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Whistleblowers are ‘unreasonable’ people – “Unsafe At Any Speed!”

It’s been just over 50 years since a young lawyer from Connecticut named Ralph Nader published a book about the American automotive industry titled, Unsafe At Any Speed: The Designed-In Dangers of the American Automobile.

As a whistleblower, Nader should have been prepared for the retaliatory backlash from the politically conservative automotive giants because they would not be pleased by what he had to say in his book.

Nader was put under surveillance, his phone was tapped and prostitutes were hired by General Motors in an attempt to entrap the young man, apparently to no avail.

So why did General Motors go to such great lengths to discredit Nader?

One would only have to start by reading the first chapter in his book which was titled, “The Sporty Corvair – The One-Car Accident”.

This chapter featured a discussion of the safety and handling characteristics of the 1960 to 1963 rear-engine Chevrolet Corvair.

 

It seems that the car was prone to dangerous over-steer because of its swing-axle configuration and the absence of $6 per car anti-sway stabilizers which were left out due to cost-cutting.

General Motors had even ignored the advice of its own engineer (George Caramagna) that the anti-sway bars should come as standard – though they were offered as an option.

A subsequent 1972 review by the National Highway Safety and Traffic Administration did eventually find that the 1963 Corvair was “no less safe” than its contemporary rivals, the Ford Falcon and Plymouth Valiant.

But the rest of Nader’s book was still on fire about hood ornaments which might seem to be designed to impale unsuspecting pedestrians, non-standardized gear shift selectors which could inadvertently send the car backwards, shiny chrome-plated and non-padded dashboards that dazzled drivers’ eyes, and sharp knobs and switches that speared passengers.

Manufacturers were obsessed with styling and horsepower and didn’t think that safety would sell.

They believed that crashes were caused by bad drivers and bad driving.

The United States was falling way behind European manufacturers who were fitting radial-ply tyres and disc brakes which were actually saving people’s lives.

Nader pointed out that Volvo could make a profit and sell cars with three-point seatbelts.

It really looked like Nader’s book was going to be bad for business, with the final chapter suggesting that, “the automotive industry should be forced by government to pay greater attention to safety in the face of mounting evidence about preventable death and injury”.

At the time about 1000 people per week were being killed in US traffic crashes.

The US Government did eventually take notice and on 9 September 1966 the National Traffic and Motor Vehicle Safety Act was enacted to empower the Federal Government to set and administer new safety standards for motor vehicles and road traffic safety.

In the 50 years since the US legislated safety standards automotive fatalities have reduced from 5.50 deaths per 100 million vehicle miles travelled to 1.07.

Unsafe At Any Speed was undoubtedly a public health success story.

So whatever happened to Ralph Nader?

His continued political activism has produced more legislation including the Freedom of Information Act, Foreign Corrupt Practices Act, Clean Water Act, Consumer Product Safety Act, and the Whistle-blower Protection Act

He has run for US president many times since 1972.

His candidacy in 2000 may have unwittingly granted George W Bush the top job when Al Gore fell 537 votes short in Florida on a split liberal/Democrat vote.

Nader has been affectionately described as “An Unreasonable Man”.

According to George Bernard Shaw, “The reasonable man adapts himself to the world; the unreasonable one insists on trying to adapt the world to himself. Therefore, all progress depends on the unreasonable man”.

Safe motoring,

Doctor Clive Fraser

PS Ralph Nader catches public transport and does not own a car.

 

Bonds loosened on rural doctors

The Federal Government has relaxed the rules surrounding return of service obligations on doctors working in bonded placements, in a decision hailed by AMA President Dr Michael Gannon as a victory for common sense.

Health Minister Sussan Ley has responded to representations from the AMA by directing the Health Department to take a more flexible approach when applying return of service obligations on medical graduates enrolled in the Bonded Medical Places (BMP) program and the Medical Rural Bonded Scholarship Scheme (MRBS).

The move means that BMP and MRBS doctors will no longer be prevented from travelling to metropolitan areas for extra training or instruction.

Dr Gannon said the policy shift addressed a damaging and unintended consequence of the obligation rules.

“The Department was previously bound by rigid guidelines to applying these return of service obligations, often leading to outcomes that made little sense,” the AMA President said. “Doctors who clearly were committed to their rural patients and more than meeting their obligations found that they were being essentially blocked from undertaking extra training or keeping up their clinical skills, simply because they would have to go to a city for a brief period to do so.”

