Health and medical organisations have provided some forthright feedback to a Department of Health and Aged Care consultation informing development of Australia’s long-awaited National Health and Climate Strategy.
In the first of a series of articles reporting on the submissions, we cover those from the Climate and Health Alliance, Doctors for the Environment Australia, and the Australian Medical Association.
Melissa Sweet writes:
The Federal Government has been urged to be far more ambitious in its plans for national health and climate action, with key health and medical organisations suggesting current plans for a national health and climate strategy are too limited and need much more work.
The strategy should explicitly support the phase out of fossil fuels, and ensure Health Impact Assessments are used to guide approvals of new projects, including new coal and gas fired power stations and fracking projects, as well as transport and industrial infrastructure, according to health and medical leaders.
They also call for a nationally coordinated approach, led by the Department of Health and Aged Care, to embed climate and health outcomes across all areas of government, with structures and levers to ensure effective implementation of a Health in All Policies (HiAP) approach through the strategy, as well as engagement of other levels of government and key stakeholders.
The Doctors for the Environment Australia (DEA) submission said legislation should require health metrics to be included in the assessment phase of any significant national, state or private sector proposal, and particularly any proposed fossil fuel project.
As well, the Government has been urged to invest in a communications campaign to ensure communities are better informed about the health impacts of the climate crisis and how to prepare for an increasingly climate-disrupted world.
“Adaptation will only be effective if the wider community understands the risks to health from climate change, and are empowered to take action to protect their own health,” said the Climate and Health Alliance submission.
“As such, the Strategy should include a public education campaign that highlights the risks to health and the health benefits of adaptation as a critical factor to the success of any adaptation action.”
The Australian Medical Association said a public awareness campaign on the health impacts of climate change (and the health benefits of acting on it) would benefit broader society in understanding the risks and the importance of mitigation and adaptation.
The AMA submission said the consultation paper does not adequately reflect the fact that climate change is a health emergency. The strategy needs a specific vision, purpose, and objectives that are underpinned by a governance system that ensures accountability, their submission said.
The calls to strengthen and expand the National Health and Climate Strategy come amid global alarm about the escalating climate crisis in recent weeks. More than 40 people have died in Algeria, Italy and Greece as Mediterranean wildfires threaten villages and holiday resorts, and thousands have been evacuated, the BBC reported on 26 July.
Communities matter
The CAHA submission said that while the references to First Nations cultural knowledge and practice throughout the Consultation Paper are welcome, it is crucial that First Nations Elders and communities are engaged in the development of the Strategy and its objectives and actions.
The Strategy should adopt a strengths based, co-design model, and outline how it will engage First Nations Elders and communities, and incorporate cultural knowledge, practice and reciprocity during implementation.
For the Strategy to be effective, its development and ongoing implementation must be informed by engagement with communities, CAHA said.
“The lived experience of all people living in Australia, including consumers and patients, rural and remote people communities, young people and those experiencing vulnerability and disadvantage, will be invaluable in setting policy that can have real world impact,” said the CAHA submission.
CAHA also recommended the Strategy adopt a Planetary Health rather than a One Health approach, as this would more fully capture the intersection of broader environmental impacts on human health outcomes in the context of planetary boundaries and sustainable development.
Prevention first
CAHA also called for the Federal Government to commit to annual funding for the National Health, Sustainability and Climate Unit (NHSCU) of $1,000,000, and said the strategy should clearly outline how the Department of Health and Aged Care and HSCU would lead cross-government work.
The NHSCU should be equipped to work across the whole of government to ensure that disease prevention is a priority of key portfolios – including transport, housing, First Nations and climate change – that can impact the social determinants of health.
The strategy is “a once in a generation opportunity to meaningfully prepare to meet the health needs of all people in Australia in the face of the climate crisis”, and it was crucial the remit of the NHSCU is broadened to take a ‘Health in All Policies’, whole of government approach, where climate and health leadership is supported throughout all Commonwealth policy planning.
“The primary focus of the Strategy, and the work of the NHSCU, should be to address health in a climate-impacted world across the Commonwealth Government,” said the CAHA submission.
