Post on 30-Apr-2022
Complementary Medicines Australia
2018/19 pre-Budget Submission
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Complementary Medicines Australia
2018/19 Federal pre-Budget Submission
December 2017
Mr Carl Gibson
Chief Executive Officer
Complementary Medicines Australia
Published by: Complementary Medicines Australia
PO Box 450
Mawson, ACT 2606
Australia
Telephone: 02 6260 4022
E-mail: carl.gibson@cmaustralia.org.au
Website: www.cmaustralia.org.au
Australia’s Complementary Medicines Industryi:
$4.7 billion complementary medicines industry revenue, having doubled from $2.3 billion in just three years
Vitamin & dietary supplement category alone has doubled over the last ten years
Complementary medicines exports have doubled over the last three years
82 TGA licensed manufacturing sites in Australia
12 700 direct high skilled jobs in complementary medicine products industry
36 441 employees across 29 natural therapy modalities
© Complementary Medicines Australia (2017)
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Introduction
Complementary Medicines Australia (CMA) is the peak industry body for the
complementary medicines industry, representing stakeholders across the value chain,
including manufacturers, raw material suppliers, distributors, consultants, retailers, allied
health professionals and educators. CMA promotes appropriate industry regulation and
advancement to ensure consumers have access to complementary medicines of the highest
quality.
Regulated in Australia as medicines under the Therapeutic Goods Act 1989, complementary
medicines include vitamins, mineral and nutritional supplements, homeopathic,
aromatherapy products and herbal medicines. The term ‘complementary medicines’ also
comprises traditional medicines, which includes traditional Chinese medicines, Ayurvedic,
Australian Indigenous and Western herbal medicines.
In response to the Treasurer's general invitation, CMA is pleased to submit its
recommendations for inclusion in the 2018-19 Budget.
Overview
The use of traditional and complementary medicines is growing worldwide, with the global
market expected to reach US$115 billion by 2020.ii Significant growth has been reported in
many countries, including the United States, Canada, across Asia – and in Australia. The
recent Australian complementary medicine industry audit shows that the industry has
generated revenues of $4.7 billion due to increasing interest and demand from consumers,
both in Australia and internationally.
Complementary medicines are an important and culturally acceptable part of healthcare
around the world, representing for many people an accessible, affordable way to actively
contribute to their health.iii The World Health Organization acknowledges that more
countries are coming to realise the contribution that traditional and complementary
medicines (T&CM) can make to the health and wellbeing of individuals and to the
comprehensiveness of their healthcare systems.
“Many countries now recognize the need to develop a cohesive and integrative approach to
health care that allows governments, health care practitioners, and, most importantly, those
who use health care services, to access T&CM in a safe, respectful, cost-efficient and
effective manner.”
(WHO traditional medicine strategy 2014-2023).
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Two significant trends are supporting the growth of the industry in the domestic market: an
ageing population and the challenge of increasing chronic disease; and the growing
awareness of the importance of preventive health. Increasingly, complementary medicines
are being found to contribute to improved health outcomes, through increased
effectiveness, safety and cost-effectiveness, and integration with conventional medical care.
Our export business has doubled in size in just two years, largely due to the growing
popularity of Australia’s high quality products in Asia. The high demand for Australian
natural health products has boosted jobs in the complementary medicines sector across a
range of areas, including manufacturing, scientific evaluation and research. Our industry
holds the ability to continue its positive growth trajectory, increasing highly skilled and
innovation rich local manufacturing, as well as providing a significant contribution to
Australian exports.
CMA believes that the 2018/19 Federal Budget provides an opportunity to:
1. facilitate industry growth and innovation via the implementation of the medicines
and medical devices regulation (MMDR) reforms;
2. focus on preventive health to build a more sustainable health system for Australia;
3. support the growth of our high-quality Australian exports; and
4. encourage and support greater innovation and investment in research.
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1. An Appropriate and Streamlined Regulatory Framework
Recommendation One: Facilitate industry growth and innovation via implementation of the
recommendations made by the Expert Panel Review of Medicines and Medical Devices Regulation
(MMDR) and accepted by Government.