Under the original terms of the BMP program, doctors were required to complete a period of eligible service in a rural area or district of workforce shortage equivalent to the length of their medical degree. MRBS graduates were required to complete at least six years eligible service in a rural area.

Related: National rural generalist program key to retention

Former AMA President, Professor Brian Owler, wrote to the Government last year highlighting that the rigid application of return of service obligations was having an unfair effect on participants who were trying to meet these obligations, particularly when they needed to undertake up-skilling and further training in a metropolitan area.

The AMA Council of Rural Doctors has previously identified the importance of rural doctors being able to access opportunities to up-skill in metropolitan centres from time to time.

The Council said such opportunities were vital to support sustainable, high quality, medical care and enable practitioners to share skills and knowledge with their rural colleagues, including doctors in training.

Dr Gannon said return of service arrangements were never intended to be an impediment to this, and the new, more flexible approach taken to their application was an important piece in the puzzle for supporting high quality rural health services.

Under the new policy approach, Health Department officials will have greater scope to approve requests by participants to undertake work in a broader range of areas, provided they are otherwise meeting their return of service obligations.

Dr Gannon urged a sensible approach to the more flexible arrangement.

“It is important that the Department of Health takes a practical approach when it applies the new policy so that it supports doctors who are committed to working in areas of workforce shortage,” he said.

“By taking steps that support a good working experience, this will encourage them to commit to long term practice in these areas – for the benefit of local communities.”

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Hospitals could pay for mistakes

Public hospitals would be charged for mistakes that seriously harm or kill patients and penalised for avoidable readmissions under reforms being developed at the behest of Health Minister Sussan Ley.

Ms Ley has directed the Independent Hospital Pricing Authority (IHPA) to model how funding and pricing could be used to cut the cost to the Commonwealth of so-called sentinel events such as operating on the wrong body part, incompatible blood transfusions, deadly medication errors, sending a baby home with the wrong parents or patient suicide.

The Authority has also been asked to look at ways to penalise hospitals that exceed a predetermined rate for avoidable readmissions.

The move coincides with the release of draft Productivity Commission proposals to publicise treatment outcomes for individual hospitals and doctors as part of measures to boost competition and contestability in the provision of health care.

In a consultation paper released on 30 September, IHPA said that incorporating safety and quality measures into pricing and funding models signalled the value Government attached to high quality care.

“Financial incentives can encourage a strengthened focus on identifying and reviewing ways in which the safety and quality of public hospital care can be improved. This can ensure that pricing and funding approaches are aligned with other strategies to improve safety and quality,” the Authority said.

It said activity-based funding was often criticised for emphasising the volume of services rather than their quality or appropriateness, and increasing attention on sentinel events and avoidable readmissions could counter this.

Ms Ley has asked IHPA to present its options to the COAG Health Council by 30 November.

This would mean they could be incorporated into a new funding model for sentinel events and preventable hospital-acquired conditions that has been foreshadowed to come into effect from 1 July next year.

But hospital funding remains a huge political football between the Federal and State levels of government.

Although a pledge by Prime Minister Malcolm Turnbull of an additional $2.9 billion in Commonwealth funding to 2020 helped mute public hospital services as an issue during the Federal election, long-term funding arrangements remain unresolved and are a point of tension between the two levels of government.

It makes a challenging setting for preliminary Productivity Commission (PC) proposals to increase information disclosure by hospitals and doctors and greater contestability between human services, including public hospitals.

While Australian public hospitals performed well by international standards, “there is scope to improve”, the PC said, including by matching domestic best practice and publicly disclosing more information.

“Public patients are often given little or no choice over who treats them or where. Overseas experience indicates that, when hospital patients are able to plan services in advance and access useful information to compare providers (doctors and hospitals), user choice can lead to improved service quality and efficiency,” the PC said.

It said that any reforms to boost user choice would have to be supported by “user-oriented information”, and suggested the English model in which increased choice is offered at the point where GPs refer patients to a specialist.

The Commission said experience in England had shown that patients given a choice of hospital and consultant-led team sought out better performing providers, and hospitals in locations where competition was most intense recorded the biggest improvements in service quality.

In order to exercise their choice, patients had access to web-based information enabling them to compare providers according to waiting times and mortality rates, and could use an online booking service.

