PHI Rebate Subsidy for Naturopathy and TGA issues (via email) and Response

Australian Government Department of Health – Private Health Insurance Branch
08 August 2018 3:58 PM
For attention: the Hon Greg Hunt MP

Dear Minister Hunt,

I am writing to you about two significant issues  affecting naturopaths and the public.

Naturopaths offer millions of Australians health support often filling gaps in the health care system where mainstream medicine has no answers or where the side effects of mainstream medicines are prohibitive.

The public is already spending billions of dollars on Complementary and Alternative medicines and treatments.

Continuing to support the rebate for naturopathy will send a very clear signal from government that a public empowered to pay an out-of-pocket expense with a small subsidy from the government is a winning and beneficial choice

Importantly, the pro-active public making this choice reduces the health burden and the health budget for the health ministry.


Removing the rebate from Private Health Insurance for naturopathy consultations is already affecting the profession of naturopathy negatively.

The message and perception to Private Health Insurance companies, the public and other health providers created by your ministry is unfounded if it is based on insufficient or lack of evidence for naturopathy.

High quality evidence for the practice of naturopathy was cited at the time of the Natural Therapies Review, and there is more today.

The Australian public who choose to pay for Extras in their insurance premiums will be disadvantaged.

Liberal policy of supporting independent health care seems to be disappearing. This rebate issue was sadly initiated by the Labour government. It was ill conceived and a significant waste of tax payer dollars.

IF the decision to remove the rebate for naturopathy was based on the findings of the Natural Therapy Review, then that decision needs to be reviewed and reversed.

As a member of the Advisory panel for the Natural Therapies Review, it was blatantly obvious to me that sound high quality evidence was discounted for naturopathy.

Quite frankly, I was appalled when the decision to stop rebating Naturopathy was decided by your ministry.

When the naturopathy profession can show evidence for good outcomes for seventeen lifestyle conditions, that should be celebrated!

A good reason to continue rebating, not remove rebates!

The health ministry should be overjoyed to have a profession that is stepping up and taking a significant burden off the system.

It is these exact seventeen lifestyle conditions in the research that are bankrupting your health budget.

Naturopathic care has cost-effective solutions.

Continuing to rebate for naturopathy consultations offers the Australian public the right approach.

Continuing to support the naturopathy rebate acknowledges a highly skilled profession already removing a burden from the mainstream health system.

There are thousands of naturopaths across the country using naturopathic philosophy and principles to treat the public effectively.

After more than one hundred years, naturopathy continues to offer health solutions for acute and chronic health conditions.

As an unregistered health profession (because we cause little harm), we make a significant contribution to the health, prevention of disease, and continued wellness maintenance of the nation.

The very comprehensive submission ANPA as well as the National Institute of Complementary Medicine (NICM)  are as valid today as they were when submitted a few years ago.

In fact, there may be more research available since that time.

Minister Hunt, retaining the subsidy for the PHI rebate for Naturopathy is a no brainer. That decision will win you votes and decrease the health budget in the long-term. 


The recent removal of significant herbal medicines due to an oversight of a cross reference in the Poisons Standard has removed access to important herbal medicines with a track record of safe use.

The removal and restriction of Arctostaphylos uva ursi (Bearberry – leaf) should never have occurred.

If there had been oversight by a suitably trained person appointed to the Advisory Committee in the TGA reviewing Poisons who also understood the implications for plant medicines I would not be writing to you today.

In this instance, a plant medicine with international recognition as being safe was removed for a technicality, not a factual issue of safety or harm.

In the plant medicine the level of arbutin even though greater than 10 ppm has been widely used as an effective remedy for Urinary Tract Infections. Other herbal medicines that are potentially affected are known to be safe and have been widely used in this country and overseas for many years. (Achillea millefolium,  Yarrow and Turnera diffusa, Damiana).

The ridiculousness of this removal is that arbutin is found in pears and marjoram. These food items have not been recalled.

It makes no sense that valuable plant medicines have been caught in the crossfire of legislative red tape.

The public is now being denied a very valuable medicine for the treatment of Urinary Tract Infection.

In a time of serious antibiotic resistance for these types of infections, this plant medicine is critical to the public who are seeking alternatives to antibiotics for these kinds of health concerns.

The public have been disadvantaged and so too the manufacturers of these excellent and efficacious medicines.

The ANPA is requesting that the TGA

  • exempts plant medicines that contain arbutin from the Schedules
  • create an entirely different schedule for plant medicines
  • invites a suitably qualified expert in plant chemistry onto the TGA Advisory Committee on Medicines Scheduling
  • the CAM Advisory Panel has its role extended to review any scheduling that could affect natural or plant medicines
  • fast track these inappropriately removed medicines back onto the dispensary shelves

Minister Hunt, I look forward to your response to these two very important issues.

I am happy to meet or teleconference on these two issues on behalf of our members and the public.

Kind regards,

B.Naturopathy, BSc Public Health, Med.Tech
ANPA President

9 Sept 2018 – Response from Department of Health

View the document here