In Australia, the regulation of complementary medicines falls within the remit of the
Therapeutic Goods Administration (TGA), which has the responsibility of regulation of all
therapeutic goods, including medicines and medical devices. The TGA is committed to
contributing to Australia’s health system through best practice regulation of health
products, and safeguarding the health of all Australians through effective, timely and risk
proportionate regulation of therapeutic goods.iv
The Australian regulatory regime for complementary medicines is such that it is viewed by
most countries as the consumer protection benchmark. In comparable countries, such as
the UK, USA and NZ, the standards for similar products are considerably lower, with many
treated as supplemented food, and manufactured and regulated accordingly. Whilst it is
considered by the majority of stakeholders that it is right and proper for complementary
medicines to be regulated by the TGA in Australia, ensuring strict quality and safety
standards for this category of health products, it does mean that over-regulation of these
low-risk products remains the biggest challenge facing the sector.
1.1 Medicines and Medical Devices Regulation Reforms to Reduce Red Tape
CMA has been supportive of the Review of Medicines and Medical Devices Regulation
(MMDR). The main objectives of the MMDR was to improve the timely and safe access to
quality therapeutic goods for consumers, whilst ensuring that any legislative framework is
commensurate with the risk of such goods, and to minimise the regulatory and
administration burden for business. This is consistent with the Australian Government’s
Industry Innovation and Competitiveness Agenda, recognising the need for Australia to
remain competitive on the global stage.
CMA would like to acknowledge the significant work that has been undertaken to date by
the TGA on the MMDR reforms.
1.2 Therapeutic Goods Amendment (2017 Measures No. 1) Bill 2017
The Therapeutic Goods Amendment (2017 Measures No. 1) Bill 2017 builds upon recent
amendments to the Therapeutic Goods Act 1989 to support the continued implementation
of the Government’s response to the MMDR. CMA is supportive of the Bill being passed
through parliament as it implements a range of important MMDR recommendations,
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including a new assessment pathway intended to encourage innovation and protect
investment in research. The Bill also replaces the existing complex complaints system with a
centralised mechanism within the TGA that includes tougher sanctions but decreases
regulatory and administrative burden for businesses.
1.3 New Assessment Pathway to Encourage Investment in R & D
The majority of complementary medicines currently sit within the listed AUST L category on
the Australian Register of Therapeutic Goods (ARTG). One of the MMDR recommendations
is for a new assessment pathway for including a medicine in the ARTG. The intention is for a
business to elect for their product, which contains ingredients already permitted in listed
AUST L medicines, to undergo pre-market assessment of a specific higher level health claim
or claims. This aims to encourage and reward greater investment in research by industry,
and be an incentive to further expand the clinical research base supporting the use of
complementary medicine products.
1.4 Advertising of Therapeutic Goods
The Government has accepted recommendation 55 of the MMDR, that the whole process of
vetting and pre-approval of advertising of therapeutic products to the public should be
stopped in favour of a more self-regulatory regime. CMA has supported the removal of
mandatory pre-approval requirements for several reasons, including reducing unnecessary
complexity for advertisers and to minimise excessive regulatory and financial burden upon
businesses. Implementation of stronger regulator enforcement powers and the
development of a sponsor education programme are expected to manage potential
concerns in implementing the recommendation.
1.5 MMDR Implementation Leading to Increased Regulation
CMA, on behalf of industry, has worked closely with the TGA to facilitate the MMDR
reforms. However, it must be noted that there are a number of areas where the proposed
implementation of the reforms remains a concern as the regulatory burden will increase,
with no foreseeable improvement in consumer protection or access to improved health
products. A number of the changes are not reflective of the aims of the MMDR to decrease
regulatory and administrative burden, and ensure that the legislative framework is
commensurate with the level of risk of therapeutic products. A large number of firms,
especially small and medium enterprises (SMEs) are concerned that the proposed regulatory
framework for complementary medicines will be one of rapidly escalating red tape rather
than the intended risk-proportionate and streamlined regulatory environment. Escalating
regulation is a keenly felt impost, especially when such regulation creates a large
disadvantage for local operators to compete globally.
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1.5.1 Permitted Indications
Work is underway to implement MMDR recommendation 38, which directs the TGA to
establish a list of ‘permitted indications’ from which sponsors must exclusively draw when
listing an AUST L product on the ARTG. The industry is very concerned that the list has
become too restrictive, which will create challenges for firms to continue to market and sell
the current range of products or to develop innovative new products. Removals or
restrictions from the permitted indications list will eliminate products from the listed
medicine space – where this occurs the product sponsor will have to opt for an application
under the new pathway with a $15 600 fee and higher efficacy requirements. This will result
in a regulatory cost to sponsors of preparing and submitting an application for the new
listed assessed pathway for indications that are currently allowed in the listed space.
