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Summary of Submissions - Draft Australian Clinical Guidelines for Health Professionals Managing People with Whiplash-Associated Disorders

Background

The draft Australian Clinical Guidelines for Health Professionals Managing People with Whiplash-Associated Disorders, Fourth Edition (Guidelines) was developed by the New South Wales State Insurance Regulatory Authority (SIRA) in partnership with the John Walsh Centre for Rehabilitation Research (JWCRR), University of Sydney.
The Guidelines update SIRA’s Guidelines for the management of acute whiplash-associated disorders for health professionals, third edition 2014. Key changes between the guidelines include:

  • updated recommendations for acute whiplash
  • the inclusion of a new section on chronic whiplash with respect to treatment, prognosis and assessment
  • risk stratification protocols for people with acute whiplash; guideline development in accordance with the Australian National Health and Medical Research Council (NHMRC) standards for clinical practice guidelines
  • use of the Grading of Recommendations, Assessment, Development and Evaluation (GRADE) approach to rate the quality of evidence and strength of recommendations
  • national, rather than NSW-based guidelines.

Public Consultation

The draft Guidelines were released for public consultation between 5 June and 5 July 2023. During the public consultation period, interested stakeholder groups and individuals were invited to make submissions and provide feedback on the draft Guidelines. Stakeholders included health, legal and insurance organisations, as well as motor accident regulatory bodies from other states and territories.
In addition to general feedback on the draft Guidelines and its recommendations, stakeholders were asked to review the recommended care pathways and consider the following questions:

  1. Is the recommended care pathway feasible to implement?
  2. Is the recommended care pathway acceptable to key stakeholders?
  3. What would be the impact on health equity?
  4. What would help you apply these recommendations in practice?

2.1. Submissions

A total of 36 submissions were received from individuals and organisations. Interested stakeholders included peak health and medical bodies, insurance bodies, health practitioners and people with whiplash injury.
The public consultation submissions raised issues mostly relating to Guideline panel representation, evidence and literature review and Guideline recommendations about radiofrequency neurotomy (RFN) and medications. There was a high level of interest and feedback from pain medicine clinicians and SIRA and JWCRR offered two additional consultation sessions to these stakeholders to further discuss the issues they raised in their submissions. The additional consultation sessions were conducted on 15 and 17 August 2023 and the discussions elicited additional comments which have been documented and addressed.
The Guideline developers carefully considered all submissions and issues raised. Key issues and the Guideline developer’s responses are summarised in the tables below. Full submissions from respondents who agreed to publish their comments are available on the SIRA Public Consultation website.

2.1.1. Governance and methods

Guideline panel
Comment Guideline developer response Action taken
There is a lack of representation from clinicians who treat a majority of cases of whiplash-associated disorder (WAD). Critical perspectives from pain specialists, anaesthetists, spinal surgeons and patient groups dealing with advanced stages of whiplash-associated disorder have not been sufficiently considered. The absence of these representatives is likely to limit the comprehensiveness, effectiveness and holistic applicability of the guidelines.
The panel contains no representatives from the following faculties or societies:
  • Australasian College of Sport and Exercise Physicians (ACSEP)
  • Australian and New Zealand College of Anaesthetists (ANZCA)
  • Faculty of Pain Medicine of Australia and New Zealand (FPM)
  • Royal Australasian College of Surgeons (RACS)
  • Royal Australasian College of Physicians (RACP)
  • The Royal Australian and New Zealand College of Radiologists (RANZCR)
  • Neuromodulation Society of Australia and New Zealand (NSANZ)
  • Neurosurgical Society of Australasia (NSA) or
  • Spine Society of Australia (SSA).
The Guideline panel was constituted with experts and non-experts as per the NHMRC Guidelines for Guidelines. Panel composition was informed by previous representation and participation in the development of the last three iterations of the Guidelines.
NHMRC recommended processes were also followed. Clinicians from multiple disciplines (e.g., general practice, physiotherapy, rehabilitation medicine, psychology) treating patients with whiplash associated disorders were included on the panel, therefore, the panel disagrees with the comment that clinicians “who treat a majority of cases of whiplash were not represented”.
We acknowledge that representation from pain medicine specialties (e.g., pain physicians, anaesthetists, spinal surgeons) was not included in the panel. The inclusion of the suggested faculties and societies will be considered for any future iterations of the Guidelines. This was added as a limitation to these Guidelines (see section 9.9).
Guideline changed (see section 9.9).
The guideline developers are advised against making clinical recommendations on treatments across pain medicine and surgical specialties without having the relevant expertise on the panel. The inclusion of pain medicine specialists with interventional expertise is recommended before finalising these guidelines and for future guideline revisions. A more representative panel should have been involved to provide expertise and a more balanced view of the literature review. The panel could have also included people with academic experience and who have published vastly on the subject of whiplash.
Selection of the panel appears skewed towards physiotherapists and rehabilitation physicians, with an apparent absence of holistic interventional pain physicians who work in multidisciplinary departments.
We agree that further consultation is required with pain medicine specialists around interventional pain medicine treatments. However, the development of these guidelines followed a rigorous process in accordance with NHMRC guidance (outlined in the Guidelines for Guidelines Handbook https://www.nhmrc.gov.au/guidelinesforguidelines) to meet NHRMC Guidelines Standards required of all new Australian guidelines. This involved the following procedures: the formation of a guideline panel which included multidisciplinary stakeholders, members actively involved in the management of people following whiplash (nominated by their respective professional organisations), and consumers; prioritisation of clinical treatment questions based on treatments presented in the previous guidelines, the extant literature, and interventions commonly used in an Australian context for this condition; systematic review and synthesis of high quality evidence (randomised controlled trials involving participants with acute or chronic WAD) for short- and long-term critical outcome treatment effects; evaluation of the certainty of evidence for each outcome using the Grading of Recommendations, Assessment, Development, and Evaluations (GRADE) process (considering the included studies’ risk of bias, heterogeneity in findings, appropriateness for an Australian context, precision of findings with respect to clinically meaningful thresholds, and sample sizes; use of the GRADE Evidence to Decision Framework which considers the treatment effects (benefits vs harms; the primary domain used to inform recommendations), the GRADE certainty of the evidence for each critical outcome, costs associated with the intervention, acceptability (adherence rates of participants to the intervention in trials and consumer input), and feasibility of the intervention; and an anonymous voting system used by the guideline panel members based on discussion of data presented in the Evidence to Decision Framework, with further discussion if a consensus was not reached. Further detail on the evidence summaries and evidence to decision frameworks are presented in the respective technical report documents.
