15 December 2020

COVID and National Security

The report by the Victorian Legislative Council  Legal and Social Issues Committee into the Victorian Government’s COVID–19 contact tracing system and testing regime deals with the Committee's reference 

to inquire into, consider and monitor the capacity and fitness for purpose of the Victorian Government’s COVID-19 contact tracing system and testing regime, and in doing so consult with businesses, including small business representatives, the community sector and Victoria’s multicultural communities

It features the following Findings and recommendations 

Why did the Committee undertake this inquiry? 

FINDING 1: Despite the effective elimination of the COVID-19 virus in Victoria after a second wave of infections, Victorians need to be confident that the public health system is prepared to effectively respond to new COVID-19 outbreaks. 

RECOMMENDATION 1: That the Government engage with the evidence from the experience of the pandemic that our public health system requires review, testing and enhancement and a more decentralised, community-based approach to fulfil its function of identifying and preventing or minimising public health risks to the community.  

What did this inquiry not address and why? 

FINDING 2: A robust response to COVID-19 in any jurisdiction should include a multi-tiered approach. Contact tracing and testing are only two, albeit critical, elements amongst a range of necessary measures in effective communicable disease control. 

RECOMMENDATION 2: That the Public Accounts and Estimates Committee examine the following issues in depth during their inquiry into the COVID-19 pandemic response: • Wrap-around services that could be implemented to support individuals who are unable to isolate in a hotel setting because of health reasons. • The cost effectiveness of the contact tracing system and testing regime including examining ongoing contracts and their efficacy. • The impact of restrictions that have been implemented, including determining if their benefits have outweighed the social; physical and psychological health; and economic outcomes. 

How has Victoria’s contact tracing system and testing regime evolved since January 2020? 

FINDING 3: Contact tracing is part of a wider process of detection of positive cases and isolation of close contacts. While it is important to identify, or ‘trace’ the contacts of a confirmed positive case, the communication, engagement, and information provided by government about isolation processes and contact tracing itself are important factors that must be embedded within effective contact tracing management. 

FINDING 4: Maintaining ease of access to testing will give Victorians confidence that they can be tested without delay. 

RECOMMENDATION 3: That the Victorian Government ensure that Victoria’s testing regime includes diverse processes for different cohorts and testing sites have good territorial reach. 

FINDING 5: All of Metropolitan Melbourne should be within 10km of a fixed-testing site and there should be significant coverage with testing sites across regional and rural Victoria. 

FINDING 6: Some general practitioners initiated and undertook asymptomatic testing in their communities. 

FINDING 7: The Victorian Government is developing alternative testing modalities including at-home testing, rapid response testing, surveillance testing, asymptomatic testing and wastewater testing. 

FINDING 8: Asymptomatic testing is an important tool for an enhanced testing regime. 

RECOMMENDATION 4: Asymptomatic testing should continue to be voluntary for all Victorians. 

FINDING 9: The Victorian Government did not initiate wastewater surveillance until after the second wave. 

RECOMMENDATION 5: Pending further research into its validity, the Victorian Government should continue to incorporate wastewater testing into an ongoing disease surveillance program.   

RECOMMENDATION 6: The Committee encourages further research into and development of saliva testing technology and other non-invasive, quick turn-around technologies, for wider roll out in industry and time-critical situations. 

FINDING 10: The use of manual data entry processes at the beginning of the pandemic meant that the system for contact tracing and recording of testing was not fit to deal with any escalation in cases and led to significant errors. 

FINDING 11: Salesforce first introduced their end-to-end system to the Victorian Government in March 2020. 

FINDING 12: The Victorian Government engaged IBM for an analytics platform. The Committee regards the engagement as a misguided and costly mistake given the platform’s known lack of AI capacity. 

FINDING 13: Appropriate data capture systems are now being rolled out throughout the state, however the length of time between the first COVID-19 case in Victoria on 25 January 2020 and the rollout of a digital test tracking system piloted in September and October 2020 is disappointing and inadequate. 

FINDING 14: Victoria’s redeveloped contact tracing system demonstrates that the Victorian Government responded to lessons learnt throughout the pandemic. Nevertheless, further refinements are needed to ensure that it is fit for purpose. 

FINDING 15: Local knowledge is an indispensable tool in establishing an efficient contact tracing system and broader public health response. Regional presence and local case managers are essential for establishing and maintaining a robust system of contact tracing and testing. Such an approach would have facilitated greater awareness of interactions of community members had it been in place before the height of the pandemic. 