“Greater competition, contestability and informed user choice could improve outcomes in many human services,” the PC said. “Well-designed reform, underpinned by strong government stewardship, could improve the quality of services, increase access…and help people have a greater say over the services they use and who provides them.”

Treasurer Scott Morrison said he had ordered the review to improve the efficiency and cost effectiveness of human services.

But Opposition leader Bill Shorten, reprising Labor’s scare campaign during the Federal election on the privatisation of Medicare, said he feared it would be used to justify the wholesale handover of human services to the private sector.

“We’ve all seen this move before,” Mr Shorten said. “When Malcolm Turnbull and the Liberal Party start talking about changing human services it means that poor people get it in the neck.”

The Commission said that not all human services were amenable to increased competition, contestability and choice, but identified public hospitals and palliative care services among six priority areas targeted for reform.

The enormous variety of Australia’s public hospitals, including big differences in the populations they serve, workforce arrangements and characteristics and the complexity of their links to the rest of the health system, militate against like-for-like competition – something the Commission admitted.

If such issues or political considerations made fostering direct competition unfeasible, the Commission instead suggested exerting pressure for improved performance by making the position of senior hospital managers more precarious.

“There have been difficulties in the past commissioning non-government providers, and lessons from these attempts should not be forgotten,” it said. “As a result, it may be more feasible to implement contestability as a more transparent mechanism to replace an underperforming public hospital’s management team (or board of the local health network) rather than switch to a non-government provider.”

The PC’s preliminary report is open for submissions until 27 October, and the Commission is due to deliver its final report by October 2017.

 Adrian Rollins

Medicare data breach prompts law change

The Federal Government has moved to tighten privacy laws after doctor provider numbers were disclosed in a breach of security around Medicare and Pharmaceutical Benefit Scheme data.

Attorney-General George Brandis has announced plans to amend the Privacy Act to make it a criminal offence to re-identify de-identified Government data following a discovery that encrypted MBS and PBS data published by the Health Department had been compromised.

The Department was alerted on 12 September to the worrying security lapse by Melbourne University Department of Computing and Information researchers Dr Chris Culnane, Dr Benjamin Rubinstein and Dr Vanessa Teague, who found they were able to decrypt some service provider ID numbers in the publicly available Medicare 10 per cent dataset. They immediately alerted the Department.

In a statement, the Department said no patient information had been compromised in the incident.

“The dataset does not include names and addresses of service providers, and no patient information was identified,” the Department said. “However, as a result of the potential to extract some doctor and other service provider ID numbers, the Department of Health immediately removed the dataset from the website to ensure the security and integrity of the data is maintained.”

But Shadow Health Minster Catherine King questioned why it had taken the Government 17 days to reveal the security breach, and voiced concerns that there may have been 1500 downloads of the dataset before it was withdrawn by the Department.

“The Government’s 17 day delay in admitting to a breach of health data under their watch is unacceptable,” Ms King said.

Notice of the breach came as a Senate inquiry heard concerns about data security surrounding the decision to award Telstra Health $220 million contract to design and operate the National Cancer Screening Registry, and follows the collapse of Australian Bureau of Statistics systems on census night.

The AMA said that although the data security breach was concerning, it should not result in governments withholding data from being available for research and policy development.

The Association said that although it was paramount that personal information be properly secured and protected, it was important that de-identified and encrypted data be made available by Government to help inform research and the analysis of health information.

Senator Brandis reassured that the Government remained committed to making valuable data publicly available.

“The publication of major datasets is an important part of twenty-first century government providing a great benefit to the community,” the Attorney-General said. “It enables…policymakers, researchers and other interested persons to take full advantage of the opportunities that new technology creates to improve research and policy outcomes.”

But Senator Brandis said that advances in technology had meant that methods used in the past to de-identify data “may become susceptible to re-identification in the future”.

Under his proposed changes to the Privacy Act, it would be a criminal offence to re-identify de-identified Government data, encourage someone else to do it, or to publish or communicate such data.

The Health Department said it was conducting a “full, independent audit” of the process followed in compiling, reviewing and publishing the data, and promised that “this dataset will only be restored when concerns about its potential vulnerabilities are resolved”.

The Office of the Australian Information Commission is undertaking a separate investigation.