The aim of the evidence to decision framework is to limit bias and consider data presented under key domains that inform the final recommendation. To further mitigate inherent bias, members deemed to have a conflict of interest excused themselves from discussions and decisions in relation to the relevant agenda item, abstained from voting and took any other such measures to effectively manage that conflict of interest as directed by the Chair of the panel. For example, where panel members were a lead author on an included trial.
Meetings with submission authors from pain medicine specialities and several other representatives was held. This resulted in a response letter to pain medicine specialists clarifying implementation recommendations for radiofrequency neurotomy and other issues including medication recommendations.
There were further responses from pain medicine specialists. As consensus was not reached with these stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
Contrary to the declaration, there appears to be significant conflicts of interest in the development of this guideline.
  • There are insurer representatives involved – these proposed guidelines will decrease the ability for insured patients to get access to a treatment that may help them.
  • At least 25% of the panel receive significant financial support from SIRA.
  • The selection criteria for the panel are not stated. Although there are three medical practitioners (12.5%) on the panel, it is not stated if they represent their representative colleges. One can assume it reflected their own views rather than the views of their colleges.
  • The panel involves a large proportion of people from the JWCRR. A biased panel is giving recommendations on how doctors should be giving treatments and this has medicolegal consequences.
Conflicts of interest of panel members were declared as per NHMRC process.
There are insurer stakeholders on the guideline group. As explained in the draft guidelines, NHMRC procedures were followed.
Whilst the guideline panel contained representatives from the JWCRR, only three had voting rights and could make decisions regarding the Guideline recommendations. The remaining JWCRR panel members were observers.
Nil.
Voting system
CommentGuideline developer responseAction taken
Voting on what treatments the panel accepts is not a scientific approach to defining best clinical practice. There are more rigorous means by which consensus guidelines can be developed, e.g., Delphi Processes.Evidence-based clinical recommendations were made using the GRADE process which includes a voting protocol. This process is a NHMRC requirement for all new Australian clinical guidelines and follows a rigorous scientific process for developing recommendations.Nil.
The voting system should be explained as there are different voter totals for some recommendations.This is explained in the main guideline and technical reports. “Following review and panel agreement on content presented in the Evidence to Decision Framework, an anonymous online voting system (https://www.menti.com/) was used by the panel to reach consensus on a recommendation classification. Interpretation of recommendation classifications for Diagnosis, Prognosis, and Treatment are outlined in Table 14. If no clear consensus was present after the first vote the panel would critically discuss before re-voting.” Recommendations were developed over a 12+ month period, where a quorum of 8 voting members was required for a vote to pass.
The Evidence to Decision Framework asks the panel to consider constructs such as strength and certainty of evidence, undesirable effects, resources required, acceptability and feasibility. These are discussed at length prior to the vote.
Nil.
Ethics
CommentGuideline developer responseAction taken
The guideline development process should have had independent ethics approval from the outset, similar to models of funding for medical research. The costs associated with the preparation of this document should have been revealed.Ethics approval is not required to review evidence nor produce guidelines. Rather, NHMRC processes are recommended to be followed.Nil.
Literature and evidence review
CommentGuideline developer responseAction taken
There should be more research inclusion. The scientific papers that were used are outdated and limited in scope and consideration. Papers from 1994 are acceptable but good research from 2022 is available. If there is limited research specific for radiofrequency ablation for whiplash facet injury, then it’s reasonable to extrapolate and determine appropriateness based on non-whiplash-based facet injury.The draft guidelines have been developed in keeping with NHMRC requirements. Based on the searches conducted in development of the draft Guidelines, there are no other more recent randomised placebo-controlled trials of these treatments (radiofrequency neurotomy) in the context of whiplash. Given the literature search returned more than 60 RCT’s to base the treatment recommendations in this guideline on, the panel did not consider RCTs conducted on other patient groups.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
There is a lack of transparency regarding handling, publication and selection of information that is included in the guidelines. The selective use of evidence that recommend against evidence-based treatment opens this document to the interpretation of literature manipulation that doesn’t put the patient first. It is also unclear how queries about the guidelines will be addressed.The inclusion criteria used to select studies for appraisal are described in the Technical Report (see Technical Report Chapter 1 Diagnosis – section 7.1.5; Chapter 2 Assessment – section 6.1.4; Chapter 3 Prognosis – section 7.1.4; Chapter 4 Treatment – sections 7.1.4.). These inclusion criteria are standard for conducting systematic reviews of randomised controlled trials. Where secondary evidence was used to inform recommendations, we were transparent in our approach - see 9.7.2. Absence of evidence procedures in the Guideline document.Modification to multiple sections of the draft Guidelines has been made in response to specific queries and feedback (see other responses/actions).
The inclusion of more meta-analysis or systematic reviews would benefit this document.Technical report documents for Diagnosis, Assessment, Prognosis, and Treatment detail systematic reviews and meta-analyses as part of evidence summaries. At the end of each recommendation in the Guideline document is the reference to their respective section in the technical report which includes data used to inform the recommendation.Nil.
The studies and references are not available for public access, these should be made available.The technical reports contain all the references, study and population characteristics, and data that were extracted to inform recommendations. Most articles are available on open access journals. Where an included study is not available in an open access journal, generally journal copyright does not allow us to make the study publicly available.Nil.
There needs to be explanation about which National Health and Medical Research Council (NHMRC) guidelines are being used to develop the Whiplash Guidelines.The ‘Procedures and Requirements for meeting the 2011 NHMRC Standards for Clinical Practice Guidelines’ was used and this has been described in the Guidelines and Administrative report.Nil.
The GRADE process allows upgrading on the body of evidence.Upgrading can occur based on the magnitude of effects (e.g., very large), but is generally considered if there aren’t concerns with other domains when evaluating evidence from observational studies. High quality (randomised controlled) trials were used to inform treatment recommendations in these guidelines.Nil.

