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香港醫學會回應二零二二年度《施政報告》

新一屆政府於十月十九日發表了二零二二年度《施政報告》。在醫療政策方面，香港醫學會（醫學會）樂見報告就基層及公共醫療方面提出不少方向性建議，亦感謝政府採納了醫學會關於長者醫療券、推廣家庭醫生及新增精神科公私營協作計劃的意見。醫學會現就《施政報告》中的醫療倡議作出進一步回應，冀助政府優化相關政策。

一、基層醫療

醫學會支持政府推動基層醫療的大方向，亦密切期待「基層醫療健康藍圖」出台。對於《施政報告》中提出的「慢性疾病共同治理先導計劃」，醫學會建議政府採用類同醫療券及疫苗資助計劃的模式，即提供定額資助予市民，並由私家醫生自定共付額，以確保市民能自由選擇便利他們的服務提供者，並可減低管理成本。此外，十八區地區康健中心作為計劃中的唯一篩查及轉介單位，醫學會關注單靠十八間中心未能應付計劃中龐大需求；建議應參考大腸癌篩查計劃，覆蓋紮根社區的基層醫生，以鼓勵更多市民參與。同時，政府應確保「策略採購統籌處」制定公平醫療服務採購政策，不會因行政便利選擇集團式經營而拒納私家醫生於基層醫療服務提供者之列，有違推廣「一人一家庭醫生」的原意。

二、長者醫療券

醫學會歡迎政府接納本會意見，增加每年長者醫療券的金額。在實施細節上，由於先導計劃會在長者使用1,000元於特定基層醫療服務後才可給予額外500元，我們建議政府須明確界定「特定基層醫療服務」的種類以防濫用。此外，對於使用醫療券治療慢性病的長者，現時計劃變相減少他們實際可用於支付藥物費用的金額。醫學會建議將醫療券進一步提高至3,000元以解決上述問題。同時，建議政府應推出可行措施，確認共用醫療券夫婦的婚姻狀況，以省卻爭拗。

三、公共醫療

醫學會支持政府縮短公立醫院服務輪候時間，但現時各區公立醫院的服務輪候時間差異甚大，穩定新症的輪候期可從67至142周不等。儘管《施政報告》提倡將輪候時間減少20%，但部分聯網病人仍需等候114周才獲上述服務。醫學會建議醫管局為各專科訂立輪候時間指標，為公立醫療服務確立合理的輪候時間表。

四、「醫健通」

要令「醫健通」成為貫通公私營醫療體系的骨幹系統，政府宜先檢視公營醫療機構上載規定和執行。根據醫學會了解，衛生署旗下部分診所及中心仍未上載醫療報告到「醫健通」。

五、治療師免轉介

醫學會關注病人安全，認為政府應參考推行免轉介國家的經驗，制定指引詳列可以進行免轉介的情況，推行前亦需有足夠的準備和諮詢。

有關醫學會對《施政報告》的詳細建議，請瀏覽https://m.facebook.com/story.php?story_fbid=pfbid02odQf52pqCEwGcs2tE5eBPSo9biDkDhfDrRYouPmdtrdeXGyYqY3CJNx7LE2SAAa8l&id=151407245292728&mibextid=u79Ldb

二零二二年十月二十八日

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28 October 2022

HKMA responses to the 2022 Policy Address

Regarding the 2022 Policy Address announced on 19 October 2022, the Hong Kong Medical Association (HKMA) is glad to see some of the dedications devoted in the Policy Address towards enhancing our healthcare system. We are delighted that our recommendations on the Elderly Healthcare Voucher (EHCV), the promotion of family doctors, as well as setting up a new mental health public-private partnership programme are adopted in this year's Policy Address. As the largest doctor body in Hong Kong with the aim of "safeguarding the health of the people", we would like to share our views on some of the policies incited, in the hopes of optimising the suggested policy measures to build a healthy and vibrant Hong Kong as it stated.