The significance of the effects upon Australian businesses, particularly smaller and medium
sized entities, cannot be overstated. A number of medicines will not be able to transition to
the new pathway and will lose the ability to make their existing health claims. There is a
significant history of use of these indications on products that have been sold in the listed
space for many years, and no evidence of harm or need for increased regulation.
1.5.2 Removal of Products from TGA Regulation
The regulator has proposed the removal of homeopathic products from TGA regulatory
oversight, which would prevent these products from making any therapeutic claims and
impacts the core viability of manufacturers of these products. These are major decisions
that will affect the business interests of the wider industry and restrict access to these
medicines for consumers who choose to use homeopathic products. In addition to
traditional history of use, there is a growing body of good quality, peer-reviewed research to
demonstrate the effectiveness of homeopathic products as therapeutic goods.
CMA expects that a Regulatory Impact Statement (RIS) would be undertaken when there are
to be significant changes to ingredients or indications, due to the apparent regulatory
impact to businesses. The RIS exemption from the Office of Best Practice Regulation (OBPR)
was based on the deregulatory agenda in relation to the MMDR, noting that the purpose of
the MMDR was to reduce the regulatory burden upon industry and expedite access to
medicines, without compromising safety, quality or efficacy.
Recommendations
Implementation of the MMDR reforms to achieve a risk-proportionate and
streamlined regulatory framework to support industry innovation and growth.
Appropriate evaluation of the regulatory impact of the proposed changes.
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2. Focus on a Sustainable Health System
Recommendation Two: Focus on preventive health to build a more sustainable health system for Australia.
There is a need for increased Government funding for health prevention initiatives to improve the health and wellbeing of the community and create long term savings for the health budget.
Chronic disease is responsible for 83 per cent of all premature deaths in Australia and 66 per
cent of the burden of disease, making it the largest health challenge facing our nation.v Half
of all Australians already have at least one chronic disease, and with an ageing population,
the need to place a stronger focus upon preventive health is becoming increasingly
important.vivii
In 2013–14, only 1.4% of total health expenditure went towards public health activities,
which included prevention and health promotion, much of which was dedicated to
screening and immunisation programs. The proportion of health expenditure allocated to
public health has been declining since it peaked in 2007–08 (2.2%).viii
2.1 Complementary Medicines’ Role in Preventive Heath
There is now robust evidence in a number of areas that complementary medicines are a
cost-effective way to improve health outcomes. Individuals use complementary medicines
as adjunctive therapy to conventional medicines, to help manage chronic disease, prevent
the exacerbation of illness, and to optimise nutrition and wellbeing.
The complementary medicine industry supplies high quality vitamins and minerals that play
a significant role in disease prevention. Nutritional deficiencies have been linked to
increased risk for a number of conditions, including osteoporosis, neural tube defects and
depression.ix The 2011-12 Australian Health Survey identified that:
Nearly three quarters of females (73%) and half of all males (51%) aged two years
and over did not meet their calcium requirements based on their intakes from food.
Females are more likely to have inadequate iron intakes than males, with one in four
(23%) not meeting their requirements compared with one in thirty males (3%).
The 2017 McKell Institute report ‘Picking the low hanging fruit: Achieving a more equitable
and sustainable healthcare system’ finds that targeted evidence-based uptake of certain
complementary medicines would result in notable cost savings in Australia, whilst delivering
better health outcomes and greater equity.x Through addressing some of the social
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determinants of health, which includes having a poor diet, complementary medicines can
play a role in addressing long-term health budget pressures.
Increased uptake of vitamin D and calcium
In Australia, between 31% and 58% of the population is found to suffer from vitamin D
deficiency, despite the fortification of many foods with vitamin D.xi Vitamin D deficiency
has been linked to an increased prevalence of a number of chronic diseases, including
osteoporosis, diabetes and heart disease.xii The McKell Institute estimates that up to 8895
fractures annually could be avoided in Australia with increased uptake of vitamin D and
calcium, saving the Government up to $142 million in direct health costs.
Prenatal Vitamins
Folate, iodine and vitamin B3 are known to prevent neural tube defects. Current Australian
guidelines recommend routine supplementation of folate and iodine, with vitamin D and
iron supplementation for pregnant women with identified deficiencies. Maternal
malnutrition leads to adverse pregnancy outcomes and can lead to the long-term negative
impact upon growth and development during childhood and increases in risk of developing
chronic diseases later in life.