Adrian Rollins 

NHS dispute leaves bitter divide

National Health Service trusts across England have begun phasing in a controversial employment contract for junior doctors in the latest setback for medical staff protesting the deal.

Less than a week after the British Medical Association’s junior doctor committee abandoned plans for a series of five-day strikes, NHS employers began signing up staff to a single national contract to cover all 54,000 doctors below consultant level employed by the NHS.

The move came after a last-ditch bid to have the actions of British Health Secretary Jeremy Hunt in pushing forward the contract declared illegal failed.

Picture credit: William Perugini / Shutterstock.com

Late last month a judicial review threw out claims by the group Justice for Health that Mr Hunt had acted beyond his powers by seeking to impose the contract despite its overwhelming rejection by junior doctors.

Within days, the BMA dumped plans for a rolling series of stoppages, but junior doctor committee chair Dr Ellen McCourt vowed that the fight was not over.

Dr McCourt said the BMA had not accepted the contract and was considering a range of options to force changes to address outstanding concerns.

The dispute flared last year when Mr Hunt announced plans to introduce a single national contract for NHS junior doctors that included a controversial clause for round-the-clock seven-day roster without any additional compensation.

The contract was overwhelmingly rejected by junior doctors in a vote late last year, which they followed up with an unprecedented series of strikes in the first half of 2016.

Following negotiations, a compromise deal that had the backing of the BMA leadership was also rejected by the junior doctors, and Mr Hunt declared an end to talks, instead moving to impose the contract.

But, even though the threat of five-day strikes has receded, the dispute has created enormous ill-will, according to Dr McCourt.

“Morale among junior doctors is at an all-time low,” she told The Guardian. “[There is] a deep sense of anger and mistrust that has built up towards the Government over the last year.”

There are concerns the dispute will speed the exodus of younger doctors from the UK.

A survey of 420 doctors who have studied medicine in the past decade found 42 per cent intended to practise overseas, saying their current experience as a doctor was worse than they expected when they graduated. A further 16 per cent reported they had “taken a break” from medicine.

Dr McCourt told the Daily Express the findings were unsurprising.

“We have been saying for some time that morale amongst doctors is at an all-time low and these figures show, once again, that doctors are on a knife edge,” she said. “They are reaching their limit, and if stretched any further, they will walk. Given the results of this study, it makes no sense for the Government to rush the implementation of the junior doctor contract, which will only make things worse.”

The threat of an exodus of locally-trained doctors has been compounded by the prospect that Britain will find it harder to attract foreign doctors following the Brexit vote.

Mr Hunt has announced plans to add 1500 medical school places a year in an effort to make the NHS in England “self-sufficient” in doctors after Britain leaves the European Union.

Adrian Rollins

Ley refuses to set rebate freeze end date

Health Minister Sussan Ley has dumped on hopes of an imminent end to the Medicare rebate freeze, warning that it will not be lifted until there is an improvement in the Federal Government’s finances.

Talking down the prospects of financial relief for hard-pressed medical practices any time soon, Ms Ley refused to set a date for an end to the policy, and told ABC radio’s AM program that “we cannot lift the pause…any earlier than our financial circumstances permit”.

The Minister said any decisions made about the freeze would be made in the context of Budget discussions.

“I’m a Minister who signs up to the agenda of a Government that leads Budget repair and strong, stable economic management, so I’m absolutely not walking from our responsibilities,” she told Sky News. “These are decisions that are made through the MYEFO [Mid-Year Economic and Fiscal Outlook] and Budget process, and I’m not going to forecast when or what they might be.”

The Government is due to release the 2016-17 MYEFO before the end of the year, most likely early December.

Ms Ley backed away from comments she made during the Federal election that she had been blocked from ending the freeze by her senior Treasury and Finance colleagues.

In May, Ms Ley told ABC radio that: “I’ve said to doctors I want that freeze lifted as soon as possible but I appreciate that Finance and Treasury aren’t allowing me to do it just yet.”

But when ABC reporter Kim Landers said to the Minister today that, “you’ve previously said that you’ve wanted to lift it, but you were blocked by Treasury,” Ms Ley denied it.

“That’s not what I’ve said. What I’ve said is: as a responsible Minister in a Government that needs to undertake budget repair, I recognise that we cannot lift the pause that was introduced by Labor any earlier than our financial circumstances permit,” the Health Minister said.

