0474 Australian Private Hospitals Association

General information

Submitterʼs name
Australian Private Hospitals Association
Submitted on behalf of
Professional body or industry association

About the submission

Is your organisation an Approved Sponsor for any of the following programs?
  • Temporary Work (Skilled) (Subclass 457) visa program
  • Employer Nomination Scheme (Subclass 186) visa program
  • Regional Sponsored Migration Scheme (Subclass 187) visa program
  • Labour agreements
Are you an Australian assessing authority for migration purposes?
Please select the industry your submission is in relation to. If required, you may select multiple industries.
Health Care and Social Assistance
Do you have a particular regional interest? If required, you may select multiple regions.


1. Do you consider that occupations need to be added to the Medium and Long-term Strategic Skills List (MLTSSL)?


What occupations should be added to the Medium and Long-term Strategic Skills List (MLTSSL)?

Please also include occupations that you propose should be moved from the Short-term Skilled Occupation List (STSOL) to the MLTSSL.

224213 Health Information Manager
251511 Hospital Pharmacist
251513 Retail Pharmacist
411411 Enrolled Nurse
599915 Clinical Coder

Please outline the evidence or data that would support these occupations being added to the MLTSSL.

Clinical coders (CCs) and Health Information Managers (HIMs) are an essential part of the private hospital workforce, and one that is in chronic shortfall. The APHA proposes CCs be added to the MLTSSL, and HIMs be moved to the MLTSSL. A 2014 HIMAA survey found >60% of respondents said demand for CCs is growing, and 45% face growing demand for HIMs. One third reported having CC vacancies, and a fifth had HIM vacancies. Over half stated the supply of HIMs was inadequate, and only 12% rated supply as ‘good’ or ‘excellent’. 2011 census figures show hospitals could be short by up to 1,025 HIMs and 995 CCs – a considerable fraction of this workforce.

Private hospitals also face a shortage of Enrolled Nurses (ENs), so the APHA proposes these be moved to the MLTSSL. Increasing the length of stay permitted would entice more ENs to come to Australia, and allow them to gain more experience in their role here. The APHA’s 2017 EN survey found that 4% of ENs are overseas-qualified, yet in the year to August 2017 only 3,700 visas were granted to ENs. Large employers have been actively trying for years to address this shortage via EN training and graduate programs, yet shortages persist. NDIS and aged care demand adds to the shortage. Since ENs were added to the STSOL in April, applications to private hospital-based Diploma of Nursing programs have decreased, evidencing that the lack of an EN pathway to PR is impairing our ability to continue to source and train ENs.

Hospital and Retail Pharmacists are in critical shortage in regional Australia, so the APHA seeks the transfer of both occupations to the MLTSOL for regional locations. Both should also remain on the STSOL for metropolitan locations, as short term shortages do occur there. Employers report 6-8 months on average to fill regional pharmacist vacancies, directly impairing regional service provision. Operators are forced to hire locum pharmacists, resulting in no continuity of service and also increased operation costs.

2. Do you consider that occupations need to be added to the Short Term Skilled Occupation List (STSOL)?


3. Do you consider that occupations need to be removed from the Medium and Long Term Strategic Skills List (MLTSSSL) or the Short Term Skilled Occupation List (STSOL)?

Do you have any supporting material for your submission?
Yes (see attachments)

Last modified on Wednesday 17 January 2018 [41036|98816]