2.1.2. General

CommentGuideline developer responseAction taken
Pain is a complex physical, psychosocial, ethnocultural, affective-cognitive and environmental phenomena. No single treatment can influence all aspects and consequently a multidisciplinary and multimodal approach is advocated by the FPM ANZCA. Naturally, pain from acute whiplash, subacute and chronic whiplash injuries are managed in a stepwise fashion, beginning with conservative treatment options, supported by interventional treatment when indicated by appropriately trained practitioners.The viewpoint regarding pain is reflected in the guidelines, where both multi-modal and multidisciplinary treatment are recommended.
The flowchart and implementation points also provide suggestions about when to consider certain interventions.
No change made specifically in response to this comment.
The title “Draft Australian Clinical Guidelines” assumes that the document would be accepted nationally, however this is a NSW state initiative, not a federal initiative.See methods document, where the intent was for NHMRC approval, hence a national guideline panel was convened, with representatives from several state government regulators.Nil.
This document appears to be a methods document describing how the guidelines will be produced, rather than a final guideline document.This response was specific to the “Summary of Recommendations” document which contained a general summary of the decisions, rather than the Guideline document and Technical Reports. Greater detail on development procedures and specific details of the studies considered and GRADE processes are provided in the additional documents that were available during public consultation.Nil.
The inclusion of evidence-based tools and resources, including technology enablers in the guidelines for practical application is recommended.The implementation considerations capture where resources are currently available to assist with practical application. This will be explored further in the implementation phase.Will be further scoped in the implementation phase.
The guidelines recommend against accepted evidence-based treatment and practice feedback. There are concerns that patients will be denied evidence-based treatments for whiplash associated neck and headache resulting in social, ethical, medicolegal problems and additional unnecessary treatment delays, economic loss, distress and suffering to the patient, their family and community.The draft guidelines have been developed in keeping with NHMRC recommendations. This opinion is noted but a detailed response is not possible in the absence of specific information.Nil.
The guidelines should adhere to evidence-based medical practice rather than opinion. There should be a revision of the guidelines by an appropriately constituted advisory group that evaluates the evidence for interventional pain medicine in an accepted scientific manner.See above comment. A robust systematic review was conducted to retrieve RCT’s to inform treatment recommendations, returning 44 trials of people with acute and 18 in people with chronic whiplash (a further 70 prospective cohort studies and 165 cross-sectional studies informed the prognosis and assessment sections, respectively). Methods to appraise evidence thereafter followed the NHMRC recommended GRADE process.No change made specifically in response to this comment.
Co-morbidities may influence the course of events or assessment or treatment. Medical practitioners are required to assess the injured individual taking into consideration other health issues that may arise. This should be referred to in the document.We agree, pre-crash health (general and mental) is considered when determining prognosis (‘conditional for’ recommendation) and pre-crash comorbid conditions (neutral recommendation). Implementation considerations are detailed in the main guideline. However, we agree that it could be made clearer in the flow charts for HCPs – addition of “(in addition to a normal interview with individualised biopsychosocial factors considered)” for initial assessment in the acute and chronic phases.Revisions made in care flowcharts (sections 6 and 7).
The recommendations must include a thorough assessment of the condition to determine what is the most effective way of managing pain. This is the foundation for the injured individual to return to near normal function including work. If pain is controlled everything else follows.Prognosis and Assessment sections of these guidelines guide HCPs on how to assess people with acute and chronic WAD, and the implications for management.Nil.
The judgement of the Guideline authors appears to have been consistently biased towards low-risk interventions even if they are expensive (such as MDTs) or of completely speculative efficacy (all of the recommended medications, education). The studies quoted in support of recommending neck-specific exercises, psychologically-informed exercises, multimodal physical therapy and cognitive behavioural therapy uniformly, where statistically significant, do not rise to levels of benefit usually required to claim clinical relevance.
The reasoning applied to a number of the medical treatments in the Technical Report is inconsistent and demonstrates an unsophisticated engagement with the nuances of the literature in this area.
See comments above and repeated below.
A robust systematic review was conducted to retrieve RCT’s to inform treatment recommendations, returning 44 trials of people with acute and 18 in people with chronic whiplash (a further 70 prospective cohort studies and 165 cross-sectional studies informed the prognosis and assessment sections, respectively). Methods to appraise evidence thereafter followed the NHMRC recommended GRADE process including meta-analysis to consider strength and certainty of evidence. With respect to the effectiveness of physical therapy recommendations detailed, significant findings were considered in context to the type of comparator intervention and the PICO question; interventions were compared with other active control interventions which demonstrate efficacy in the management of WAD (e.g., advice for activity), rather than placebo or no treatment.
Few medical treatments had RCTs to support the recommendation. In this instance, the panel followed a process to make recommendations based on prioritised PICO questions. Prioritised questions were based on commonly prescribed medications, including those currently over-subscribed. In view of this comment and others, the panel have adopted the approach of naming medications according to medication class and as per existing pain medication guidelines. A section on medications that were not part of this guideline has been added.
A clear section on medications (and other types of treatment) not considered in this guideline have been added.
Medication names changed to class (e.g., antidepressants) and follow the pain management guidelines: Australian and New Zealand College of Anaesthetists and Faculty of Pain Medicine: Acute Pain Management Scientific Evidence (5th ed, 2020) (Schug et al., 2020); ii) United Kingdom National Institute for Health and Care Excellence’s (NICE) Chronic Pain Assessment and Management Guidelines (2021).

2.1.3 Guideline recommendations

Additional recommendations
CommentGuideline developer responseAction taken
The inclusion of vestibular assessment when individuals with whiplash are reporting dizziness (not just oculomotor assessment and neck proprioception assessment) is recommended.
A quick literature search identified rates of 25-34% of Benign Paroxysmal Positional Vertigo (BPPV, a very treatable form of vertigo/dizziness) in patients with whiplash. BPPV is very treatable, in most cases in a standard clinic environment without additional resources. Some clinicians treating individuals with whiplash may already be familiar with assessing and treating BPPV. Additionally, it may come in the future that these individuals should be assessed for labyrinthine concussion as well to ensure all causes of their dizziness/balance deficits are addressed. We see lots of this in concussion/mild traumatic brain injury of which there is lots of overlap with the whiplash population.
The guideline panel agree. We have made assessment to determine differential diagnosis of dizziness clearer in the treatment recommendations.
This suggestion already appears in the ‘Assessment’ recommendations. Namely “consider differential diagnosis of dizziness when interpreting tests (e.g., concussion, vestibular).”
Changed implementation considerations to “HCPs should conduct a differential diagnostic examination considering vestibular, mild traumatic brain injury and other possible causes for dizziness symptoms.”
Guideline changed (section 12.3 and 16.3 in Guideline).
X-ray guided catheter placement of epidural steroid around sensitised nerve roots in the cervical and lumbar regions along with transforaminal sleeve injection and pulsed radiofrequency to the sensitised nerve root ganglia can provide significant reduction in neural sensitivity related pain and unblock response to activity and self-management orientated physiotherapy treatment input.
It is suggested that the guideline panel look specifically at these procedures, which may be supportable on the basis of long-term clinical experiences and the consideration that the treatment is consistent with current concepts concerning the predominant neural sensitivity mechanisms of WAD symptomatology.
Cervical and dorsal spinal cord stimulation treatment for nociplastic and neuropathic mechanisms dominant pain syndromes is a well-established treatment with a considerable high-quality evidence base notwithstanding current dispute about poor quality placebo studies.
For the specific treatments listed there is no high-quality research evidence (placebo-controlled randomised trials) available based on searches done for the draft Guidelines.
The NHMRC Guideline processes have been followed, which recommend inclusion of the highest quality evidence. Hence, we have included only randomised controlled trials to inform the recommendations. Lower grades of evidence (e.g., clinical opinions) were not included to inform the recommendations. There is no current placebo controlled RCTs investigating the effect of these interventions in people with whiplash.
A list of treatment for which no evidence is available has been included in the revised version of the Guidelines (see sections 12.23 and 16.24).
Section 6 and 7: Injury care flowcharts
CommentGuideline developer responseAction taken
  • Abbreviations and jargon need to be removed so the chart is accessible for non-specialists, including nurses and Aboriginal and Torres Strait Islander Health Practitioners.
  • Removing visual analogue scale and its association and expectation that pain level can be zero is even more important in chronic pain.

The flow charts give a timeline of management over a 12-month period. Management continues for much longer than this.

Abbreviations are detailed in the main Guideline (section 3) and are commonly used clinical measures by HCPs, including nurses.
Pain intensity during the chronic phase is a predictor of ongoing poor outcome and is recommended to be assessed. Consistent with the comment - a focus on pain self-efficacy and functional goals during the chronic phase is detailed throughout the Guideline.
We agree with the comment about the timeline of management.
Amended the timeframe for the final stage of the chronic flowchart to include 12+ months.
Section 8: Guidelines executive summary
CommentGuideline developer responseAction taken
Section 8.1.1 Summary of Diagnosis recommendations relating to acute whiplash, including table 3 – availability and cost of MRI need to be considered, and alternative if these are not available.Costs and resources required were considered in the Evidence to Decision Framework. Verified radiculopathy is present in less than 5% of people with WAD and indications for MRI are detailed in these guidelines with the aim of reducing unnecessary imaging.Nil.
Section 8.1.2 Summary of Prognosis recommendations relating to acute whiplash, including table 4 – access to these tools must be available for non-specialists including nurses and Aboriginal and Torres Strait Islander Health Practitioners.We agree, prognostic tools (e.g., WhipPredict) are available on the My Whiplash Navigator website and any other tools that were recommended but not currently available will be made available during the implementation phase.
Focus groups with Aboriginal and Torres Strait Islander people and health practitioners are planned in the implementation phase.
Scoping of existing and appropriate tools to implement recommendations will occur in the implementation phase.
Section 8.1.3 Summary of Treatment recommendations relating to acute whiplash including table 5 – needs specifics on education (and any inappropriate education to be aware of); and exercises.
Section 8.1.4 Summary of Assessment consensus recommendations relating to acute whiplash, including table 4 (pages 11-12)
* How do we interpret the items that are neutral or have recommendation against? Will they be in the guidelines?
* The document should provide definitions. For example, the categories of ‘conditional-for’, ‘neutral’ or ‘conditional against’ are ambiguous.
Section 8.2.1 Summary of Prognosis recommendations relating to chronic whiplash, including table 7 – we need clear definition of chronic whiplash, which may include risk factors for progression from acute to chronic.
Section 8.2.2 Summary of Treatment recommendations relating to chronic whiplash, including table 8 – needs specifics on education (and any inappropriate education to be aware of); and exercises.
How to provide education, prescribe exercises, and conduct assessments will be part of the implementation phase and provided in My Whiplash Navigator. How to interpret the recommendation classifications is detailed in section 9.8 and HCP implementation considerations for each recommendation are detailed in their respective section. Footnote added for clarity in summary tables – see action taken.Added recommendation classification interpretations in footnotes to summary of recommendation tables (section 8 in Guideline).
Section 10.1: Canadian C-spine rule
CommentGuideline developer responseAction taken
The presentation of the recommendation regarding the Canadian C-spine rule is ambiguous. The rules should apply to all post-trauma neck pain, as a screening tool for probability of imaging being required, rather than just WAD IV classified patients. It is definitionally not possible to classify as WAD IV unless a fracture is documented on imaging.

