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In July 2024, AHPA SA Branch made a submission to a South Australian Government consultation on a draft Preventive Health SA Bill.

The submission was prepared by Talia Blythman (Co-President), Belinda Lunnay (Vice President), Melinda Edmunds (National President), and Caroline Adams.

1. The draft Bill has been designed to ensure prevention is an important and permanent part of the infrastructure of the health system in South Australia, embedding preventive health policy, action and resourcing for long term and sustainable outcomes. How likely is it that the wording in the draft Bill will enable this?

a. Are there specific areas of the draft Bill that require clarification or strengthening?

The South Australian Branch of the Australian Health Promotion Association® (henceforth AHPA SA) commends Preventive Health SA for the draft Bill. AHPA SA is encouraged by this work to ensure prevention is an important and permanent part of the infrastructure of the health system in South Australia.

The Australian Health Promotion Association is the only professional association specifically for people interested or involved in the practice, policy, research and study of health promotion. AHPA SA espouses AHPA’s aims:

  • To support the professional development of members, facilitating knowledge exchange through the provision of high quality publications and opportunities to network and build knowledge
  • To contribute to discussion, debate and decision-making on health promotion policy, practice and research and advocate for evidence-informed approaches
  • To make recommendations with respect to the standards and practice of health promotion as well as the training of health promotion practitioners.

Within this remit, AHPA SA supports the statement in the draft Bill regarding the allocation of ‘sufficient funding and other resources’ and suggests that the nature of these ‘other resources’ requires clarification and strengthening.

Resources are required that specifically enable the advancement of the health promotion profession and the preventive health workforce to allow advocacy for health promotion. Resources are required that build the professional capacity of health promotion professionals such as AHPA members who work within Preventive Health SA and to support career pathways in health promotion that promote equity, diversity, and inclusion. We suggest some examples of resource type are provided and in particular, that the word ‘workforce’ is included as a resource in the draft Bill.

Herriot, Schirmer and Velardo (2022) outline a three-tiered conceptualisation of the health promotion workforce which provides important context when considering the structure of the preventive health workforce.

  • Tier 1: Health Promotion practitioners and specialists have demonstrable experience working in health promotion and likely hold a relevant degree.
  • Tier 2: Wider health promotion workforce whose role incorporates some health promotion activities.
  • Tier 3: Influences of social determinants of health whose primary role is not health promotion but whose policies greatly impact upon the determinants of health and equity.

On the topic of resources, we recommend that qualification is provided within the Bill about how much resourcing is allocated. AHPA SA is a member of the SA Public Health Consortium. As stated in the 2022 State Election Platform (2022), the Consortium seeks commitment to increased investment in public health, prevention, and promotion with 5% of health expenditure to be allocated toward disease prevention and health promotion. This aligns with the Australian Government, Department of Health, National Preventive Health Strategy 2021-2030 which stated that an ‘investment in preventive health will rise to be 5% expenditure across Commonwealth, state and territory governments by 2030 (Department of Health, 2021).’

A 5% investment of the SA health budget within prevention will ensure South Australia is equipped to address the priority areas of Preventive Health SA. There is ever-growing evidence that initiatives that prevent illness are cost effective (Jackson & Shiell, 2017; Knapp & McDaid, 2009). AHPA has developed an infographic that highlights the cost effectiveness of investing in health promotion (AHPA, 2023). Every $1 invested in health promotion and illness prevention delivers $14.30 in benefits (AHPA, 2023). The benefits of preventive health initiatives reduce the burden on public spending and increase productivity (Merkur, Sassi, & McDaid, 2013). Further to this, AHPA SA suggests the Bill contains a clause concerning monitoring and public reporting of Preventive Health SA’s investment and expenditure on preventive health and wellbeing.

b. Are there aspects missing from the draft Bill that should be considered for inclusion?

AHPA SA recommends that the draft Bill incorporates a function for the Chief Executive to purposefully build the capacity and secure a competent preventive health workforce into the future.

