Response 419446658

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Introduction

1. What is your name?

Name
Natasha Donnolley

3. Please tell us whether you are providing a submission as an individual, health professional or on behalf of an organisation

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6. In which State or Territory do you live or does your organisation operate?

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7. The Department of Health would like your permission to publish your consultation response. Please indicate your publishing response.

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About the document

8. Is the language used in the Plan appropriate and easily understood?

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9. Is the vision appropriate for the Plan?

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10. Is the overarching goal appropriate for the Plan?

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11. Please provide further comment/feedback on the Plan's language, vision, overarching goal; and priority areas? Include identified gaps and any significant strengths and weakness?

(answer in dot point format, maximum 200 words)
The vision and language are fine. I think the goal needs to be more specific - is it aiming to reduce the rate of all stillbirths by 20% or only late gestation stillbirths (eg >28 weeks)?

Priority Area 1 - Ensuring high quality stillbirth prevention and care

13. Are the action areas appropriate for Priority Area 1: Ensuring high quality stillbirth prevention and care?

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14. Are the goals appropriate for Priority Area 1: Ensuring high quality stillbirth prevention and care?

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15. Are the implementation tasks appropriate for Priority Area 1: Ensuring high quality stillbirth prevention and care?

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16. Please outline any changes you consider should be made to the existing action areas, goals or implementation tasks that would be relevant to and Priority Area 1: Ensuring high quality stillbirth prevention and care.

(answer in dot point format, maximum 200 word)
There needs to be more specific and measurable tasks related to the provision of and access to midwifery continuity of carer. It is the ONLY model of care that has the research evidence to support a reduction in stillbirth. It is not just continuity of care. The language is too vague to achieve the goal that has been set for this area.
There needs to be a more specific goal and tasks related to Birthing on Country for Aboriginal and Torres Strait Islander women. The goal and tasks need to be more specific than just increasing access to culturally appropriate care - why is Birthing on Country not mentioned?

17. Please identify any additional action areas, goals or implementation tasks that would be relevant to Priority Area 1: Ensuring high quality stillbirth prevention and care.

(answer in dot point format, maximum 200 words)
There needs to be a stronger commitment and resourcing for perinatal mortality review and audit - noting that it is also covered in other action areas. However there are no strong tasks that set a target for implementation of a national audit program, or even jurisdictional level programs.
There should be a target on the availability of Birthing on Country models of care.

Priority Area 2 - Raising awareness and strengthening education

18. Are the action areas appropriate for Priority Area 2 - Raising awareness and strengthening education.

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19. Are the goals appropriate for Priority Area 2 - Raising awareness and strengthening education?

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20. Are the implementation tasks appropriate for Priority Area 2 - Raising awareness and strengthening education?

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21. Please outline any changes you consider should be made to the existing action areas, goals or implementation tasks that would be relevant to and Priority Area 2 - Raising awareness and strengthening education.

(answer in dot point format, maximum 200 words)
The Commonwealth should be funding and running a public awareness campaign using community service announcement etc. on television, public transport etc to de-stigmatise stillbirth and increase community awareness.

Priority Area 3 - Improving holistic bereavement care and community support following stillbirth

23. Are the action areas appropriate for Priority Area 3 - Improving holistic bereavement care and community support following stillbirth?

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24. Are the goals appropriate for Priority Area 3 - Improving holistic bereavement care and community support following stillbirth?

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25. Are the implementation tasks appropriate for Priority Area 3 - Improving holistic bereavement care and community support following stillbirth?

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Priority Area 4 - Improving stillbirth reporting and data collection

28. Are the action areas appropriate for Priority Area 4 - Improving stillbirth reporting and data collection?

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29. Are the goals appropriate for Priority Area 4 - Improving stillbirth reporting and data collection?

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30. Are the implementation tasks appropriate for Priority Area 4 - Improving stillbirth reporting and data collection?

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32. Please identify any additional action areas, goals or implementation tasks that would be relevant to Priority Area 4 - Improving stillbirth reporting and data collection.

(answer in dot point format, maximum 200 words)
There should be regular (annual or biannual) state-based focus reports on stillbirth as well as national reporting that are done in a timely manner (eg not 3 years after the event).
The ABS data that is derived from the RBDMs needs to be updated after perinatal mortality review and partially-registered stillbirths need to be followed up to ensure they are fully-registered and counted in ABS reporting
The Australian Perinatal Mortality Audit Tool needs to be implemented in all jurisdictions.
Jurisdictions should be funding their own central perinatal mortality review and audit team to coordinate review and audit across their state/territory to ensure timely and complete capture of information, including from parents, and more comprehensive reporting on contributing factors.

Priority Area 5 - Prioritising stillbirth research

33. Are the action areas appropriate for Priority Area 5: Prioritising stillbirth research?

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34. Are the goals appropriate for Priority Area 5: Prioritising stillbirth research?

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35. Are the implementation tasks appropriate for Priority Area 5: Prioritising stillbirth research?

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37. Please identify any additional action areas, goals or implementation tasks that would be relevant to Priority Area 5: Prioritising stillbirth research.

(answer in dot point format, maximum 200 words)
The development of an enduring linked data platform for epidemiological research using routinely collected data, including but not limited to the National Perinatal Data Collection (including mortality review data), Admitted Patient Data Collection, National Death Index, MBS, PBS, Emergency data collection. Improving access to big data on an ongoing basis would improve the ability to do stillbirth research, including development of a risk prediction model.