The Canadian C spine rule has been included in the Diagnosis Section of the Guidelines.
Clarity has been added to ensure the rule is followed to refer for imaging (which in turn diagnoses fracture) rather than to just classify WAD.
Amended text:

  • "A positive result is an indication to refer for imaging to determine possible cervical fracture.”
  • “Subgroup of WAD IV is determined by imaging if positive for cervical fracture.”
  • “If a cervical fracture is confirmed by imaging there should be urgent referral to a Hospital Emergency Department or immediate surgical consultation.”
Clarity added to the Canadian C-Spine Rule recommendation (section 10.1).
Sections 12.19 – 12.21 and 16.22 – 16.24: Injections
CommentGuideline developer responseAction taken
It is unclear where the injection options were actually placed as there is significant variance. Perhaps breaking this down further, e.g., steroid non-specifically around the neck, vs. for patients with features of occipital neuralgia, should be considered.The technical report makes it clear that “facet joint corticosteroid injections” are the injections under consideration.
“Facet joint corticosteroid injection” (in place of “corticosteroid injection”) amended throughout the guideline documents.
Guideline changed (see sections 8.1, 12.20 and 16.20).
Section 16:21: Radiofrequency neurotomy (RFN)
CommentGuideline developer responseAction taken
Steroid injections and radiofrequency treatment appear to be entirely rejected. The document focuses on cervical facet injection and radiofrequency treatment which I would agree does not have a persuasive evidence base of efficacy for WAD symptoms and in my experience thermal neurotomy of neural sensitised cervical facets entails risking a flare up of pain rather than pain reduction.The issues raised are noted.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
The third edition of the whiplash guidelines provided the following guidance: “Follow recommendation from specialist and ensure coordinated care. Follow the chronic pathway as detailed in the NHMRC Clinical guidelines for best practice management of acute and chronic whiplash associated disorders, Nov 2008.” In this latter document, it is stated that thermal frequency denervation (RFN) “may be useful for chronic whiplash sufferers whose symptoms have been shown by diagnostic blocks to arise from the lower cervical joints” with NHMRC Grade B (Body of evidence can be trusted to guide practice in most situations).The response is noted.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.

There appears to be selective literature bias and a disregard of a substantial body of literature on the application of medial branch blocks and RFN for WAD. There is strong evidence and comparative data supporting RFN, yet a recommendation against it has been made. The only trial that was considered was a single study by Lord et al. in 1996, which was incorrectly described as a small pilot trial. The study followed a prior pilot trial and was adequately powered to detect a statistically significant difference in the clinical setting where there is a large difference in outcomes between the control and the intervention group.
There is extensive literature and many publications that support RFN in facetogenic pain which have not been mentioned. These include:

  • Comprehensive Evidence-Based Guidelines for Facet Joint Interventions in the Management of Chronic Spinal Pain: American Society of Interventional Pain Physicians (ASIPP)
  • Guidelines Facet Joint Interventions 2020 Guidelines
  • Consensus practice guidelines on interventions for cervical spine (facet) joint pain in Regional Anaesthesia and Pain Medicine in 2022 by a multispecialty international working group.
  • Landmark studies by Lord et al in 1996, 1999 and 2003.
  • Review by Eseonu and colleagues looking at the utility of facet joint injections in whiplash associated spinal pain.
  • Study by Manchikanti L and colleagues on therapeutic cervical medial branch blocks administered for proven cervical facetogenic pain.
  • Rydman and colleagues’ longitudinal study regarding cervical degeneration.
  • Malik 2021 literature review and Yang and colleagues 2010 study on cervical facet joint pain.
The NHMRC Guideline processes have been followed, which recommend inclusion of the highest quality evidence. Hence, we have included only randomised controlled trials (RCTs) to inform the recommendations. Lower grades of evidence (e.g., clinical opinions) were not included to inform the recommendations. A GRADE methodologist was engaged to provide ongoing input and advice in relation to this process.
There is not “extensive literature” (high quality multiple placebo controlled RCTs) for radiofrequency neurotomy as shown in the draft guidelines. Robust literature searches retrieved only one study on RFN in whiplash with a placebo control group.
The recommendation and implementation considerations sent to stakeholders for review were consistent with conclusions drawn from a multispecialty international working group (Cervical Joint Working Group) who developed consensus practice guidelines for managing cervical facet joint pain (Hurley et al., 2021). They concluded that RFN could provide benefit to well-selected individuals based on stringent selection criteria.
Hurley, R. W., Adams, M. C., Barad, M., Bhaskar, A., Bhatia, A., Chadwick, A., ... & Cohen, S. P. (2021). Consensus practice guidelines on interventions for cervical spine (facet) joint pain from a multispecialty international working group. Pain Medicine, 22(11), 2443-2524.
The studies referenced fall outside the scope of studies considered for inclusion in the draft Guidelines developed using methods suggested by NHMRC.
As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.

Multiple clinical trials have provided compelling evidence that a highly effective treatment exists that significantly reduces or eliminates pain by targeting the known pain generators. Based on the most rigorous studies using appropriate diagnostic techniques to select patients and using optimal treatment techniques of on cervical medial branch thermal RFN (CMBTRFN):

  • Over 60% of patients treated with CMBTRFN can expect to be pain-free at 1 year with restoration of activities of daily living and no need for other health care for neck pain.
  • In the event of a recurrence of pain, complete relief can be reinstated by repeating the treatment.
    No literature refutes any of these conclusions. SIRA should continue supporting practices that achieves such outcomes and ensure they remain available to patients.
This submission comments on the one placebo controlled randomised trial of CMBTRFN. It acknowledges that this procedure is provided differently by different practitioners and states that patient selection is important and dual comparative blocks are required to identify patients who may benefit from the procedure. It acknowledges that significant numbers of treatment responders require repeat procedures. It does not provide data on adverse effects of the procedure. The GRADE process that is mandated by the NHMRC guidelines procedures considered all relevant issues.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
RFN is a specialised medical treatment reserved for patients who have failed to benefit from primary care treatment and have been referred for specialist care. It is well documented in the scientific literature that the facet capsules can be an ongoing source of nociception in chronic whiplash sufferers on the basis of pre-clinical and clinical research. There is excellent evidence for positive outcomes which are dependent on close attention to the technical factors. The Guidelines would have benefited either from including these technical factors in their recommendations, or alternately by not addressing specialist treatment in a document intended for primary healthcare professionals.See responses to other similar submissions.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
There needs to be a broader literature search beyond RCTs, especially for pain studies where it’s difficult to conduct RCTs in particular groups of pain patients and sometimes considered unethical to replicate. This includes well-conducted longitudinal studies that have demonstrated in favour of RFN. Other guideline development groups include other study methodologies. Methodological rigour in this case is preventing helpful interpretations and a lack of consideration of important evidence.See responses to other similar submissions.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
RCTs for exercise had small measured effects whilst there were dramatic treatment effects compared to placebo for RFN and the outcome was superior for 9-12 months. The guidelines contain a lot of conservative treatments and their effects are often negligible or absent.The certainty of evidence for the effects of RFN were very low. With respect to the effectiveness of exercise recommendations, findings were considered in context to the type of comparator intervention and the PICO question; interventions were compared with other active control interventions which demonstrate efficacy in the management of WAD (e.g., advice for activity), rather than placebo or no treatment. Other factors in the GRADE evidence to decision framework such as feasibility, acceptability, and undesirable effects are also considered when developing recommendations for treatments.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.