AHPA SA realises there is complexity in achieving the priority areas identified for Preventive Health SA including addressing the social, political, and commercial determinants of health and that this requires a vision of health in all policies. Preventive Health SA needs to be supported by a competent preventive health workforce in order to undertake a comprehensive, systematic approach. This aligns with the National Preventive Health Strategy priority that by 2030 “the public health workforce is ‘future proofed’ through the enhancement of the availability, distribution, capacity and skills of the workforce’ (Department of Health, 2021).

Preventive Health SA and AHPA recently collaborated to build the capacity and support the preventive health workforce. AHPA was commissioned by Wellbeing SA in 2022 to develop ‘an evidence-informed review to support the development of the South Australian health promotion workforce strategy (Herriot, Schirmer & Velardo, 2022).’ Incorporating a function of the Chief Executive to build the capacity of the preventive health workforce would ensure workforce development remains a key focus of Preventive Health SA both now and into the future. This will support the ongoing implementation of the recommendations made in this review which includes the development of a Health Promotion Workforce Strategy for South Australia in collaboration with key partners.

Another of the review recommendations was that Preventive Health SA and AHPA collaborate to support the workforce of Preventive Health SA to become International Union for Health Promotion and Education (IUHPE) Registered Health Promotion Practitioners (Herriot, Schirmer & Velardo, 2022). This process has commenced in accordance with the review recommendation to ‘advocate for, promote and support the Registration of Health Promotion Practitioners in SA’. As also recommended in the review, it is critical to plan and implement workforce development strategies for all 3 Tiers of the Health Promotion workforce to effectively address the wider determinants of health (Herriot, Schirmer & Velardo, 2022). We note the importance of ensuring Health Promotion practitioner roles are created for the preventive health workforce (and prospective workforce) and this includes the provision of roles for new graduates. We call for the Bill to reflect this important work of building the capacity of the preventive health workforce to ensure that it is ongoing.

2. Do you have any comments about:

a. The Objects?

AHPA SA supports the Objects of the draft Bill.

We recommend the terminology ‘public health and illness prevention’ is utilised in the Bill rather than ‘non-communicable health conditions’ as this language moves away from individual health conditions and is more inclusive of work to address the wider determinants of health. Health Promotion is a core function of public health which addresses health challenges through building healthy public policies, creating supportive environments, strengthening community action, and building personal skills (World Health Organisation, 2012).

b. Functions of the Chief Executive for Preventive Health SA?

AHPA SA supports the functions of the Chief Executive.

We recommend that an additional role be added which is to build the capacity of the preventive health workforce now and into the future. AHPA SA would look forward to supporting the Chief Executive with this endeavor through our professional development activities.

c. The Preventive Health SA Council?

AHPA SA supports the Preventive Health SA Council statements. We call for the Preventive Health SA Council to include a person with expertise in health promotion and/or in addressing the social determinants of health. We also recommend that the recruitment of the board is undertaken utilising a merit-selection or other such transparent process and that this process is detailed in the draft Bill.

3. The draft Bill seeks to strengthen collaborative action across government and non-government agencies on prevention. Do you think the wording in the draft Bill will enable this? What, if anything, could be considered to strengthen this approach?

AHPA SA supports the wording in the draft Bill to ‘strengthen collaborative action across government and non-government agencies’. We know health is significantly affected by factors outside the health sector (housing, transport, the environment, education, and employment) and impacts on people’s ability to make healthy choices. Action undertaken must be done both within and outside of the health sector, including with the community and people with lived experience. Collaborative action is central to addressing the wider determinants of health.

To strengthen this approach, AHPA SA recommends that clear and ongoing processes are established to support the collaboration between Preventive Health SA and external agencies such as AHPA SA (and also PHAA, SACOSS, Cancer Council all of whom are our partner). We recommend the Bill contains a schedule for regular (e.g., bi-annual) meetings between Preventive Health SA and external agencies to allow for updates and to streamline communication pathways thereby enhancing collaboration opportunities. We also suggest Preventive Health SA enable regular communication to share the work of Preventive Health SA with external agencies including mediums such as a quarterly newsletter.