CMA supports the recommendation of increasing the uptake of pregnancy vitamins by low
income mothers to help address health inequalities, estimated by the McKell Institute to
cost between $26 million and $46 million per year, a small cost given the potential benefits
to health equity and long-term savings from stemming the rise in prevalence of chronic
diseases.
Cost effectiveness & Maximising Health Outcomes
There is a growing number of economic analyses that highlight the cost effectiveness of
complementary medicines. A 2014 Frost & Sullivan report, commissioned by ASMI, showed
that several of the more well-known complementary medicines were identified as being
able to reduce the relative risk of experiencing a medical event associated with common
conditions.xiii These include:
Magnesium and calcium/vitamin D combinations for osteoporosis
Lutein and zeaxanthin for age-related macular degeneration
Folic acid/B6/B12 and Omega-3s for cardiovascular disease
St John’s Wort for major depression
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2.2 National Preventive Health Body
CMA supports the call to re-establish a National Preventive Health Body to evaluate
evidence-based interventions at a population level. The best practice example is set by
England, where the National Institute of Health and Care Excellence (NICE) is responsible for
scrutinising the cost-effectiveness of preventive health interventions and monitoring their
outcomes. Re-establishing a preventive health body in Australia would be an important step
towards shifting the health focus from a reactive acute care model to empowering
Australians to take greater responsibility for protecting their health. A fundamental aim of
any health system should be to prevent disease and reduce ill health so that people remain
as healthy as possible for as long as possible.
Preventive health is also an essential move towards improving the cost-effectiveness of the
health care system, by improving Australians’ health and quality of life, reducing
preventable illness and building a more sustainable system for the Australian community. In
the case of complementary medicines, a thoughtful and rigorous strategy, led by the
preventive health body, would further demonstrate the cost-effectiveness and health
benefits of complementary medicines for contributing to the prevention and management
of chronic illnesses and improving public health.
2.3 Complementary Medicines Practitioners and Natural Therapies
Complementary medicine practitioners emphasise nutrition, lifestyle modifications, and the
importance of taking personal responsibility for heath as fundamental principles for
improving quality of life. Natural therapies are recognised by the World Health Organization
and by governments around the world as effective, appropriate and cost-effective solutions
to helping people manage their healthcare. Recent research conducted in Australia
demonstrated that the total number of client consultations is estimated at 16 million
annually, contributing over AUD$1.8 billion to the economy each year.xiv
In Australia, consumers have been increasingly choosing natural therapies as an element of
caring for their health, which is reflected by the complementary and natural therapies
sector outperforming the wider economy. The sector has seen strong growth: according to
IbisWorld (2016) IVA is forecast to grow at a compound annual rate of 4.8% over the 10
years through 2020-21, exceeding the overall economy's forecast real GDP growth of a 2.8%
compound annual growth over the same timeframe. xv
CMA noted the recent announcement of new private health reforms, which include the
cessation of coverage for natural therapies, including herbal medicine, naturopathy, tai chi
and yoga, all of which have a strong evidence base supporting their use to promote good
health. An analysis carried out by PricewaterhouseCoopers found that members across all
levels of hospital cover who also choose ancillary benefits for natural therapies claim $200
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per person less every year in hospital and medical costs; for members with top hospital
cover it was $430 per person less claimed if they chose ancillary benefits for natural
therapies. Ceasing the private health rebate for natural therapies, such as herbal medicine
and naturopathy, should be reconsidered in light of both consumer demand and the
evidence supporting the use of these natural therapies.
Recommendations
CMA supports the development of a strategy, in consultation with physician groups, to increase the uptake of vitamin D supplementation amongst at risk groups, and the introduction of a scheme to provide free vitamins during pregnancy through medical practitioners for women that hold concession cards.
Re-establish a national preventive health body to implement and evaluate population-wide prevention initiatives to improve the health and wellbeing of the community and provide long-term savings for the health budget.
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3. Supporting Growth of Australian Exports
Recommendation Three: Support further growth of our high-quality Australian
complementary medicines exports.
Government support programs are vital to assist Australian exporters to conduct business in
emerging and growth markets, and in terms of provision of advice, capacity building and
expediting export opportunities.