The recommendation against evidence-based medial branch blocks and RFN treatment should be rescinded.

  • Without the branch blocks I would not be able to do my role as a Clinician.
  • As a patient who has obtained immediate relief as a result of these procedures, I am distressed to hear that your group is seeking to discontinue the procedure.
The comment is noted.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
Cervical medial branch blocks and RFN treatment are available to patients with chronic neck pain not covered by third-party insurance in public and private hospitals. If this draft guideline is adopted, it may lead to a two-tier system that discriminates against patients with third-party funding.This comment is noted.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
Cervical zygapophysial joint pain, that comprises 56% of whiplash injuries, more than any other underlying pathology, is not included. The diagnostic injections of cervical zygapophysial joints are a means of diagnosing whiplash induced pain and RFN is effective in treatment. It should be readily available to those who have incurred whiplash and need it and after being informed about it, want it.Neck pain was a critical outcome addressed in these guidelines. Hence interventions that were effective in reducing pain were considered and form many of the recommendations.
There is limited high quality evidence (randomised placebo-controlled trials) for RFN in whiplash.
As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
A detailed analysis of the Guidelines authored by Prof Nikolai Bogduk outlines the substantial body of bioengineering, animal and clinical research which supports the role of cervical RFN in the treatment of WAD. It is unacceptable that this evidence has been ignored by the reviewers and Guideline authors. A practical upshot of this evidence being mischaracterised in the Guidelines is that refusals of RFN requests will be conciliated by FPM Fellows and others with consistent success in the interests of their patients, who will potentially be deprived of what is potentially the single most effective medical treatment for WAD. SIRA is strongly encouraged to re-evaluate this recommendation.The studies referenced fall outside the scope of studies considered for inclusion in the draft Guidelines developed using methods recommended by NHMRC.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
When done by an appropriately trained practitioner using established clinical standards, RFN is a safe procedure with a very low risk rate. The Spine Intervention Society has developed guidelines on how to perform this properly.There is no external oversight or validation of practitioners who perform these procedures and no additional qualifications required – who is considered an “appropriately trained practitioner”? To what extent is the standard of care audited? Insurers would not be able to differentiate who is appropriately trained to perform RFN.Nil.
RFN is incorrectly stated to require CT. Therma radiofrequency can be conducted using CT guidance (typically by radiologists) but is more often provided by pain medicine specialists using multiplanar fluoroscopy guidance.The comment is noted.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
Returning to accustomed pain immediately after the procedure should not be listed as an adverse effect and there needs to be balance in the way information is presented.
The fact that the effects of RFN wear off overtime should not be a reason not to do it as everything eventually wears off.
We agree – the wording around this was reframed to indicate that the treatment may be ineffective for some people.
Noted that some people do recover.
As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
The recommendation should be reworded into a positive recommendation to make the passage of treatment easier for people who need it.Implementation considerations were added to this recommendation to include indications for RFN use. This was intended to provide more guidance regarding who may receive the treatment as we suggested that it should not be used for most people with chronic WAD.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
The costs are not especially large for RFN.
The cost-effectiveness of RFN should be weighed up against the cost of ongoing medication and other treatments. For example, if RFN gives 70-80% relief for 9-12 months, that is likely to be more cost-effective than continuous medications.
Costs in this section refer to public costs associated with the treatment, rather than costs to the person. Relative to other interventions, the costs are moderate.
None of the interventions included a cost-effective analysis.
As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
Workcover Victoria and Transport Accident Commission (TAC) accept a 75% improvement in pain from the branch blocks to proceed with RFN.The comment is noted.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
A lack of access to specialised pain services in general is already a problem across the country but using that as a reason not to provide RFN will compound the issue.This comment is noted.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
In relation to implementation of RFN, there is a strong consensus against a double-blind placebo and double-blind blocks are also not funded by Medicare. In practice, most people will accept that a single medial branch block with 75% improvement in pain is unlikely to be a false positive. It would be ideal to aim for 100%, but this is often difficult in practice and 75-80% is not unreasonable. Anything less than 80% would mean there’s
significant pain that’s not coming from that target joint that has not been found.
The consensus against a double-blind placebo is noted, however, this is different to the protocol of the published RCT.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
Section 16.25: WAD associated headache
CommentGuideline developer responseAction taken
There are no comments on treatment for WAD associated headache, where WAD has associated headaches in up to 90% of cases associated with neck pain. Headaches affects most patients with acute whiplash. This is a vital aspect of whiplash assessment and treatment. Have recommendations been considered in conjunction with headaches?Headache related to WAD was considered, however, no specific recommendations were made (see sections 12.22 and 16.23). In our systematic review of whiplash RCTs, no trials specifically aimed to change headache symptoms as part of the intervention. Four studies evaluated headache intensity as a secondary outcome where no significant differences in between group headache intensity found in these studies. The guideline panel note that as per the International Classification of Headache Disorders (3rd edition), the critical outcome measure for headache is the frequency of headache over the previous month. Frequency of headache was not measured in any of the included whiplash trials. Intervention trials that target headache after whiplash might be an area for future research. HCPs should review primary headache trials for evidence regarding headache management following traumatic injury.Headache frequency over previous month added as recommendation for future research in acute and chronic whiplash (see sections 14 and 18).
Section 10.3: Imaging
CommentGuideline developer responseAction taken
  • “Refer for imaging to determine probable diagnosis of cervical radiculopathy” implies there is no indication to refer for imaging in other circumstances. This will lead to injuries being missed.
    There are many other indications for imaging in acute whiplash. Multiple anatomical areas and structures need to be considered even without radicular pain e.g., the cranio-cervical joint [CCJ] complex, bones, ligaments and facet joint capsules. Relevant pain syndromes that occur may include the upper cervical spine (cervico-encephalic syndrome) or lower cervical spine (lower cervical syndrome).
    Imaging should be considered if there is any concern about fracture or instability. Other aspects to consider imaging include;
  • Any alteration in level of consciousness.
  • Any evidence of trauma to the head or neck (“trauma above the clavicles”).
  • Any evidence of intoxication.
  • Any distracting painful injury elsewhere.
  • Age greater than 65 years.
  • High-speed rear-end motor vehicle collision.
  • Focal neurologic symptoms or signs.

Clinical judgement is still the overriding principle and radiography must be carried out while ensuring mobilisation of the cervical spine.