FINDING 16: Victoria’s highly centralised healthcare system did not have the means to deal with regional cases effectively, which contributed to confusion and delays in contact tracing and test result management. 

RECOMMENDATION 7: That the Victorian Government participate in the development, establishment and use of a national contact tracing Data Exchange as recommended by the National Contact Tracing Review. 

What are the key performance indicators and benchmarks for COVID‐19 contact tracing and testing? 

RECOMMENDATION 8: That the Victorian Government is guided by the following indicators in relation to the ongoing development of their testing regime so that Victorians can be confident that the regime has capacity: • easily accessible and reliable tests with clear criteria for getting tested • tests are accurately recorded, and results are received by the patient within 24 hours • surge workforce is available at short notice • multiple testing strategies can be deployed (fixed, rapid response, mobile units). 

FINDING 18: Test results should be available within 24 hours of a sample being taken, maximising the likelihood that people will isolate themselves while awaiting test results. It should be no more than 48 hours in total from the time a test sample is first taken to the point at which close contacts of a confirmed case are notified that they must quarantine. Victoria is sitting well within the optimal range in relation to these metrics at present. 

FINDING 19: The following are indicators of a contact tracing system that has the capacity to respond to a range of COVID-19 scenarios: • The system can manage four new cases per day per million population (stress tested). It should be extreme stress tested at ten times the number (40 new cases per day per million population). • The number of hours from collecting the positive specimen to notifying the patient of their results should be less than 24 hours. • The number of hours from collecting the patient’s COVID-19 specimen to notifying their close contacts that they must quarantine is fewer than 48 hours for more than 90% of cases (both of these measures should be qualified with at least 80% of primary close contacts being notified). 

FINDING 17: Data Exchange is required to assist effective contact tracing between jurisdictions to manage future outbreaks. 

How does Victoria measure up against key performance indicators and benchmarks? 

RECOMMENDATION 9: That the Victorian Government be guided by the following indicators in relation to the ongoing development of a contact tracing system so that Victorians can be confident that it is fit for purpose: • facilitates multilingual communications through in-language resources • cost-effectiveness • technology captures nuances for each case and contact (number of persons per household, language, quarantine stage, time since test and more) • risk-based prioritisation during super surges • capacity to analyse data and identify links. 

FINDING 20: An effective contact tracing system relies on a highly trained and qualified workforce built from a jurisdiction’s existing public health sector. This should be extended to a surge workforce where possible, or alternatively training tools should be developed to ensure that people employed as part of a surge workforce are properly equipped to manage contact tracing. 

FINDING 21: Victoria is well placed to continue to provide accessible testing in relation to proximity and cost and has established a capacity to collect a high volume of PCR tests. 

FINDING 22: The Victorian Government has increased its capacity to manage a greater number of tests within the recommended timeframe between samples taken and results being received. 

FINDING 23: The current COVID-19 testing regime is fit for purpose to monitor, process, identify, record and communicate up to 15,000 test results per day within a 24-hour window. The Victorian Government is investing in additional capacity which would allow 35,000 tests to be processed per day. 

FINDING 24: The introduction of a Customer Relationship Management system was a highly effective measure to facilitate rapid contact tracing. 

FINDING 25: The external workforces contracted to provide system support were not a cost-effective choice, nor were some of those employed qualified to understand all the public health elements of the role. 

RECOMMENDATION 10: That the Victorian Government conduct modelling studies on its digital contact tracing system to better understand its expected and potential capacity. The results of these studies should be made public. 

FINDING 26: Due to the late commencement of implementation of a digital contact tracing system at the end of August 2020, the Committee was unable to determine if the system has the appropriate responsiveness and robustness. 

RECOMMENDATION 11: That the Victorian Government establish a trained reserve workforce for future public health emergencies. 

FINDING 27: The adoption of an end-to-end automated process for enabling and recording contact tracing and testing results occurred too late - after the second wave of infections in Victoria. This is despite approaches by technology providers with proven capacity in other contexts and jurisdictions made early in the Victorian pandemic. 

FINDING 28: Scalability is a key measure in an adaptable and fit for purpose testing and contact tracing system. This includes technical capability, testing and pathology capacity, and a flexible workforce that can be activated or scaled down on short notice. 

FINDING 29: Assessing the capacity and effectiveness of contact tracing is difficult because the system has only recently been redeveloped and some functions are yet to be rolled out and tested with the arrival of international positive cases. 

What issues have been raised about contact tracing and testing in Victoria, and have they been resolved? 

FINDING 30: The Victorian Government had previously received reports which identified the need for additional contact tracing staffing resources but to the Committee’s knowledge did not act on them. 