Over 60 per cent of Australian complementary medicine companies are involved in
exporting. The Australian industry has seen the value of complementary medicines exports
double in just 2 years, largely due to the growing popularity of Australia’s high quality
products in Asia. More than half of these exports are destined for China and Hong Kong,
with the top 5 export countries sitting in the Asia-Pacific region.xvi
The Asia-Pacific region is the largest market for complementary medicines products in the
world, and the demand for Australian complementary medicines is expected to remain
strong. Across the region, greater disposable incomes, ageing populations, increased chronic
disease, limited access to primary healthcare, and concerns about food safety and quality
are contributing to the growing demand for Australian complementary medicines.xvii
Chinese consumers’ demand for Australian complementary medicines and health foods has
been well publicised in recent years. The Chinese health food market alone – which includes
vitamins and minerals, herbal extracts and traditional Chinese medicine (TCM) – is currently
valued at US$30 billion and is projected to grow by 10 per cent every year until 2025.xviii The
Chinese Government has also made health a priority in its 13th Five-Year-Plan (2016-2020),
with a number of national initiatives that support demand for complementary medicines,
including adhering to the principle of ‘prevention first’, ensuring food and drug safety and
promotion of TCM.xix
Australian complementary medicines are seen as the benchmark for quality among
international consumers, thanks to Australia’s reputation for quality products and its clean
and well-regulated environment for food and medicines.xx The high demand for Australian
products has boosted jobs in the complementary medicines sector in Australia across a
range of areas, including manufacturing, scientific evaluation and research.
3.1 Support Programs for Exporters
CMA believes that government support programs are vital to assist Australian exporters to
conduct business in emerging and growth markets, and in terms of provision of advice,
capacity building and expediting export opportunities. Maintaining Austrade as a strong
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organisation is vital to Australia’s economy, as are the continued efforts by the Department
of Foreign Affairs and Trade to support Australian firms in building strong international
networks.
3.2 Trade Liberalisation
Continued trade liberalisation will present sizeable opportunities for the Australian
complementary medicines industry as the sector is well positioned to compete for emerging
opportunities. The industry recognises the importance of a strategic, collaborative approach
to International market engagement, leveraging of our strengths and facilitating strong
commercial ties, especially within the Asian region.
CMA also notes and strongly supports the growing focus of Australia’s free trade agreement
negotiations on helping to address ‘behind the border’ issues, and the Australian
Government’s goal of advocating for policy changes beyond other countries’ borders in
support of greater mutual understanding of national arrangements and a better interface
between regulatory frameworks and those of our neighbours.
3.3 Ingredients Grown in Australia
AgriFutures (formerly RIRDC) identifies and nurtures research, innovation and collaborative
efforts to support new and emerging opportunities for rural industries. This includes
support of the emerging Australian seaweed industry, tea tree oil, and native plants such as
wattle seed, Kakadu plum and native pepper. There is currently a large opportunity to
increase the market capacity for Australian grown raw materials for medicinal herbs and for
marine-based ingredients, underpinned by Australia’s ‘clean and green’ branding and
reputation for quality. CMA proposes targeted funding for AgriFutures to work with the
Australian complementary medicines industry, supporting additional research and
commercialisation to fully capture the opportunity of locally grown ingredients.
Recommendations
Maintain current investment in Austrade to support Australian exporters and
enhance Australia’s global competitiveness.
Targeted funding for AgriFutures to collaborate with the Australian complementary
medicines industry to increase locally grown ingredients.
Build on the momentum of the ChAFTA and continue to pursue trade liberalisation
in the Asian region.
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4. Encouraging and supporting innovation and investment in research
Recommendation Four: Encouraging and supporting innovation and investment in research.
Australia holds the potential to be an international leader in complementary medicines
research and translation into both commercial and health policy outcomes.
The complementary medicines industry contributes to employment opportunities and
development of a range of technical and vocational skills through innovation, research and
the utilisation of complex technologies. With the high international demand for Australian
complementary medicines, the sector holds great potential to continue to expand,
contributing further to the strength of our high-skilled local manufacturing. Despite the
positive growth story, the sector in Australia is facing a number of challenges, including the
need to remain globally competitive. Our industry must consistently produce innovative and
value-added products in order to compete internationally.
4.1 Funding for Complementary Medicine Researchers
As recognised by the National Innovation and Science Agenda, Australia has been poor at
translating research into commercial outcomes and ranks low among OECD countries for
measures of commercialisation and business-research collaboration.