The panel agrees. The Canadian C-Spine rule is recommended for referral for imaging to detect fracture or other serious cervical spine trauma. It includes consideration of other factors.
Imaging recommendations for injuries other than whiplash (e.g., traumatic brain injury) are outside the scope of this guideline. Section 4.2 in the Guideline notes that “As per the implementation considerations detailed in these guidelines, clinical judgement should be used by HCPs when delivering care to these people in accordance with the Clinical Framework for the Delivery of Health Services (https://www.tac.vic.gov.au/providers/working-with-the-tac/clinical-framework).”
Clarity provided in the diagnosis section regarding Canadian C-Spine rule (see section 10.1).
Sections 12.6-12.7, 12.11-12.12, 12.16, 19.9-16.12, 16.17: Medications
CommentGuideline developer responseAction taken
The guidelines do not adequately cover the use of anti-neuropathic medications, an aspect which contemporary evidence suggests can be integral to the effective treatment of this disorder.
There is no mention of other relevant medications such as gabapentin, nortriptyline, a short course of muscle relaxants (orphenadrine, baclofen or diazepam) or a controlled short course of opioids for acute injury. The Guidelines do not mention analgesic infusions (e.g., sub-anaesthetic ketamine infusion, lidocaine infusion), which may be an appropriate clinical treatment under a pain medicine specialist.
  • We have developed a list of other medical interventions that were proposed during the public consultation period and are listed in the guidelines without specific recommendations. These interventions were not identified in our systematic review of RCTs of people with WAD and were not prioritised as clinical questions in these Guidelines. These interventions, for acute WAD included:
  • Alexander technique
  • Antidepressant medication – specific types e.g., duloxetine
  • Anticonvulsant medication – including gabapentinoids (with exception of pregabalin in acute WAD)
  • Cannabis – medicinal products
  • Cervical pillows
  • Electrical nerve stimulation
  • Heat
  • Homeopathy
  • Ice
  • Injection techniques – other e.g., transforaminal epidural steroid injection
  • Feldenkrais
  • Ketamine infusion
  • Lidocaine infusion
  • Magnetic necklaces
  • Pilates
  • Shortwave diathermy
  • Traction

A similar (but not identical) list was developed for chronic WAD.

Guideline changed (see sections 12.23 and 16.24 for list of other treatments).
Amitriptyline was rated as a ‘neutral’ recommendation for acute WAD, based on no clinical trials in WAD. On page 98 of the draft Guidelines, this seems to have been rated as “conditionally for” although 67% of the committee rated it as neutral. This seems to be an error.‘Conditionally for’ was incorrectly highlighted in section 12.11 and was amended to ‘neutral’.Corrected to neutral in section 12.11. Amitriptyline recommendation title changed to Antidepressants (see other responses for more detail).
With respect to anti-depressant medication, the following pilot trial of duloxetine was published in April 2023 (https://pubmed.ncbi.nlm.nih.gov/36375173/). It would be beneficial to include it.We acknowledge the suggested article related to the use of duloxetine for managing musculoskeletal injury. The mechanism of injury varied in the study with 37.2% of the participants sustaining motor vehicle collision injuries. No specific mention of whiplash injury or WAD grade was referred to, and the motor vehicle collision group made up <50% of the total sample. The article therefore does not match our population inclusion criteria. However, we have included duloxetine in the list of other treatments that were proposed during public consultation but had no evidence for whiplash. See responses to other submissions for more detail.Duloxetine added to list of other treatments that were not prioritised as clinical questions in these guidelines (see other responses for more detail and sections 12.23 and 16.24).
There is a role for opioids to play in some specific clinical situations under controlled circumstances. For example, a low stable dose of opioids in a compliant patient, where the opioid has been shown to provide both pain reduction and functional gains without any aberrance. The guidelines make no allowances for any of the nuances that specialists manage on a day-to-day basis.The recommendation classification notes that opioids should not be used for most people with WAD. Allowances were made and detailed in the implementation considerations for opioids. E.g., “If simple analgesics, NSAIDs, and other medications (e.g., antidepressants) are ineffective and pain is very severe, cautious use of low-potency opioids (e.g., tramadol) could be considered provided that there is clinical benefit. If used, opioids should be only prescribed for short periods of time for severe pain that either is not responsive to other analgesics, or when other analgesics are contraindicated.”Nil.
The naming of two individual medications (amitriptyline and pregabalin) without commenting on their classes is out of step with current practice in pain medicine. Drugs should be recommended by class, e.g., tricyclic antidepressants, gabapentinoids, as examples. This is done for the ‘simple analgesics’ (referred to by class, which class appears to only contain one drug).
The Neutral recommendation for pregabalin alone, not gabapentin as well is out of step with current practice. The specific suggestion in the Guidelines to use pregabalin is not the recommended practice in Australia. There is a general shift within the pain community to discourage the use of pregabalin unless there is a clear diagnosis of neuropathic pain (WAD III with radiculopathy). Despite the fact that there was RCT evidence in a single trial of clinically relevant benefit, the recommendation was ‘Neutral’ despite NSAIDs, tricyclic antidepressants and paracetamol (which have no RCTs between them) being recommended. There is also a failure to mention the addiction potential of pregabalin.
A Neutral recommendation for paracetamol in chronic WAD is given despite the acknowledgement that there is no support for it in the research literature or NICE recommendations. This recommendation seems based on expediency and low risk, with zero consideration of efficacy.
Amended

Amended treatment recommendation title for amitriptyline (acute and chronic) to “Antidepressants” to be consistent with the secondary evidence that was reviewed and implementation considerations that were outlined for a broader range of antidepressant medications.
Pregabalin was left as a recommendation for acute WAD given that a small RCT was included. Short term use for pregabalin was noted due to known side effects associated with their use, particularly with long-term use. Further, a planned clinical trial will be carried out in Australia for pregabalin use for the management of acute WAD.
The draft pregabalin recommendation was removed from the chronic WAD section due to insufficient evidence.
Antiepileptics including gabapentinoids were added to the list of treatment interventions not considered in these guidelines (see previous response).
A neutral recommendation classification for simple analgesics means that it could be used in some instances provided there is clinical benefit. Lack of efficacy of this medication in chronic pain management was considered in the implementation points:
“If a person with chronic WAD is already using simple analgesia (e.g., paracetamol) for pain management, HCPs should review the prescribing and consider the following actions:

