Index the PBS Cabinet threshold, which has been widening its own coverage for years
Listings with a financial impact above $20 million go to Cabinet rather than the Minister. The threshold is not indexed, so inflation moves medicines across it without anyone deciding they should cross. Cabinet approval time has reportedly grown from 6.7 months to 10.
Steps this would change
Rationale
By the time a medicine reaches this step, every substantive question has been answered. The TGA has established that it is safe and works. The PBAC — an independent expert committee whose rigour is the reason Australia pays what it does for medicines — has found it cost-effective at a price. The department has negotiated and settled that price.
What remains is a budget decision, and where the financial impact exceeds $20 million it is taken by Cabinet rather than by the Minister.
Cabinet approval of a spending decision of that size is entirely legitimate and this proposal does not argue against it. What it argues against is the threshold sitting still while the value of money does not.
A threshold that is not indexed does not hold its position; it moves. Twenty million dollars catches more medicines every year, not because anyone decided those medicines warrant Cabinet attention, but because the number was set once and inflation did the rest. Every year, quietly, a slightly larger share of PBS listings is routed to the slowest available decision-making forum by an arithmetic nobody voted for.
And the cost of being routed there has grown. Reported Cabinet approval time has
increased from 6.7 months to 10 months, with delays of 12 months or more
reported. On the modelled process this single step is 300 of
930 critical-path days, and it is scheduling — nobody is assessing anything.
The proposal. Index the threshold, and restore it to something like its intended real coverage. That is a smaller and more defensible ask than raising it arbitrarily: it does not change which class of decision Cabinet takes, only which decisions the original policy actually meant to send there.
Who acts: the Commonwealth alone.
What is being traded away
This is a proposal to reduce Cabinet oversight of public spending, and it should be described that way. Raising or indexing the threshold means more listing decisions taken by a minister without collective consideration. PBS expenditure is large, growing, and difficult to reverse once a listing is made — medicines come off the schedule very rarely. Collective agreement before committing recurrent expenditure of that scale is a real fiscal control, and industry, which is the loudest voice for raising the threshold, has an obvious interest in fewer people being asked.
Delay is not always the government's doing. Recent academic work on strategic delay in Australian medicine reimbursement argues that sponsors themselves make timing and pricing choices that extend negotiations, because the alternative to agreeing a lower price now is holding out for a better one later. Attributing the whole of the gap between recommendation and listing to Cabinet would overstate it, and this database has no way to decompose it.
Ten months is a reported figure, not a published series. There is no official time series of Cabinet approval durations for PBS listings, which means the central number in this argument comes from advocacy rather than from the department. If the Commonwealth published listing timeframes by stage — PBAC outcome to price agreement, price agreement to approval, approval to listing — this proposal could be evaluated properly instead of argued about. That publication is arguably the more important ask.
And this reform does nothing for the medicines that need it most. A high-impact medicine for a large population is exactly the case where Cabinet consideration is most warranted. Indexing helps mid-sized listings cross back below the line; it leaves the largest and most contested where they are.
Precedent
A Senate committee has recommended the threshold be increased. Indexation of financial thresholds is ordinary practice across Commonwealth legislation, including in tax, corporations and social security law.
Sources
- The Minister approves PBS listings with a financial impact below $20 million; above that the listing requires Cabinet approval
- Reported increase in Cabinet approval time from 6.7 months to 10 months, with Cabinet approval able to delay listing by 12 months or more
- Senate committee recommendation that the Cabinet threshold be increased and indexed
- Li, 'Strategic Delay and Bargaining Over Public Insurance Coverage for Drugs in Australia', Health Economics, 2026