Our nation holds the potential to be an international leader in complementary medicines
research and translation into both commercial and health policy outcomes. Australia has
world class academic and research bodies, including two five-star Australian Research
Council recognised institutions, the National Institute of Complementary Medicines and the
Australian Research Centre in Complementary and Integrative Medicine. Australia also
boasts exceptional research centres outside of the university sector, such as the Endeavour
College of Natural Health and the Blackmores Institute.
For every dollar invested in Australian health research and development, $2.17 in health
benefits is returned.xxi Given the potential benefits of complementary medicines as a tool
towards health promotion and disease prevention, complementary medicines research
should be a priority area for funding.
4.2 R&D Tax Incentive
Continued support for innovation in the health care sector is vital to improving productivity
and boosting competitiveness. In the complementary medicines sector, encouraging
business expenditure on research and development will help Australia capture the growing
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market for these products, nationally and internationally, as well as provide significant
economic and health benefits for Australians.
The R&D tax incentive encourages companies to engage in R&D to benefit Australia, and is
important for both supporting SMEs and for attracting multinational firms to invest in R&D
activities in Australia.
Recommendations
Beyond the general need for increased funding support for public health research in
Australia, we suggest that particular areas of research priority include targeted
additional support for complementary medicine research groups.
Maintain the R&D tax incentive in its current form to support R&D activities in
Australia.
Final Word
CMA is also a signatory to and supports the submission made by ARCS on behalf of the
wider medicines and medical technology sector.
CMA appreciates the opportunity to make this submission and feed into the budget process.
Please do not hesitate to contact me should you require additional information or have any
queries in relation to this submission.
Carl Gibson
Chief Executive Officer
Complementary Medicines Australia
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i Complementary Medicines Australia (2017) Healthy People, Healthy Growth. Complementary Medicines Industry Audit 2017. ii Ung, C., Harnett, J. (2017). Community pharmacist’s responsibilities with regards to traditional
medicine/complementary medicine products: A systematic literature review. Research in Social and Administrative Pharmacy 13 686-716 iii Commonwealth of Australia (2017) Complementary Medicines Industry Capability Report.
iv Therapeutic Goods Administration (2017) Therapeutic Goods Administration Business Plan 2017-18
v Jackson H, Shiell A. (2017) Preventive health: How much does Australia spend and is it enough? Canberra:
Foundation for Alcohol Research and Education vi Australian Government. (2015). New stats reveal 50% of Australians battling disease. Accessed from
https://www.health.gov.au/internet/ministers/publishing.nsf/Content/health-mediarel-yr2015-ley100.htm vii
McKell Institute (2017). Picking the Low-Hanging Fruit. Achieving a More Equitable and Sustainable Health Care System. viii
AIHW (2016) Australian Institute of Health and Welfare 2016. Australia’s health 2016. Australia’s health series no. 15. Cat. no. AUS 199. Canberra: AIHW ix Nieves, 2005; Pitkin, 2007; Sarris et al, 2015: Stover, Berry & Filed, 2016, in McKell Institute (2017). Picking
the low-hanging fruit: Achieving a more equitable and sustainable health care system. Equity Economics, Sydney. x McKell Institute (2017). Picking the low-hanging fruit: Achieving a more equitable and sustainable health care
system. Equity Economics, Sydney. xi Boyages, S.C. (2016). Vitamin D testing: new targeted guidelines stem the overtesting tide. MJA 204 (1) doe:
10.5694/mja15.00497 xii
McKell Institute (2017). Picking the low-hanging fruit: Achieving a more equitable and sustainable health care system. Equity Economics, Sydney. xiii
Frost & Sullivan (2014) Targeted Use of Complementary Medicines: Potential Health Care Outcomes & Cost Savings in Australia. xiv
The Practitioner Research and Collaboration Initiative (PRACI) https://praci.com.au xv
IbisWorld. (2016). Alternative Health Therapies in Australia: Market Research Report http://www.ibisworld.com.au/industry/default.aspx?indid=1914 xvi
Austrade (2017) Annual Export Statistics: Vitamins & Supplements. Year ended December 2016 xvii
Commonwealth of Australia (2017) Complementary Medicines Industry Capability Report. xviii
Austrade (2017) Complementary Medicines in China: A guide for Australian business xix
ibid xx
Commonwealth of Australia (2017) Complementary Medicines Industry Capability Report. xxi
Access Economics. (2008). Exceptional Returns: The Value of Investing in Health R&D in Australia.