RECOMMENDATION 12: That the Victorian Government increase the number of staff in the Department of Health and Human Service’s public health units and contact tracing teams so that it is line with current recommendations. 

FINDING 31: Despite the availability of the Victorian health management plan for pandemic influenza since 2014, there has been limited investment in and commitment to pandemic preparedness from the Victorian Government. This has resulted in the public health response and contact tracing being driven by a reactive crisis response leading to poor decision-making and unnecessary delays. 

FINDING 32: Greater transparency in relation to processes and a willingness to acknowledge and take responsibility for failings by the Victorian Government would increase public trust and confidence in the capacity of the contact tracing system and testing regime. 

FINDING 33: There was a lack of transparency from the Victorian Government in relation to the cost of the testing regime. 

FINDING 34: The Committee was unable to determine if the system was cost-effective with the data supplied to the inquiry . 

RECOMMENDATION 13: That the Victorian Government publish accurate records of financial commitments and costings involved with the testing regime and contact tracing system, including resourcing and staffing by third parties. 

FINDING 35: The Victorian Government testing regime exceeded its capacity, both in public and private pathology labs, at the beginning of, and throughout, the second wave. 

FINDING 36: A lack of clear communication and conflicting advice about testing criteria from Federal and State government agencies was an obstacle to Victorians accessing testing and prevented some healthcare providers delivering testing services. 

RECOMMENDATION 14: That the Victorian Government engage in further consultation with other jurisdictions to ensure consistency of testing criteria. 

FINDING 37: The Victorian Government was significantly underprepared to effectively collect, manage and utilise the key data required to accurately understand the State’s performance up to October 2020. 

FINDING 38: Appropriate data capture systems are being rolled out throughout the state, however the time between the first COVID-19 test in Victoria and the rollout of a test tracking system is insufficient and inadequate. 

RECOMMENDATION 15: That the Victorian Government mandate the use of Test Tracker for all test sites and develop real-time reporting between Test Tracker and the appropriate databases. 

FINDING 39: More transparency from the Victorian Government would increase public trust and confidence in the capacity of the testing regime and contact tracing system. 

RECOMMENDATION 16: That the Victorian Government provide evidence to the Victorian public about the basis of its contact tracing and testing response to COVID-19 in relation to operational processes implemented and procurement decisions. 

FINDING 40: General practitioners were not consulted in the development of the contact tracing system and testing regime or formally involved in developing or supporting the official crisis response. Excluding general practitioners from the official system of contact tracing and the testing regime led to a less effective, less responsive and potentially more costly response to COVID-19. 

FINDING 41: Because general practitioners were excluded from the official response to COVID-19 the system did not include effective measures to ensure general practices were made aware of positive cases amongst their patient cohort. 

RECOMMENDATION 17: That the Victorian Government, through the Chief Medical Officer, embed general practitioners into the system of management of contact tracing and testing as part of a localised, collaborative and more person-centred approach. 

FINDING 42: By better engaging with trusted representatives throughout the community, the Government may have been able to prevent widespread transmission through vulnerable communities. The Government’s approach to culturally and linguistically diverse communities was a failure to coordinate a system effective for all Victorians. Greater work needs to be done to ensure the testing regime and contact tracing system is fit for purpose to and makes genuine provisions for all Victorians. 

FINDING 43: The Victorian Government’s CALD Community Task Force was established and includes multicultural and multifaith leaders. 

RECOMMENDATION 18: That the Victorian Government’s CALD Community Task Force include health workers such as general practitioners. 

FINDING 44: Community leaders, including general practitioners, are trusted voices in their communities and can assist with ensuring their communities understand the processes of COVID-19 testing and contact tracing. 

FINDING 45: Due to a lack of clear and accessible guidance from the Victorian Government some eligible small businesses are not aware of their legislative obligations to assist contact tracing by recording personal information of any persons on their premises for over 15 minutes. 

RECOMMENDATION 19: That the Victorian Government work with unions, industry groups and associations to develop clear and accessible guidance for businesses on their obligations for contact tracing record keeping, particularly around setting up and using digital systems such as QR codes. 

FINDING 46: Businesses that record personal information for contact tracing must store the information for 28 days, unless another statutory requirement requires it to be retained. After 28 days, this information must be destroyed as soon as practicable. 

FINDING 47: There is a lack of clear, publicly available information on the collection, storage and usage of information gathered by contact tracers. 

