Thirty years after its first edition, the RACGP’s newest general practice standards are placing greater emphasis on patients’ needs.
Artificial intelligence and environmental sustainability are brand-new focus areas for the latest standards for general practice, but practices will have 31 fewer mandatory criteria to clear for accreditation.
The RACGP’s sixth edition standards for general practices introduces six entirely new areas – planning and governance, environmental sustainability, digital health technologies, artificial intelligence, quality improvement and consumer engagement.
The 181-page document, Standards for general practices, was released today. It contained 31 fewer mandatory criteria overall, but added more sub-indicators and upgraded several aspirational items to mandatory status.
Healthcare accountant David Dahm, who had previously raised concerns with TMR that the sixth edition’s definition of “contractor” could throw GPs “under the tax bus”, said the final publication had made a “significant improvement”.
“This clarifies the word ‘independent doctor’, and it’s saying explicitly they’re not employees and they’re not contractors,” Mr Dahm said.
But he said the document fell short elsewhere: it never defined “practice” as a legal or organisational entity.
“Practice owner” appeared several times in the standards and featured in the glossary definition of “practice leadership” – “the members of the general practice leadership team which could include the practice owner, practice manager and clinical leads” – but the term itself remained undefined.
It is generally understood the practice owner and practice manager bear the administrative and financial consequences of failing to maintain compliance. But the standards made no mention of who was liable for the accreditation certificate itself.
Mr Dahm said this vagueness was not, on its own, an issue.
“It’s not that specific, and it doesn’t need to be because this document itself may not be used for tax purposes,” he said.
The risk emerged where the standards were more prescriptive, including recall and reminders, Mr Dahm told TMR.
“The question is, who’s monitoring it? Who’s dealing with complaints? Is it an individual independent doctor, or is it what they loosely call the practice, and who is that? Is it a service entity?” he said.
Mr Dahm said the remedy lay in documentation, including clear service agreements defining the practice-practitioner relationship and staff manuals that did not depict the practice as controlling or directing independent doctors.
Billing was central to that test, he said – echoing the reasoning that saw the NSW Supreme Court find Uber liable for payroll tax on payments to its drivers.
“If you can’t set your own fee, you can’t be an independent business,” Mr Dahm said.
His recommended fix was separate, independently published pricing for each doctor.
“If you’re an independent doctor, you should have your own independent website,” he said.
“These things are all fixable, but it means people have to have you look at rewriting or reviewing their manuals, so they’re not seen to be controlling or influencing them,” Mr Dahm said.
“That’s absolutely key from a superannuation, tax, [and] payroll tax compliance perspective.”
“It’s a bit of a breather – there are still traps, but you can’t be superficial about it; it’s substance over form.”
The final standards replaced the draft’s employee-contractor binary with two refined categories – employed members and independent doctors in practice – using “contractor” only once, to define what an independent doctor was not.
“We’ve taken considerable advice from legal advisors, medical defence insurers, and key stakeholders on this wording to differentiate between members of the clinical team who may be either employed or independent,” Dr Louise Acland, chair of the RACGP standards for general practice expert committee, said.
The broader changes, Dr Acland said, reflected developments over the almost-decade since the fifth edition’s publication.
“Ten years ago, environmental sustainability wasn’t an issue; we didn’t have to consider the digital landscape, AI or issues around privacy and confidentiality,” she said.
Now, she said these concerns were at the forefront.
This included clear criteria for a “positive culture” that ensured the safety, health, and both physical and psychological well-being of the practice team, as outlined in new sub-criteria in F7.A.
“It reflects the shift in the healthcare workforce landscape, particularly since covid, where working in healthcare generally and general practice in particular is more complex and demanding,” she said.
Dr Acland said much of the fifth edition’s content had been carried over, with a mapping document available to help practices understand how content from the previous edition had been “reorganised, consolidated, clarified or expanded”.
“Our aim with the standards is to provide GPs and practice teams with continuity amid change,” she said.
“[The RACGP’s] emphasis is on safety, continuity, and, very importantly, patient-centred care, which is more emphasised in the sixth edition than in the fifth edition.”
Entirely new on the agenda were consumer expectation statements, which were first-person statements attached to each of the criteria sets, co-developed by a dedicated RACGP Consumer Focus Group.
Dr Acland told TMR the RACGP consulted various consumer groups nationwide to gather feedback on the new edition’s criteria from a patient-consumer viewpoint, in a “first for the college”.
“Internationally, it’s been recognised that health outcomes, or outcomes of care provided in healthcare models, are better when patients are engaged in making decisions about their care. We’ve taken that on board and encouraged consumers to be involved in the development of the standards,” she said.
While “continuous quality improvement activities” had previously existed only in concept, the colleges’ latest edition established concrete criteria.
While the standards acknowledged their two-part AI criterion may be updated as new national regulations evolved, it included specifications such as patients’ informed consent before AI use in their care, and that clinicians remained accountable for care decisions supported by AI tools.
Other updates to the standards included a requirement that practices inform patients how to access care when closed.
Paper-based clinical information systems were also deemed unacceptable, with hybrid systems permitted only where genuinely needed.
“Accreditation was envisioned not merely as a compliance exercise, but as a mechanism to support excellence in patient care and provide a visible measure of quality,” Dr Acland said.
The RACGP said implementation arrangements for the sixth edition under the National General Practice Accreditation scheme would be published shortly on the Australian Commission for Safety and Quality in Health Care’s website.
Read the full Standards for general practices (6th edition) here.