The exchange came amid mounting warnings from the AMA and others that the rebate freeze is pushing medical practices to the financial brink, forcing many to abandon bulk billing and raising the prospect that patients will be charged up to $25 in out-of-pocket costs.

Ms Ley defended the rebate freeze as the right policy for the times, and said bulk billing rates had “never been higher”.

The Minister’s declaration, which is based on figures measuring the number of Medicare services performed rather than GP consults, has been disputed by those who claim that the real figure is closer to 69 per cent.

Regardless, AMA President Dr Michael Gannon expressed disbelief the rebate freeze would still be in place by the time of the next election in late 2019.

“I would be gobsmacked if the Government took an ongoing freeze to the next election,” the AMA President said following a meeting with Ms Ley earlier this year. “They got the scare of their life on health, and that was probably the policy which hurt them the most.”

Ms Ley said that she wanted the freeze to end “as soon as possible”, but refused to nominate an end date.

“I’m sure that others in the Cabinet and the Parliament want that day to be as soon as possible,” the Minister said. “But we also recognise our responsibilities in terms of our credit rating, in terms of the national debt, in terms of, as I said, the economic circumstances that Labor left us with.”

Adrian Rollins

[Comment] Offline: Public health—when ideology trumps science

Politicians call it a “war on diabetes”. With one in five Singaporeans projected to have diabetes (that’s 1 million people) by 2050, the Government of Singapore responded earlier this year with welcome urgency. One can understand why. Today, diabetes costs Singapore S$1 billion. By 2050, that figure will likely have risen to S$2·5 billion. Painful past failures—the “war on cancer” and the “war on drugs”—have not deterred Singapore’s public health leaders. They worry they face an unsustainable future.

Science delivers another jab at anti-vaxxers

Image: AMA President Dr Michael Gannon (right) launches the Australian Academy of Science’s Science of Immunisation booklet with Health Minister Sussan Ley and Nobel Laureate Professor Peter Doherty at Parliament House on Monday.

The Federal Government’s No Jab No Pay vaccination policy is working to boost vaccination rates, but there is no room for complacency, AMA President Dr Michael Gannon has warned.

Speaking at the launch of the Australian Academy of Science’s The Science of Immunisation: Questions and Answers booklet alongside Health Minister Susan Ley and Nobel Laureate Professor Peter Doherty, Dr Gannon said vaccination had been one of the great success stories of modern medicine and public health, savings millions of lives every year.

Data from the Australian Childhood Immunisation Register showed that 93 per cent of children nationwide were fully immunised at 12 months, 90.7 per cent were fully vaccinated at two years, and 92.9 per cent were fully covered at five years.

But although child immunisations rates in most of the country were above 90 per cent, the AMA President said there was a need to lift them even higher, particularly in areas such as the Gold Coast, the north coast of New South Wales and parts of western Sydney, where they were as low as 86 per cent.

“One of the reasons for vaccine hesitancy or vaccine refusal is the proliferation of material that seeks to link vaccination with ill health,” Dr Gannon told the launch at Parliament House. “While thoroughly disproven, we still see people linking the MMR [measles, mumps, rubella] vaccine with autism. This is genuinely troubling. This claim has been thoroughly and comprehensively disproven.”

Ms Ley said often parents had not kept their child’s vaccination up-to-date simply because of competing demands on their time.

The Minister said the Government was not trying to force people to have their children vaccinated, but the No Jab No Pay policy meant there would be consequences in terms of reduced welfare payments and access to childcare, and was a prod to many to make their child’s immunisation a priority.

According to the Government, the new rules, which came into effect at the start of the year, have resulted in almost 6000 children previously denied vaccination on the grounds that their parents were conscientious objectors being fully immunised, while a further 148,000 whose vaccinations were not up-to-date have been immunised again.

Dr Gannon said the figures showed that the policy was working “extremely well. There are thousands of children whose parents had conscientiously objected [to vaccination] who no longer conscientiously object”.

But he warned the measure will do little to budge “rusted on” objectors, and might have “minimal impact on families in wealthier parts of Australia,” some of which had low immunisation rates.

Objections to vaccination are typically based on claims about safety, including widely and repeatedly discredited allegations that immunisation is associated with autism.