1. Primary Healthcare

The HKMA supports the Government’s proposal that Primary Healthcare should be prioritised and promoted in order to tackle future challenges brought by our rapidly ageing society. As the Primary Healthcare Blueprint is scheduled to be announced this year, the HKMA would like to take this opportunity to make further recommendations on primary healthcare planning and development to facilitate the discussion.

1.1 Chronic Disease Co-Care Pilot Scheme

The Policy Address announced a three-year Chronic Disease Co-Care Pilot Scheme, under which the District Health Centres (DHCs) will refer people who are screened to be at high risk of hypertension or diabetes mellitus to the private sector for further examination, and the Government is committed to subsidising about half of the examination and treatment fees. As the details of the Scheme are yet to be released, we strongly propose that the subsidy model should adopt the same approach as EHCV and Vaccination Subsidy Scheme.  A fixed subsidy together with transparent amount of co-payment set by individual doctor would allow free choice from the patient. Moreover, administrative costs can be much reduced.

Furthermore, the 18 DHCs are proposed to be the sole “point-of-contact” for the registration, screening and referral in the Scheme. The capacity of the DHCs is questionable for such massive screening. Outreach to citizens is also much limited. On this, we suggest the Government to include the already well-established network of primary care doctors to aid patients' participation in the Scheme.  Reference is drawn to the Colorectal Cancer Screening Programme in which Primary Care Doctors play a crucial role in the preliminary test and screening in wider community. 

1.2 Strategic Purchasing Office

The Policy Address mentioned the setting up of a Strategic Purchasing Office to coordinate primary healthcare services provided through the private healthcare sector. Given the arrangement of the current public-private partnership (PPP) programmes, we are concerned that the aforementioned Office will only benefit private organisations instead of all eligible private medical practitioners. We understand that there is administrative convenience in preferential purchasing from large HMOs. However, doing so disregards the merit of our existing private healthcare system and is against the promotion of family practice by limiting patients' choices.  Solo Medical Practitioners should be given equal opportunity in the provision of healthcare services to the public under the PPP framework for better patient’s choice and higher accessibility to the public.

1.3 Direct Access (DA) to Physiotherapy

2022 Policy Address continued the legislation of amending the Supplementary Medical Professions Ordinance to facilitate patients' direct access (DA) to services provided by physiotherapists (PTs) without a doctor's referral. The HKMA made a submission that the proposed amendment might not be beneficial to patients for the likely tendency of self-prescription for medical therapy.

European guidelines and studies show that around 1 to 2.3% of patients in primary care have serious underlying pathologies. Early identification of these severe pathologies is of utmost importance as they necessitate timely and correct diagnosis and treatment, which cannot be provided in the DA setting. We are concerned that neither the public nor physiotherapists are ready to take responsibility for adverse outcomes that follow "self-referral". Also, who should be accountable for the "self-prescription" patients remains debatable.

In fact, in DA settings, a PT's ability to recognise clinical danger signs, to understand his limitations, as well as when patients should be referred to a doctor are vital to patient safety. Regarding other countries that practice DA, most are carried out in a limited extent with conditions well spelled out. It is noteworthy that with all the above concerns, regulations and supervisions are essential if DA is to be implemented; preparatory and consultation work are essential to ensure patient safety.

2. Elderly Healthcare Voucher (EHCV)

The HKMA welcomes the Government's adopting our recommendation to increase the amount of yearly EHCV. At the same time, we have more inputs.  Firstly, regarding the initiative to allow shared use of EHCV between spouses, the current EHCV system does not record the related information. The Government should put in place practical administrative measures to verify marital status of the users.   It would be difficult for frontline doctors to do so. Secondly, the additional $500 will be allotted automatically to the elderly persons' accounts upon claiming at least $1,000 for designated primary healthcare services. We see the need to clearly define "primary healthcare services" so as to prevent abuses to the use of EHCV. Thirdly, for those elderlies using EHCV for management of chronic illnesses, the suggested changes would decrease the actual amount available to them for medication fees. We recommend to raise EHCV by $1000 instead of $500 to address the above.

