losses and loss of well-being. In a 2010 analysis of the economic cost of sleep disorders undertaken by Deloitte Access Economics on commission from the Foundation, it was estimated (using conservative prevalence estimates) that the total cost of OSA (financial and non-financial) to the community was $21.2 billion per annum yet only $250 million per annum was spent identifying and treating it.1 This huge imbalance between expenditure on the condition and the costs of it if left untreated emphasises the economic danger of investing even less in pursuing this enormously costly condition.
The gold standard diagnostic test for sleep disorders is an overnight sleep study, performed within a hospital sleep laboratory. This usually involves a 1 night admission to a private or public hospital. Although home diagnostic tests are available, they have limitations and they are not suitable for all patients.
While we support the concept of simplifying private health insurance we are seriously concerned about the classification of sleep studies in the draft hospital treatment product tiers of the Private Health insurance reform amendments. We note that sleep studies are proposed to be limited to those who hold policies classified as Gold tier. Limiting sleep studies to the Gold tier is likely to severely limit or prevent access of part of the population to an appropriate diagnosis of their sleep disorder, and put additional stress on the public hospital system, which already has demand for sleep services exceeding supply. This will create inequity of access to sleep diagnostic testing among the population.
At the Sleep Health Foundation, we work with a number of self-help groups including:
• Sleep Disorders Australia
• Narcolepsy Australia
• NODDS
• Hypersomnolence Australia
whose personal perspectives underline the importance of supporting the need to identify and treat sleep disorders in the wider community.
We have found that often people with sleep disorders have limited finances due to an inability to maintain full time work. Limiting sleep studies to the Gold tier is likely to severely limit or prevent access of these and other community members to an appropriate diagnosis for their sleep disorder, and put additional stress on the public hospital system, which already has demand for sleep services exceeding supply. This will create inequity of access to sleep diagnostic testing across different sectors of the population.
The Sleep Health Foundation strongly recommends re-classifying sleep studies to allow them to be covered by all tiers of private health insurance, in order to provide equity of access to diagnosis and treatment for these extremely common medical sleep disorders.
Yours sincerely
Emeritus Prof Dorothy Bruck
Chair, Sleep Health Foundation
1 Re-awakening Australia. The economic cost of sleep disorders in Australia. Deloitte Access Economics, 2010. Available at: https://www.sleephealthfoundation.org.au/pdfs/news/Reawakening%20Australia.pdf