  • Explain the lack of evidence for these medicines for managing chronic pain.
  • Develop a shared plan in conjunction with the injured person for usage of simple analgesia if there are clinically meaningful benefits at a safe dosage.
  • Explain the risks of continuing if they report little benefit or adverse effects and encourage and support them to reduce and stop the medicine if possible.”
Guideline changed (see sections 12.11 and 16.11 for antidepressants).
Within the NSAID group there is significant diversity of risk and efficacy. Coxibs such as etoricoxib and celecoxib are substantially safer in terms of gastrointestinal and cardiovascular risk compared to other classes, especially with use beyond the acute phase. Where the recommendation is based on extrapolated evidence, the safest course is to recommend drugs which are plausibly effective with the lowest risk. This appears to have been not considered at all for the NSAID group. The statement that “The risk of serious side effects from NSAIDs is negligible” is untrue and represents an unsafe level of appraisal of this group of drugs. The risks include serious adverse effects on multiple domains including hypertension, heart failure, renal dysfunction and gastrointestinal bleeding.We agree that there are sub-class-related side effects with NSAIDs.Addition of “sub-class” in implementation considerations (see sections 12.7 and 16.10 - “Inform person of known side-effects (which appear to be dose and sub-class related).”) and reference to sub-class effects in technical report.
The findings regarding amitriptyline also can be applied to other TCAs such as nortriptyline which is often more tolerable and equally effective. Tricyclics may have beneficial effects on sleep, neuropathic and soft tissue pain and are potentially valuable group of drugs in WAD for selected patients. The guidance given is likely to lead to underutilization when benefit is possible.TCAs such as nortriptyline which is often more tolerable and equally effective. Tricyclics may have beneficial effects on sleep, neuropathic and soft tissue pain and are potentially valuable group of drugs in WAD for selected patients. The guidance given is likely to lead to underutilization when benefit is possible.
Amended treatment recommendation title for amitriptyline (acute and chronic) to “Antidepressants” to be consistent with the secondary evidence that was reviewed and implementation considerations that were outlined for a broader range of antidepressant medications.
Guideline changed (see response).
Opioids are a problematic group in all types of chronic pain, and a common-sense approach is enshrined in FPM’s professional document PS01(PM) Statement regarding the use of opioid analgesics in chronic non-cancer pain which is highly commended to the attention of the Guideline authors.We agree with a common-sense clinical judgement approach when considering these medications. See response above with regards to implementationNil.
Sections 12.9 and 16.8: Multidisciplinary care
CommentGuideline developer responseAction taken
The Guidelines provide conflicting advice regarding the appropriateness, timing and selection of patients for referral in relation to multidisciplinary care. There are very significant gaps in provision of multidisciplinary care, especially outside major metropolitan areas. The requirements to qualify as ‘multidisciplinary care’ are very poorly defined in the Guidelines. Provision of treatment to address PTSD, pain catastrophising, low self-efficacy and high anxiety and depression scores must be undertaken by experienced teams, as success rates for these teams are significantly higher than non-specialists. The Guidelines provide for referral to apparently self-designated ‘whiplash specialists’ who can be allied health practitioners or doctors. How are these titles defined in an accountable fashion? Does it refer to titled pain specialist physiotherapists or osteopaths? What training and CPD is required to gain this designation? Extensive data on the costs of multidisciplinary care are available and it is puzzling that the Guidelines make no comment that multidisciplinary care is expensive compared to other care types. The assumption that self-efficacy can be easily and permanently raised within a specified time period or number of sessions is not an evidence-based assumption and leads consistently to treatment failures and poor outcomes in clinical practice if not very carefully implemented. This recommendation will not be able to be implemented without a large national increase in the workforce of both allied health and medical staff with significant expertise, meaning that health equity will be compromised and the current ‘postcode lottery’ of pain care as highlighted in the Deloitte document The Cost of Pain in Australia.We recognise that multi-disciplinary care is currently difficult to implement. Implementation gaps have been identified and these include effectively implementing true multi-disciplinary care. Solutions to the practice and implementation gaps will be further explored during the implementation phase.
The flowchart indicates the people that may benefit from multi-disciplinary care (e.g., medium/high risk on the prognostic tool, not responding to current care) and the timeframes to consider this.
We have defined whiplash specialists in the footnotes to the flow chart.
Explore current implementation gaps during the implementation period and propose solutions.
Sections 12.15 and 16.19: Manipulation
CommentGuideline developer responseAction taken

Comments in relation to sections of the Technical Report Chapter 4: Treatment
T.9.2, page 169 – Undesirable effects

  • Fernandez des la Pen 2004 – Assume cause and effect here – limited evidence for that.

T.9.3, page 172 - Recommendation

  • There is no real evidence for or against. The recommendation should be that, not biased against manipulation.
  • Inclusive study – 1 study with poor control. Full spine approach then recommendations based on parts of the study – inappropriate bias.
  • Technique variances
  • Inconclusive

T.9.4, page 174

  • All assumptions, no evidence
  • Relates to risk factors in diagnostics like dizziness and anterior neck pain
  • Qualify recommendations to how protocol and evidence within the cited study. Why apply this bias here within the physio and manual therapy literature. The opposite is true for the CBT literature as well as the harmful medications.
  • Do not provide sweeping conclusions based on one flawed study.
  • Conclusions should be neither for or against the intervention.

T.18.2, page 283

  • Contrast these findings with manipulation. No evidence and yet supported.
  • Side effect similar to placebo

T.20, page 294

  • Bias towards medication

T.20.1, page 299 – Recommendation

  • Here there are no trials and the recommendation is “conditional recommendation for either the intervention or the comparison”. A similar recommendation should occur for manipulation in the absence of evidence to the contrary.

T.21.3, page 309

  • Biased source
  • Strong side effects, inappropriate and soft recommendation (unlike manipulation).

T.22.2, page 317

  • Regarding opioids – under reporting of side effects

T.23.6, page 337 – Recommendations

  • Compare these recommendations to HVLA recommendations

T.25.2, page 352

  • Compare this outcome with HVLA manipulation
  • Risk of surgery understated
  • Bias

T.9 (HVLA manipulation recommendations):
We agree that there is inconclusive evidence (lack of high-quality studies) for manipulation techniques for the management of people with WAD. This is highlighted in the evidence summary for acute WAD where the trial is not consistent with care in an Australian context and that there was very low certainty in the evidence. The decision to make two recommendations regarding manipulation in acute WAD was made considering the evidence-to-decision framework where risks and benefits were considered. The “conditional against” recommendations do not rule out use of the procedure for individual patients, but we suggest that it should not be used for most people with whiplash. This has been clarified in the HVLA manipulation recommendations with the addition of “most”. Regarding comments on the other interventions (e.g., medications such as opioids); they should not be applied for most people with WAD and the implementation considerations for their use are stringent.

T.18 (simple analgesics):
We agree that there is no high-quality evidence for simple analgesics for the management of WAD. However, paracetamol is a first line analgesic that is widely available in an Australian context and is known to be an effective analgesic for some types of acute pain and has fewer side effects than NSAIDs.

T.20 (antidepressants recommendation):
This recommendation considered acute and chronic pain guidelines and efficacy of these medications in other pain types. Similar to the response with opioids above, subgroup considerations and indications for their use are outlined “People with suspected neuropathic/nociplastic pain and/or psychological distress who have not shown benefit with simple analgesics and NSAIDs.”

T.21 (pregabalin):
Small pilot randomised placebo-controlled trial (very low certainty in the evidence) showing clinically significant benefits of pregabalin in a specific subgroup with stringent indications for short-term use: “People who have high initial pain intensity (NRS≥5) early after whiplash injury (e.g., 48 hours post) and are suspected to have neuropathic pain.” This treatment has an upcoming planned clinical trial in Australia to evaluate its efficacy in people with WAD.

T.22 (opioid analgesics):
We do not believe we have underreported side effects “Clinically meaningful adverse effects (nausea, vomiting) of opioids are dose-related and in high doses opioids can induce hyperalgesia and/or acute tolerance.” We have also detailed additional considerations that include screening for history of drug misuse and ongoing monitoring, and contraindications for opioid use.

T.23 (multidisciplinary care):
While there is limited high quality evidence for multidisciplinary care in the context of WAD, multidisciplinary care is common practice for people who are medium/high risk of poor prognosis following whiplash injury in Australia. “Recommended treatments for managing acute WAD in these guidelines are delivered by several healthcare professions, and people with acute WAD are likely to receive multi-profession care in practice.” The risk stratified approach outlined in the whiplash injury care flowcharts in the Guidelines can be used to determine those who may benefit from multidisciplinary care, as it should not be applied to all people with acute WAD.