3. Public Hospital Services

3.1 Waiting time for specialist out-patient services

The HKMA appreciates that the Policy Address acknowledges the importance of reducing the waiting time of public hospital services.  Instead of simply stating reduction of waiting time by 20%, the Government may wish to set a standard level for the reduction. For instance, the waiting time for stable new case bookings for the specialty of Medicine ranged from 67 to 142 weeks among different hospital clusters. Despite reducing the waiting time by 20%, a patient still needs to wait 114 weeks for the said service. It would be more objective to set up a time bar of waiting time for each specialty so that reasonable expectation can be established for public hospital service.  On the other hand, the Government should expand the current scope of PPP so that patients in stable conditions can seek private medical attention promptly, and to serve the purpose of arranging these patients to the private sector effectively.

3.2 eHealth

The Policy Address suggested transforming eHealth into a key infrastructure integrating public and private healthcare systems. We believe that public healthcare institutions should be the spearhead in mobilising the initiative. We understand that many clinics/centres under the Department of Health (DH) have yet to upload their health records to eHRSS, despite all being reported to be fully connected with the system. We hope that the Government can sort out the current asynchronization between Hospital Authority, DH and DHCs regarding health record upload to truly transform eHealth into the backbone of primary healthcare practice.

4. Post-COVID Management

As COVID-19 disease has become endemic and will continue to exist in our community, therapy and treatment services for Long-COVID patients will be in desperate need. The University of Hong Kong has estimated that 4.4 million Hong Kong people have already been infected; the Government has to allocate adequate resources for Long-COVID management to address this pressing issue, notably for the post-COVID era. The HKMA supports the Government to actively sketch the roadmap for normalisation, especially on how to maintain interflows with both Mainland China and the world. With a solid roadmap, the Government can simultaneously prioritise its anti-pandemic resources for severe cases treatment and vaccination in lieu of cases isolation and contact tracing. 

5. Closing

Notwithstanding that the 2022 Policy Address has pinched a grand scheme for the future development of primary healthcare, detailed measures are yet to be announced to depict whether it will drive real and positive changes in our healthcare system. We hope that further details can be released as soon as possible to facilitate timely debate and discussion for the Blueprint. Besides the above suggestions for the healthcare policies stated in the Policy Address, the HKMA would like to take this opportunity to iterate the importance of considering the following points which we included in our previous Policy Address 2022 submission:

• Adherent to evidence-based practice in the implementation of healthcare policies, and in the promotion and governance of non-western medical practices.
• Ensuring good governance and transparent mechanism for Public-Private Partnership (PPP) with references to successful existing programs like the seasonal influenza vaccination program and the colorectal cancer screening program.
• Introducing Key Performance Indicator (KPI) to HA to evaluate PPP effectiveness quantitatively and regularly.
• Extending the current vaccination programmes and mobilising primary doctors to provide a more holistic approach to health prevention services.
• Pursuing structural reform to retain medical talents in the public sector to untangle the problem of manpower shortage caused by brain drain.

For detailed HKMA’s recommendations in regard to the 2022 Policy Address, please visit https://m.facebook.com/story.php?story_fbid=pfbid02odQf52pqCEwGcs2tE5eBPSo9biDkDhfDrRYouPmdtrdeXGyYqY3CJNx7LE2SAAa8l&id=151407245292728&mibextid=u79Ldb .

編輯備忘：香港醫學會成立於一九二零年，旨在聯繫政府、各公立醫療機構、大學及私人執業的醫務工作者，交流意見，團結一心。醫學會致力將最新的醫療資訊及醫務發展傳遞與會員，提倡會員遵行專業操守，進而服務社會，維護民康。

Notes to editors:  The Hong Kong Medical Association, founded in 1920, aims to bring together Hong Kong's government, institutional, university and private medical practitioners for an effective exchange of views and co-ordination of efforts.  The foremost objective of the Association is to safeguard and promote public health.  The Association speaks collectively for its members and aims to keep its members abreast of medical ethics, issues and advances around the world.  In fulfilling these goals, the association hopes to better serve the people of Hong Kong.