“Owing to the need to restructure the current approach of the Strategy and the remit of the NHSCU, it is recommended the timeline for delivery of a final Strategy is extended so that the sector may have additional consultation and review a draft Strategy.”
CAHA also called for a board to be established to advise the Minister on the strategy, including representatives of public and private hospitals, general practitioners, allied health professionals, public health specialists, consumers, climate and health experts, and national climate agencies.
The Board should provide advice to the NHSC Unit and an interdepartmental committee of senior officials from all jurisdictions and representatives from climate change coordination agencies in jurisdictions. It should produce an annual report on the implementation of the Strategy, and provide public communication on progress and outcomes.
CAHA, the AMA and DEA all stressed the importance of primary prevention, including through action on the social determinants of health, as a key mitigation strategy.
“One of the best ways to reduce emissions associated with the healthcare sector is to keep people as healthy as possible for as long as possible. We strongly support the inclusion of optimising models of care, as it reduces emissions, improves consumer experience and patient outcomes and reduces wastage of resources,” said CAHA.
The AMA said HiAP should be prioritised over the other existing strategy objectives, and that the strategy should recognise that addressing the health impacts of climate change will require a whole-of-government approach, instead of focusing on environmental sustainability in the healthcare system alone.
“The AMA would like to participate in further consultation once a draft strategy is available.”
The AMA also stressed the importance of addressing mitigation more broadly than for the health system alone, and called for Australia to prioritise and resource research into all aspects of health and climate change action.
“Decades of inaction has meant that Australia is behind other countries on climate change action and is lacking investment into researching Australia-specific solutions,” the AMA’s submission said.
Healthcare in focus
CAHA called for a national healthcare decarbonisation plan, with the NHSCU fully equipped to establish a dedicated team that can collate and report on carbon emissions of the public and private health systems.
DEA said that decarbonisation of the Australian economy by 2050 and 2040 has been modelled to avert an estimated 988,000 and 1,101,000 global deaths respectively. Decarbonisation of the Australian healthcare sector by 2050 and 2040 is predicted to avoid an estimated 69,000 and 77,000 global temperature-related deaths, respectively.
CAHA said the Strategy should fund a climate change adaptation worker program akin to the existing environmental health worker program, and for the establishment of an ongoing national community of practice (as has been established in Western Australia), to enable knowledge and information exchange, facilitate collaboration, and help build momentum and capacity for action.
CAHA also said the Strategy should set a goal to establish mandatory climate change mitigation and adaptation requirements in healthcare accreditation standards.
“There is much more to do in increasing understanding among health executives and boards in relation to their fiduciary responsibility (‘duty of care’) and potential for personal liability if they fail to account for climate risks in strategic and operational plans. The Strategy should set a goal that requires all health services and other relevant services to conduct climate change risk assessments as a core risk management strategy.”
CAHA said the Strategy should require (and support) all health services to develop a climate change adaptation plan that outlines the steps they need to take to prepare for the challenges ahead. This would include such matters as emergency preparedness, infrastructure assessment, workforce skill in managing climate-related health risks in their patients.
The production of health service adaptation plans could be mandated in the Australian Council of Healthcare Standards, and included as a performance measure in the National Healthcare Reform Agreement. Targets should be included in the National Healthcare Reform Agreement and National Safety and Quality Health Service to cover both community and health service adaptation.
CAHA also said that state and territory jurisdictions are key stakeholders in the development and implementation of the Strategy and should be extensively consulted on goals and targets. The jurisdictions should also be considered a key enabler to implementation of the Strategy, and be supported and funded to expand existing work and tailor programs to localised solutions where needed.
The AMA called for the strategies and funding for mitigation and adaptation of public hospitals to be included in the National Health Reform Agreement Addendum 2025 onwards.
Noting that there is great variation in the levels of mitigation and adaptation planning already occurring by hospitals, the AMA suggested that the funding be disbursed either through block funding for specific hospitals/health districts or as part of Activity Based Funding (ABF) National Efficient Price with relevant adjustments according to the needs of individual hospitals.
“This process must be equitable and not seen as punishing for those hospitals that have already progressed along the climate mitigation and adaptation path,” the AMA said.
