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05 September 2011 Louise Macleod Director Intelligence, Infocentre & Policy Liaison Branch GPO Box 3131 Canberra, ACT 2601 Dear Director, I am responding on behalf of the Australian Society of Orthodontists, Inc. (ASO). The ASO supports the submission by the affiliate Association the Australian Dental Association, Inc.. There is one area of concern of the ASO that relates to the use of ADA Item numbers. 1. Private Insurance providers are inconsistent in the ADA Item number required to claim for a full-course of Orthodontic treatment or the application of full-fixed appliances “braces”. In several states the ADA item number 881 is required for a patient to gain a rebate. However, in other states a different ADA Item number or sets of ADA Item numbers are required. This inherently will result in different rebates being provided to patients. In some States no rebate will be offered to the patient until the ADA Item number the Private Health Insurance Company requires is submitted. 2. Private Health Insurance providers are reported to give preferential treatment to Specialists within one or more Sates when allowing exclusive use of individual ADA Item numbers. This preferential treatment creates an unfair situation between practitioners within different States. Thank you for the opportunity to comment on Private Health Insurance to the Australian Competition and Consumer Commission. Kind regards, J. Mike Razza ASO – Federal President