AHPA SA also recommends that Preventive Health SA specifies instances of consultation and collaboration with community members within the draft Bill to ensure community engagement and community contributions toward Preventive Health SA strategic plans and initiatives. This aligns with our feedback provided in a recent submission regarding the development of the National Consumer Engagement Strategy National_Consumer_Engagement_Strategy_SEPT.pdf ( (Lunnay et al, 2023). A National Preventive Health Strategy (2021) priority states that by 2030 ‘partnerships with the community are strengthened and informed by a national consumer engagement strategy that prioritises co-design approaches.’

4. Which aspects, if any, of the draft Bill align or support current or future prevention activities or initiatives which your agency is involved in planning or delivering?

Several aspects of the draft Bill align with and support AHPA SA activities and initiatives. This includes: Functions of the Chief Executive to ‘improve health equity in partnership with government and non-Government bodies’ and ‘to develop partnerships and collaborate with other agencies, and be the primary source of advice to the Minister and government, in relation to preventive health policies and action’. These functions directly align with and reflect AHPA SA activities and initiatives. AHPA SA undertakes a range of advocacy and collaboration activities through our membership designed to support and advise on actions to increase health equity. Recent examples include our submissions to provide feedback on National and State level policies with the view to improve health equity e.g., National Consumer Engagement Strategy (Lunnay et al., 2023), Proposed restriction of unhealthy food and drink advertising on South Australian buses, trams and trains (AHPA SA, 2024), and the worsening rental crisis in Australia (Flavel et al., 2023).

The draft Bill also maintains a focus to ‘undertake, commission or support research in areas of preventive health and wellbeing.’ This aligns and supports current initiatives undertaken by AHPA including our official publication the Health Promotion Journal of Australia (HPJA). HPJA facilitates communication between researchers, practitioners and policymakers involved in health promotion and preventive health activities. It prioritises the publication of practical examples of policies, theories, strategies and programs and submissions from Preventive Health SA are strongly encouraged. AHPA SA are also working with the Public Health Association of Australia SA Branch and other key agencies to host the SA Population Health Conference this year in October. Preventive Health SA are a key sponsor of this event and numerous members of their workforce will be present at the event. This conference provides a workforce development opportunity for the preventive health workforce in South Australia that aligns with the core competency areas highlighted by The International Union for Health Promotion and Education. Furthermore, AHPA’s National Health Promotion Symposium is scheduled to be held in Canberra this year. Marina Bowshall, Interim Chief Executive of Preventive Health SA will be a key expert speaker at this event alongside other health promotion agency leaders from Victoria (VicHealth), Queensland and New Zealand. It is excellent to have this preventive health leadership and collaboration from Marina and Preventive Health SA with the Health Promotion Community at a national and international level.

5. Which aspects, if any, of the draft Bill will enable and encourage your agency to support preventive health action and positive health and wellbeing outcomes?

A function of the Chief Executive is ‘to collect, monitor and support the sharing of population level health and wellbeing data and analyses to inform evidence-based practice in preventive health and wellbeing.’ This aspect will enable AHPA SA to identify and respond to local contexts and conditions for preventive health activity including opportunities to address health inequities. AHPA SA recommends that population health and wellbeing data collected at a state level is in alignment with the ‘Measuring What Matters: Australia’s First National Wellbeing Framework’ (Australian Government, 2023). Consistency in the data collected allows for sharing of data across jurisdictions in a meaningful way.

6. Do you have any other suggestions or feedback regarding the draft Bill?

AHPA SA commends Preventive Health SA for this work on the draft Bill and the process undertaken to consult toward its development. AHPA SA appreciates the opportunity to attend an information session and to ask questions alongside other key external agencies, prior to submitting our written feedback herein. We welcome the opportunity to continue working in collaboration with Preventive Health SA, including with future strategic planning processes.

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