The AMA said the Strategy should engage with Therapeutic Goods Administration and the Pharmaceutical Benefits Advisory Committee to ensure that environmental sustainability is a consideration when approving medicines to be registered in Australia and subsidised by the Pharmaceutical Benefits Scheme.
“Ensuring environmentally sustainable medicines are accessible and affordable for patients will be key to ensuring their use,” the AMA said. “The strategy should support research to determine the environmental impacts of therapeutics and provide guidance to prescribers.”
DEA said all pharmaceutical and medical device or supply companies must be required to publicly report the carbon footprint of each of their products, and the results should aid procurement decisions.
Other enablers to optimise sustainable models of care and practices include:
- defunding, via Medicare, of procedures identified as low value care
- working with private insurers to defund low value procedures
- identifying and eliminating financial incentives for over-servicing.
The DEA also called for funding for the Choosing Wisely and NPS MedicineWise programs to be restored and increased, as these programs reduce low value prescribing.
Other recommendations
DEA also recommended:
- 100 percent renewable electricity supply to all Australian public and private healthcare facilities by 2025
- no planned healthcare facility builds to include gas infrastructure, effective immediately
- transitioning of existing healthcare facilities to be gas-free by 2030
- the establishment of nationally consistent guidelines for healthcare facilities to be designed and constructed for net zero emissions by 2024. Note that the value of reducing ongoing energy consumption through better design and insulation needs to include current and projected increased extreme weather events, such as heatwaves and hot weather, and not be based on historical data.
- no piped nitrous oxide infrastructure in future hospital designs as of 2023, apart from when considered necessary for obstetric and paediatric services.
DEA wants all vehicles owned or operated by the health system to be zero emission vehicles before 2025, although acknowledged this may not be practical in very remote settings, where a high fuel efficiency standard must be the minimum.
They also called for universal electric vehicle charging to be available at all healthcare facilities for staff, patients and visitors.
As well, the Strategy should incentivise uptake of videoconferencing, telehealth, telephone consultations and other virtual technologies when clinically appropriate, and support models of care such as Hospital in the Home, and decentralising healthcare away from tertiary centres by upskilling and adequately resourcing local health facilities to deliver appropriate care closer to home.
Staff travel emissions should be addressed through restructuring continuous medical education funding to de-incentivise international travel for conferences, prioritise virtual attendance and allow CME allowances to be reimbursed to the clinician, used for other educational activities or environmental, social and governance projects that benefit the health system.
DEA also said Australia must join the WHO-led Alliance for Transformative Action on Climate and Health, noting that 64 countries are members, and “it is very disappointing that Australia is not”.
“It is through this alliance that national Departments of Health are developing international procurement standards, led by the UK NHS, United States Department of Health and Human Services and several major European nations.”
Workforce matters
The AMA has been calling for private health services in rural and regional areas to be declared essential services so they can be offered immediate financial support and resources following climate change-fuelled disasters.
The AMA also wants all rural health service providers to be declared essential workers, so in future disasters they will not have to bear the stress of funding uncertainty in the aftermath.
“Climate change-fuelled extreme weather events are already occurring, and we are under-prepared,” said the AMA.
“Australia so far has been lacking national leadership and coordination with states and territories when such an event occurs.
“High priority adaptation actions should include ensuring healthcare facilities are better prepared to face an extreme weather event, and ensuring there is adequate support and resources for healthcare facilities facing climate change events.
“At a broader level, government needs to focus on community resilience and ensure social services are adequately prepared for increasing extreme weather events. This includes resourcing for emergency services, transport, housing, and food and water security.”
The AMA also said that healthcare facilities need employed, dedicated environmental sustainability managers with executive support.
Built environment
Other CAHA recommendations include:
- The Strategy should outline how it will encourage electrification and energy efficiency in all buildings to improve health and wellbeing.
- Built environment design and urban planning must also promote active transport, which benefits health through reduction of transport emissions as well as physical activity pathways. Adequate housing density, well-connected streets, mixed land uses to create nearby destinations, and proximate public transport are key determinants of walkability, especially in outer suburban areas.
- Targets and actions to increase urban greening and tree canopy cover in the built environment, as this can reduce health impacts of extreme heat and air pollution.
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