At the national level the Joint Standing Committee on Foreign Affairs, Defence and Trade report on Implications of the COVID-19 pandemic for Australia’s foreign affairs, defence and trade (which quotes my submission) features the following recommendations -

Recommendation 1  The Committee recommends that within 12 months the Australian Government define which critical national systems are essential to Australia’s ability to function as a secure, prosperous, first world nation. 

Recommendation 2  The Committee recommends that the Australian Government develop a national resilience framework to assess which elements of Australia’s critical national systems are vulnerable to high-consequence supply chain disruptions. 

Recommendation 3  The Committee recommends that the Australian Government develop specific shared objectives with allies and regional partners to increase global support for the rules-based order that underpins the global system of security, international relations and trade. 

Recommendation 4  The Committee recommends that the Australian Government use the recent DFAT audit of Australia’s engagement with UN and other international organisations to identify those that are a priority for Australia’s national interest. 

Recommendation 5  The Committee recommends that the Australian Government develop a detailed agenda of the reforms necessary in priority international organisations and an implementation plan to lead the case for change, working cooperatively with like-minded countries to restore confidence and investment in priority multilateral institutions. 

Recommendation 6  The Committee recommends that the Prime Minister lead deliberations in the National Cabinet to produce an agreed national framework to ensure that COVID-19 related measures imposed by states and territories do not prevent the timely change-over of international maritime crews, a situation which has led to unsafe and unreasonable workplace conditions which breach Australia’s ILO obligations. 

Recommendation 7  The Committee recommends that National Cabinet develop the processes agreed as an outcome of Recommendation 6 such that Australia has an agreed framework to ensure all states and territories remain compliant with national obligations in the event of future crises that require responses falling under the authority of sub-national governments. 

Recommendation 8   The Committee recommends that within 12 months the Australian Government identify those elements of Australia’s critical national systems where supply chains are entirely or significantly dependent on companies which are likely to be subject to extrajudicial directions or coercive interference from a foreign government that place continuity of supply at risk of failure. 

Recommendation 9  To prevent failure of critical nationals systems, the Committee recommends the Government, in consultation with industry, develop plans and a timeframe to move ‘at risk’ supply chains for critical national systems to sovereign Australian suppliers or where appropriate, to other trusted, transparent arrangements with companies in nations having a strong record of adherence to the rule of law. 

Recommendation 10  The Committee recommends that the Australian Government initiate parallel Track-1 (Government to Government) dialogue to place an assurance framework around the establishment of commercial arrangements pertaining to supply chains for critical national systems. Where appropriate, this should include reciprocal assurances of supply by Australia to our partners’ critical national systems. 

Recommendation 11  The Committee recommends that within 6 months the Australian Government identify an initial tranche of Australia’s key national strengths in the potential supply of resources, elaborately transformed manufactures and services in critical areas and assess any barriers to the scaling up and commercial sustainability of such industries that would prevent Australia becoming a trusted and transparent partner of choice for like-minded nations. 

Recommendation 12  The Committee recommends that within 12 months the Australian Government conduct a cross portfolio review and where it supports Australia’s strategic interests, develop and implement competitive processes to provide targeted support for Australian industry sectors, enabling them to become trusted suppliers to overseas consumers of critical resources, elaborately transformed manufactures and services. 

Recommendation 13  The Committee recommends that within 24 months the Australian Government ensure that where necessary, Australia regenerates and sustains the test and certification capability to provide assurance that Australian sourced supplies and elaborately transformed manufactures for critical national systems, meet the relevant Australian/New Zealand standards (or international equivalents where applicable). This same capability must be able to verify to a suitable level of confidence that imported enablers to critical national systems are fit for purpose. 

Recommendation 14  The Committee recommends that Australian Government support for Australian industry sectors supporting identified critical national systems move away from purely grant-based assistance to the intentional use of procurement to build and sustain sovereign capability. 

Recommendation 15  The Committee recommends that the CPRs and Accountable Authority instructions be modified to reflect Recommendation 14 by explicitly requiring procurement authorities to consider how the generation and sustainment of sovereign industry sectors that supply to critical national systems could be facilitated by: Aggregation of demand across Commonwealth departments and where agreed, state government requirements; and Phasing of procurement where the timeframe for delivery can be optimised to meet operational requirements and Australian industry capacity. 

Recommendation 16  The Committee recommends that a new sub-paragraph should be added to paragraph 4.5 of the CPRs dealing with assessing value for money. The sub-paragraph should have the effect that: officials must give a priority weighting to the extent to which a proposed project or individual procurement contributes to the generation or sustainment of a sovereign Australian industry capability which is providing nominated supplies to a critical national system.