Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697636881411.pdf (Australia)
The Sleep Management Group Pty Ltd Concord Private Hospital 55 Burwood Road Concord NSW 2137 Phone 02 8330 6430 Fax: 02 8587 0018 ABN: 72 127 689 374 Dear Parliamentary Inquiry, INQUIRY INTO SLEEP HEALTH AWARENESS IN AUSTRALIA By way of introduction I am the founder and director of The Sleep Management Group Pty Ltd we commenced the business in 2008 to allow an improved pathway for patients to access sleep studies to diagnose sleep disorders without the need to attend a hospital/Lab-based study we initially set up in Campbelltown NSW and have expanded from there.
I was associated with Healthy Sleep Solutions initially who prepared and lodged the MSAC submission for ambulatory sleep studies which was successful and allowed patients to access sleep studies at a much lower cost and without a hospital admission.

Some time ago Healthy Sleep Solutions was sold to Air Liquide and I have set up independently since then, we employ around 30 people.
The potential and known causes, impacts and costs (economic and social) of inadequate sleep and sleep disorders on the community; Sleep Disorders are one of the major health concerns in Australia.

It is estimated that 22.4% of the Australian population have a sleep disorder, including 8.3% having obstructive sleep apnoea (OSA).

OSA is associated with an increased risk of cardiovascular disease, stroke, dementia, depression, motor vehicle accidents and increased mortality1.
The total health system costs per year attributable to sleep disorders and their effects is $1.86 Billion AUD1.
Access to, support and treatment available for individuals experiencing inadequate sleep and sleep disorders, including those who are: children and adolescents, from culturally and linguistically diverse backgrounds, living in rural, regional and remote areas, Aboriginal and Torres Strait Islander; The gold standard diagnostic test for sleep disorders is an overnight sleep study, performed within a hospital sleep laboratory according to the Australasian Sleep Association.
This usually involves a 1-night admission to a private or public hospital.

Home diagnostic tests are available, they have limitations and they are not suitable for all patients, but they provide a more preferable and cost-effective way to allow access to a diagnostic test without needing to go to the expense both to the Government and the patient of a hospital sleep laboratory.
The Medicare item 12250 was introduced in 2008 some Sleep Specialists were supportive, but a great many were not as they “felt” that they would lose patients to other providers and that the sleep labs that they had invested in would become underutilised.

This was not the case the new item number allowed access to diagnostic testing to a much wider group of patients as cost to the patient was no longer a consideration and barrier for screening and diagnosis.
Unfortunately, the Sleep Physician’s undertaking home diagnostic studies (Medicare item 12250) have become a target for Medicare and the Professional Services Review committee.
1 Inquiry into Sleep Health Awareness in AustraliaSubmission 65 The Sleep Management Group Pty Ltd Concord Private Hospital 55 Burwood Road Concord NSW 2137 Phone 02 8330 6430 Fax: 02 8587 0018 ABN: 72 127 689 374 The providers (79 in total) received letters in February 2018 from Medicare is very high as it may represent around 20% of practising sleep physicians.

I do not believe there has been any other group targeted like this by Medicare?
There have also been media reports of sleep physicians overproviding services both in the lay media and medical media this leads to a reluctance of General Practitioners to refer patients due to “fear” of Medicare.
There has also been a proposal from government a proposal to limit access to sleep studies only to the proposed Gold tier of health insurance Limiting sleep studies to the Gold tier is likely to severely limit or prevent access of part of the population 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 among different sectors of the population.

Medicare on the 1st November have introduced new rules for GPs to request a sleep study under Medicare, GPs must now screen patients with 2 questionnaires to determine their eligibility for testing.

This is another barrier to testing as GPs will be reluctant to devote the time for the questionnaire and the questionnaire excludes a lot of patients that may have sleep disorders.
Medicare are making it difficult to diagnose patients rather than providing improved access to diagnosis and then treatment where necessary.

We have an operation in the New England area of NSW and provide both an ambulatory and lab-based facility in Tamworth our technician also conducts clinics in remote areas such as Moree and Narrabri.
We also employ 3 Chinese speaking technicians who work in Chinese communities to provide home based sleep studies we also employ Chinese speaking lab technicians for our sleep laboratory in Sydney.

Two of our consulting physicians are also Chinese speaking.

We receive very good support from GP’s in Chinese and remote communities.
Education, training and professional development available to healthcare workers in the diagnosis, treatment and management of individuals experiencing inadequate sleep and sleep disorders; We currently employ around 30 people in NSW, Qld, Victoria and the ACT, these range from university qualified Sleep Technicians to receptionists and support staff.

These technicians provide diagnostic sleep studies to patients under the supervision of Sleep Physicians who also provide training.
We also provide support to patients undergoing treatment most often with CPAP, this is not funded by Medicare.

We also have contractual arrangement with 7 Sleep and Respiratory physicians who consult patients in our rooms and provide training to our technical employees as well as oversee and report on our sleep studies conducted both home-based studies and laboratory based studies.
2 Inquiry into Sleep Health Awareness in AustraliaSubmission 65 The Sleep Management Group Pty Ltd Concord Private Hospital 55 Burwood Road Concord NSW 2137 Phone 02 8330 6430 Fax: 02 8587 0018 ABN: 72 127 689 374 Workplace awareness, practices and assistance available to those who may be impacted by inadequate sleep or sleep disorders, with a focus on: rostering practices for shift workers, heavy-work requirements, and the transport industry as compared to international best practice; and We have been a provider to Sonic to undertake sleep studies for at risk rail workers.
This is an area that is necessary for government to provide legislation and direction to ensure at risk professions are tested for sleep disorders currently we rely on a GP to refer a patient and the patient is under no obligation to undertake the sleep study if referred and remain a risk to themselves and the wider community.

Proposals 1.

That Medicare should be making it easier for General Practitioners to refer patients to undertake sleep studies.
A General Practitioner is the best judge to determine the need to test an at-risk patient who may have a sleeping disorder and then commence treatment where necessary.

Medicare are continually making it more difficult to allow patients to be referred for testing either by increasing the hurdles for referral or persecuting Sleep Physicians who undertake the studies.

2.
2.

That MSAC consider introducing a simpler diagnostic test, Level 3 sleep diagnostic test which could be done at a much lower cost to government.

This test could be interpreted by a General Practitioner and used as a simple screening tool to triage patients that may need simple treatment or referral to a sleep physician if a severe or complex condition is diagnosed.
The technology for sleep testing has improved dramatically over the last 5 years but the profession is still clinging onto old technology due to vested interests.

3.

That the TGA consider making CPAP machines only available with a Doctor’s prescription, currently any person can buy a CPAP machine from the internet or shops without any checks.
A CPAP machine is a medical device and needs to be correctly set to the right pressures and ongoing management by a trained professional is necessary for the patient to ensure compliance.

4.

It should be mandatory for professional drivers and machinery operators to undertake sleep studies and be treated if they have been diagnosed with a sleep disorder.

Currently this is not the case.

Yours truly, Robert Leslie Director The Sleep Management Group Pty Ltd 1 Asleep on the job.
Costs of Inadequate Sleep in Australia.

Sleep Health Foundation; Delolitte; 2017 3 Inquiry into Sleep Health Awareness in AustraliaSubmission 65