In this report we analysed proposed changes to Victoria’s Health Service Establishment Regulations
Private health hospitals, day procedure centres and mobile health services (known as health service establishments) are a significant part of health service delivery in Victoria. They are facilities where patients are treated by a doctor of their own choosing and pay a fee for services (patients may have private health insurance to cover costs). In 2021-22, 1.08 million separations in Victoria occurred in private hospitals, which is 37% of all hospital separations (A separation is when an admitted patient’s episode of care ends).
Registered health service establishments in Victoria must comply with minimum regulations for patient safety and care. The Health Services (Health Service Establishments) Regulations 2024 set requirements for key drivers and safeguards of quality and safety, including in relation to:
- clinical governance
- systems and processes for monitoring, maintaining and improving quality and safety of services
- qualifications and competence of staff and adequacy of workforce
- clinical assessments
- clinical records
- premises and equipment
- reporting.
“While most healthcare in Victoria leads to good safety and quality outcomes, this is not always the case. Patients are not able to assess and control many relevant risk factors when seeking and receiving treatment, so they rely on effective safety and quality systems to be in place to ensure risk of harm is minimised.”
– Sapere
Our Regulatory Impact Statement (RIS) report for the Victorian Department of Health reviewed the effectiveness and efficiency of current Regulations and investigated the impact of proposed changes to clinical governance, sentinel events reporting and review, admissions assessment, and infringement penalties.
The proposed changes to the Regulations build on the program of regulatory reform that has been occurring in the Victorian health sector in recent years since Targeting Zero – supporting the Victorian hospital system to eliminate avoidable harm and strengthen quality of care: Report of the Review of Hospital Safety and Quality Assurance in Victoria (2016).
We also provided advice to the Department on potential changes to fees charged for applications for private health service establishments.
The RIS outlined the nature of the problem being addressed, explored different options, quantified key costs and benefits of the options, and examined small business and competition impacts.
Options were assessed against the following criteria:
- protects the safety and quality of care of patients receiving health services in HSEs
- cost to HSEs; and cost to government.
The RIS was published for public consultation in August 2023 and the Department of Health subsequently released new Health Services (Health Service Establishments) Regulations 2024.
Our team included:
- Sally Carrick
- Michelle Hall