The latest outbreak of anti-vaccination sentiment accompanied plans by the Castlemaine Local and International Film Festival to screen a show claiming that US health authorities have covered up evidence linking a vaccine to autism.

The festival eventually withdrew the film following widespread community outcry, including from Dr Gannon, who said the director of the show was a “charlatan” and “entirely discredited”.

Dr Gannon said vaccines are subject to rigorous safety assessments and surveillance, and are carefully scrutinised before being added to the immunisation schedule.

Though a small number of children suffer mild and temporary side effects from vaccination, serious problems are very rare.

By comparison, the World Health Organisation estimates that vaccinations saves between two and three billion lives each year.

More than 70,000 copies of the original AAS booklet have been distributed since its launch in 2012, and Dr Gannon said the latest version would be an important aid for doctors and parents in helping counter the dangerous misinformation being circulated by opponents of immunisation.

[Comment] Longer lives and unfinished agendas on child survival

The Global Burden of Disease Study 2015 (GBD 2015) is a landmark event.1–7 Building on the earlier GBD studies it provides a detailed snapshot of the state of global health and an analytic approach to tracking this dynamic picture. As the international community embarks on the transition from the Millennium Development Goals (MDGs) to the Sustainable Development Goals (SDGs), GBD 2015 is a critical part of the toolkit for measuring progress and—critically—holding governments to account.

Government pathology changes could cost practices up to $150m

Federal Government plans to change the rules regarding rents for pathology collection centres could be a disaster for medical practices, ripping up to $150 million a year from their income, the AMA has warned.

AMA President Dr Michael Gannon has told Health Minister Sussan Ley that a significant number of general practices will become “collateral damage” if the Government persists with plans to change the definition of ‘market value’ that applies to rents for pathology collection centres, with serious consequences for the provision of health care.

Dr Gannon said the Minister needed to re-think the proposed changes and adopt a more nuanced approach “consistent with the original intent of the…laws”.

“If you do not get this right, a significant proportion of general practices will become collateral damage, which would be a disastrous policy outcome and contrary to your stated support for the specialty,” he told Ms Ley.

Last month it was revealed that the Government had put off plans to axe bulk billing incentives for pathology services and abandoned its threat to impose a moratorium on the development of new collection centres.

In a climb-down, the Government pulled back from its threat to scrap the incentives on 1 October and advised it would not be proceeding with the moratorium, which was announced during the Federal election in order to head off a protest campaign by the pathology industry against the axing of a bulk billing incentive.

Instead of a ban, the Government has directed that collection centre leases be put up for renewal every six months, down from the usual 12 months, until a new regulatory framework is put in place. Existing leases will be grandfathered for up to 12 months, after which the new rules will come into effect.

The bulk billing incentive cut, meanwhile, which was originally due to come into effect from 1 July and save $332 million, will now not be implemented until 1 January 2017.

“Bulk billing incentives for the pathology sector will continue until new regulatory arrangements are put in place and the Government will continue to consult with affected stakeholders,” a spokesman for Ms Ley told the Herald Sun.

But the Minister is persisting with plans to change the regulations governing rents for approved collection centres, particularly regarding the definition of market value as applied under the prohibited practices provisions of the Health Insurance Act.

Dr Gannon said that in talks earlier this year, the AMA had agreed with moves to strengthen compliance with existing regulations and “weed out examples of rents that are clearly inappropriate”.

But he said the Government at that stage had given no hint it was considering changes to the regulations, and its election announcement had taken all stakeholders, except Pathology Australia and Sonic Healthcare, by surprise.

Dr Gannon said the Government’s clear intent was to control collection centre rents, and the AMA opposed the proposed changes.

There are more than 5000 collection centres across the country, many co-located with medical practices.

“These practices are small businesses and have negotiated leases in good faith,” Dr Gannon said, and had made business decisions based on projected rental revenue streams, including staffing and investment.

He warned that ripping this source of revenue away could be disastrous for many.

“For many practices feeling the impact of the current MBS indexation freeze, this source of rental income has helped keep them viable,” he said, adding that AMA estimates were that the Government’s changes would cost practices between $100 million and $150 million a year in lost rent revenue.

“The magnitude of this cut goes well beyond an attempt to tackle inappropriate rental arrangements. It is causing significant distress, particularly for general practice,” Dr Gannon said. “I doubt the Government truly contemplated the extent of the impact of its election commitment when it was announced.”

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