How can Australia make specialist healthcare more accessible and affordable while maintaining the capacity to deliver it?
Submissions from the Council of Procedural Specialists (COPS), Australian Society of Ophthalmologists (ASO) and Australian Society of Anaesthetists (ASA) offer distinct perspectives on this question.
Presented to the parliamentary inquiry into access to and affordability of medical specialists in Australia, the submissions examine public hospital services, the economics of specialist practice, workforce planning and the costs patients face.
Together, they make the case for reform that addresses the full journey from referral to treatment.
COPS: expand public access and make better use of specialist expertise
COPS argues that improving access requires greater investment in public hospital specialist services and better use of the medical expertise already available.
Its submission challenges the proposition that recent increases in specialist fees adequately explain the difficulties some Australians experience accessing care. It instead highlights longstanding constraints on public sector capacity, including restricted operating time and limited public hospital appointments.
For orthopaedic surgery, COPS reports that specialists working as Visiting Medical Officers face restrictions on public elective operating sessions, while younger surgeons seeking public appointments encounter fewer opportunities.
COPS recommends restoring and expanding public hospital specialist clinics, increasing investment in hospital infrastructure, and creating more opportunities for younger specialists to work in the public system. It also proposes restoring Honorary Medical Officer roles so senior specialists can continue contributing.
Patient choice and clinical independence are central to its position. COPS supports informed financial consent and action against exploitative behaviour through existing consumer protection legislation. It also opposes insurance arrangements that provide lower rebates because a patient chooses a doctor outside an insurer’s preferred network.
The emphasis is on expanding access through cooperation with specialists while preserving patients’ freedom to choose their doctor.
ASO: affordability reform must account for the cost of providing care
The Australian Society of Ophthalmologists’ submission, A Transfer of Risk, examines whether proposed affordability measures would reduce healthcare costs or shift them elsewhere.
ASO argues that the Medicare rebate is a government contribution towards care, rather than a measure of the contemporary cost of delivering it.
Ophthalmology requires substantial investment in specialised equipment, technology, premises, staff, consumables, insurance and clinical governance. ASO warns that restricting patients’ Medicare benefits or using the Medicare Benefits Schedule to constrain private fees would not remove these underlying costs.
Its submission also examines the practical value of private health insurance. ASO recommends including cataract treatment as a minimum clinical category in Silver hospital policies and reviewing insurer benefits and gap-cover arrangements against the cost of providing care.
Regional access is another priority. ASO argues that workforce assessments should reflect actual patient catchments, travel distances, referral patterns and subspecialist expertise, rather than administrative boundaries alone.
Its proposed reforms include regular reviews of Medicare rebates, stronger public hospital capacity, improved regional workforce planning and an independent Private Health System Authority.
ASO’s central concern is that affordability measures should preserve the services and infrastructure patients depend on, rather than transfer additional financial risk to patients and providers.
ASA: connect workforce, funding and the patient’s pathway to treatment
The Australian Society of Anaesthetists approaches access and affordability through the complete patient pathway.
Its submission explains that having a registered specialist workforce does not automatically translate into available treatment. Specialists need funded positions, supporting clinical teams, diagnostics, operating theatres and beds. ASA describes this as effective specialist capacity.
Rather than simply arguing that Australia already has enough specialists, ASA identifies projected anaesthesia workforce shortages. It recommends a nationally coordinated workforce strategy, including funding at least 50 additional anaesthesia trainees each year, with one-third undertaking training in regional and rural Australia.
ASA also calls for clearer referral pathways. Patients and referring practitioners should receive confirmation that referrals have been received, information about triage status, indicative waiting periods and clear next steps.
On affordability, ASA distinguishes the specialist’s fee from the patient’s out-of-pocket cost. It recommends an independent review of Medicare and insurer benefit settings, including known-gap limits and other scheme rules.
ASA supports action against genuinely excessive charging, but argues that assessment must account for the complete episode of care, clinical complexity, procedure duration and anaesthesia billing arrangements. Responses should be specialty-specific and proportionate, while protecting patients’ Medicare benefits.
Bringing the perspectives together
The submissions identify different problems and propose different measures. Together, they offer a broader understanding of what makes specialist care accessible.
COPS focuses on public hospital access, patient choice and opportunities for specialists to contribute. ASO examines the financial sustainability of specialist care and the risk of shifting costs without addressing them. ASA connects workforce planning, service capacity, funding and continuity across the patient journey.
These perspectives point towards a coordinated reform agenda:
- Expand public treatment capacity, including specialist clinics, operating sessions, beds and supporting teams.
- Align workforce policy with each specialty’s needs, better using available expertise while addressing demonstrated shortages.
- Review Medicare and insurance funding, alongside specialist fees and the costs of delivering care.
- Give patients meaningful information about referrals, treatment options, benefits and likely out-of-pocket costs.
- Address exploitative charging fairly, using evidence and safeguards appropriate to the circumstances.
For COPS, the inquiry is an opportunity to develop practical reforms with the clinicians who deliver procedural care across Australia.
Success should be measured by whether patients can safely and promptly obtain the specialist assessment and treatment they need, at a cost they can afford.
Read the full submissions
For the detailed evidence and recommendations, download:
- Council of Procedural Specialists — Full submission (PDF)
- Australian Society of Ophthalmologists — A Transfer of Risk (PDF)
- Australian Society of Anaesthetists — Full submission (PDF)
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