The Australasian Institute for Genital Autonomy (AIGA) provides the following submission in response to the Report from the Paediatric Surgery Advisory Group, dated May 2019.

Feedback item 1.
Under 6.3.2 Rationale for recommendation 4, the report states “The Committee noted that Item 30654 should continue to include circumcisions conducted for religious and cultural reasons, reflecting both current practice and the need to ensure safe circumcisions.” This statement is particularly concerning, and indicates ‘current practice’ includes unlawful Medicare claims under the Health Insurance Act 1973, which requires that benefits are payable only for clinically relevant professional services. Additionally, around 2% of all Item 30654 claims are reported as female patients. All Australian states amended their Crimes Acts over a decade ago to criminalise female circumcision, with penalties ranging from 7 to 21 years imprisonment. This warrants urgent and serious investigation.

Feedback item 2.
Recommendations should have included an investigation into why the rate of Item 30654 in NSW is several times higher than Victoria (for example), for a similar population size. The suggestion here is that thousands of healthy boys are being subjected to an irreversible surgical procedure, without need and without their consent.

Feedback item 3.
Recommendations should have included an investigation into why there is an extremely limited use of tissue preserving / less invasive treatments for foreskin problems (Item 30666) in Australia. Why the rush to surgery which is significantly more invasive?

Feedback item 4.
The Paediatric Surgery Advisory Group report was silent on the fact that Australian state governments ended the practice of circumcising healthy boys in their public hospitals between 2006 and 2007, which aligns with the intent of the Health Insurance Act 1973, where a ‘clinically relevant’ test is applied.

Feedback item 5.
The Paediatric Surgery Advisory Group report noted that Item 45206 is used to repair the more serious circumcision botches. MBS data shows hundreds of <4yo boys are having plastic / reconstructive surgeries each year, which is an order of magnitude higher than <4yo girls. Beyond early childhood, the Item 45206 claims are roughly equal between males and females. Are hundreds of healthy <4yo boys suffering serious iatrogenic injuries caused by the thousands of needless Item 30654 surgeries each year? This very much warrants further investigation.

Feedback item 6.
The child patient’s right to autonomy fails to get a mention in the 44 page Report from the Paediatric Surgery Advisory Group, which is both surprising and extremely disappointing.

There is no ethical or legal basis for public monies to be used to fund surgical procedures ‘conducted for religious and cultural reasons’, especially where healthy children are involved. The Department of Health has an obligation to end this unethical and unlawful use of Medicare funds.