RACGP weighs in on future vaccination requirements

Matt Woodley

16/11/2020 3:25:08 PM

The college has commented on proposed changes that would compel GPs to report all newly administered vaccines to the Australian Immunisation Register.

Person holding a vaccine syringe
Some of the proposed changes would come into force from March next year, before being expanded further in July.

The current recording of vaccinations on the Australian Immunisation Register (AIR) is encouraged, rather than mandatory, which has resulted in vast under-reporting from some sectors.
The RACGP has identified this under-reporting as an area of ‘great concern’, as it can inhibit GPs’ ability to see what vaccines their patients have received and when they are next due.
As a result, the public submission signed by RACGP Acting President Associate Professor Ayman Shenouda is broadly supportive of the new proposal, which would initially apply to influenza vaccinations, vaccinations provided under the National Immunisation Program (NIP), and COVID-19 vaccinations, before being extended to all vaccinations by July 2021.
However, it contains several recommendations to ensure these changes would not affect patient access to vaccines, compromise privacy, or place undue financial burdens on providers.
It also argues that GPs and general practice nurses are ‘best placed’ to administer vaccines, particularly within the context of newly-developed coronavirus candidates.
‘In 2019, around 80% of all vaccine encounters on AIR were reported by GPs, showing already existing high uptake of the reporting function,’ Associate Professor Shenouda wrote.
‘The COVID-19 vaccination will have no post-marketing safety data and will need to be administered with full medical supervision to protect the Australian public.
‘It is vitally important with any new vaccine that record keeping is of the highest order, and patients are closely monitored by a qualified medical practitioner for potential adverse events, in the short and longer term.’
Some Australians could begin receiving new coronavirus vaccines as early as March 2021, with a goal of completing the rollout by the end of next year. The statement stresses the importance of not creating additional barriers that may stop people from coming forward to get vaccinated.
‘Patients must not be excluded from receiving a vaccine if they are not comfortable sharing their personal health information with the Australian Government,’ Associate Professor Shenouda wrote.
‘Any additional barrier may impact on the important public health measure of ensuring adequate population vaccination rates to achieve herd immunity.
‘GPs will need time to discuss these issues with their patients, and obtain consent, prior to uploading any information to AIR.
‘This presents an additional cost that will need to be supported by Government. It cannot be absorbed by general practice.’
In total, the college made seven recommendations to ensure the new requirements do not have any unintended negative consequences:

  • The Australian Government to provide a full and detailed privacy disclosure statement and consent form, with adequate guidance for GPs to provide to their patients
  • Patients should be able to opt out of reporting their personal information to AIR. A second-line option should be available for general practices to report completely de-identified information where a patient does not provide their consent
  • The Australian Government to provide additional funding, such an Immunisation Practice Incentive Payment, to support the increased time spent obtaining consent and uploading information to the AIR, as well as increased infrastructure costs associated with storing larger numbers of vaccines
  • The Australian Government to provide a patient communication plan and resources, with an implementation plan and provider education strategy, to support the changes
  • The Australian Government to support seamless integration of AIR reporting functions with commonly used general practice software
  • The Australian Government to introduce technology to support seamless upload of vaccinations administered outside of the general practice; for example, in residential aged care facilities
  • Compliance measures must focus on educative and supportive strategies, during and after the initial implementation of changes. Compliance measures must not negatively affect patient access to immunisations
The submission makes it clear that the college does not support punitive compliance measures described in the consultation paper aimed at increasing reporting rates.
‘There are many reasons which may impact on a GP’s ability to report a vaccine to AIR; temporary technological failure or limitations, lack of consent from the patient, or workforce shortages,’ Associate Professor Shenouda wrote.
‘GPs and general practices must not be penalised or prevented from providing future vaccines under these circumstances.
‘Instead, the focus should be on identifying the reason for under-reporting and finding solutions to improve reporting levels.’
Many of the vaccines captured by the proposed legislative changes may soon be produced in Australia, with Melbourne set to house the southern hemisphere’s largest flu vaccine manufacturing plant thanks to a new $1 billion deal struck between the Federal Government and CSL subsidiary Seqirus.
Seqirus is the only company that makes influenza and Q fever vaccines in Australia, while no other firm in the world produces life-saving antivenoms against 11 poisonous Australian snakes, marine creatures and spiders.
The plant, which will become operational by mid-2026, has been described as an important asset to help safeguard Australia against future pandemics.
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Dr Philip William Ousby   17/11/2020 4:36:11 PM

Are Pharmacies required to report vaccinations to the AIR?