T.25.2 (Spinal surgery for chronic WAD and cervical radiculopathy). Risks outlined “Known significant adverse risks with cervical surgery (e.g., infection, vascular/neural damage).” The recommendation differs in this context as this is applicable to a small subgroup of people with chronic WAD and radiculopathy, rather than most people with WAD like in the HVLA recommendation.

Minor clarification to HVLA acute WAD recommendation (see response).
Sections 12.4 and 16.4: Psychologically informed exercise
CommentGuideline developer responseAction taken
The term “psychologically informed exercise”, a recommended treatment for acute WAD does not accurately reflect the interventions used in the RCTs that support this recommendation. Psychologically informed exercise infers that psychological techniques were used to overcome barriers to exercise. The included RCTs used exercise but also added psychological techniques to address stress symptoms (Sterling 2019), behavioural activation (Bring 2016), psychological strategies for example travel anxiety (Lamb 2013). These interventions would be better described as “exercise plus simple psychological strategies”.We agree that “psychologically informed exercise interventions” should be changed to “exercise plus simple psychological strategies”.Changed to “exercise plus simple psychological strategies” throughout the guideline document and in the treatment technical report.
Section 11.4: Psychological factors: Post-traumatic stress symptoms, expectations of recovery
CommentGuideline developer responseAction taken

Implementation – How to measure and interpret

  • It is important to note that the PCL-5 tool, or any other self-report measure, should not be used as the primary measure for diagnosis of PTSD.
  • The Primary Care PTSD Screen (PC-PTSD) is also a well-validated screening tool for PTSD to be used by psychologists and should be included in the guidelines.
  • There appears to be some variability within the Guidelines for the cut-off score for a provisional diagnosis of PTSD with the PCL-5 (e.g., on pages 70 and 141). Other research specifies 38 as a raw cut-off score for a provisional diagnosis, which has high sensitivity (.78) and specificity (.98). We recommend due consideration when using the PCL-5 to screen for PTSD. It would be beneficial to thoroughly review the research around the PCL-5 cut-off points to ensure there is a strong rationale within the Guidelines for these suggestions, along with consistent statements about the cut-off points throughout the Guidelines to minimise confusion.
  • It is also important to note that while a raw cut-off score is one method for determining a provisional PTSD diagnosis when using the PCL-5, the other method is to examine items rated as 2="Moderately" or higher as an endorsed symptom, then following the DSM-5-TR diagnostic rule which requires at least: 1 B item (questions 1-5), 1 C item (questions 6-7), 2 D items (questions 8-14), 2 E items (questions 15-20).
  • Further, if the PCL-5 is being used to monitor symptom change over time, a minimum 10-point change represents clinically significance.

Implementation – Indications

  • We agree with the position within the Guidelines that psychologists do not need to be immediately involved following a potentially traumatic experience. We recommend that people are offered practical and emotional support and encouraged to use their existing personal resources and social supports.

Implementation – What to do

  • However, it is critical for psychologists to become involved with individuals who are very distressed or do not start to return to their usual functioning within the first- or second-week post trauma. We recommend reconsidering the position within the Guidelines to wait until 6 weeks to refer if PTS symptoms are not improving.
  • This is particularly relevant given the ongoing and systemic workforce issues that have led to a chronic undersupply of psychologists nation-wide. Waiting until 6 weeks to make a referral to a psychologist may result in the patient waiting even longer to receive the treatment they need, thereby delaying recovery.
The guidelines recommend that the PCL 5 be used by primary health-care professionals to screen for likely posttraumatic stress symptoms, rather than determine a provisional diagnosis. Amended text in prognosis section for PTSS (section 11.4) to:
“Screen for PTSS with the PCL-5 tool. Scores of ≥34/80 could indicate the existence of Post-Traumatic Stress Disorder.” This cut-off differs to the TF-CBT implementation considerations as it considers people around the cut-off who may benefit from TF-CBT treatment (rather than possible existence of PTSD): “Scores around the cut-off (e.g., 31-33) suggest that the person may benefit from PTSD treatment and consideration should be given for referral for psychological management.”
Following screening for PTSS, if found to be elevated, referral should then be made for psychological assessment to determine the diagnosis of PTSD, using recommended methods. The guideline has been altered to make this clearer: “Mental health professionals should follow recommendations from clinical practice guidelines (e.g., Phoenix Australia Guidelines, NICE guidelines) around how to diagnose PTSD according to DSM-5-TR.”
Addition of useful alternative tools for assessing PTSS (section 11.4): “Useful alternatives to the PCL-5 are the Primary Care PTSD Screen for DSM-5 (PC-PTSD-5), PTSD Symptom Scale – Self-Report Version (PSS-SR), or the Davidson Trauma Scales (DTS).”

Implementation – Indications
We have added to the specific education information recommendations that educational information in the acute phase can include:
“Practical and emotional support for people with WAD to use their existing personal resources and social supports.”

Implementation – What to do
We agree and have amended the acute whiplash injury care flowchart and the prognosis section (PTSS) to consider assessment of PTSS and referral for psychological assessment in weeks 2-4 following injury.
For TF-CBT indications we have outlined for “People with diagnostic criteria for MVC-related PTSD.” and noted “The intervention could be provided earlier than three months, based on persons levels of distress and loss of function.”
We have removed any reference to length of time for diagnostic criteria for MVC related PTSD. See response above in relation to following recommended guidelines for diagnosing PTSD.

Guideline changed (see responses).
Section 11.5: Psychological factors: Depression, pain catastrophising and coping strategies
CommentGuideline developer responseAction taken

Implementation – How to measure and interpret

  • In addition to the using the DASS-21 to measure symptoms, the DASS-42 is also recommended and can be useful to yield meaningful discrimination between symptoms.
  • The in-text reference of “Guest et al., 2018” does not appear to be in the reference list of the Guidelines and hence we are unclear about the statement that a score on the DASS -21 greater than or equal to 15 out of 63 indicates a probable MDD. We assume the statement is referring to an interpretation of the raw score on the depression subscale only (i.e., out of 21), rather than a total raw score across the three subscales combined.
  • Further, the statement that a DASS -21 score greater than or equal to 15 out of 63 indicates a probable MDD may be misleading, particularly as the DASS is based on a dimensional rather than a categorical conception of psychological disorders, and scores emphasise the degree to which someone is experiencing symptoms rather than having specific diagnostic cut off points.
DASS 21 chosen as was used in primary trials. It is also in widespread clinical use in Australia, including with people with WAD.
Removal of specific cut-off for DASS-21. Amended implementation considerations to “When moderate or severe on the depression subscale consider referral for psychological management.”
Guideline changed (see section 11.5).
Page 71: >15 on DASS is predictive of MDD. Should that be >15 on the depression subscale> As that implies a cumulative score of depression, anxiety and stress.See amendment above.Addressed above.
Section 16.6: Psychological: Trauma focused cognitive behavioural therapy
CommentGuideline developer responseAction taken
  • It is important to note that there are a variety of treatments which commonly fall under the umbrella term of trauma-focused cognitive-behavioural therapy. These interventions commonly include:
    • Trauma-focused cognitive therapy (CT-PTSD)
    • Prolonged exposure (PE)
    • Eye movement desensitisation and reprocessing (EDMR), and
    • Cognitive processing therapy (CPT)
  • There is scope for the Guidelines to be more specific and expand on the well-established and evidence based recommended psychological treatments for PTSD.
    Implementation – Indications
  • We are unclear about the rationale for specifying that full diagnostic criteria for MVC related PTSD cannot be met until at least six months after the trauma. The DSM-5-TR criteria specifies that PTSD can be diagnosed when the “Duration of the disturbance (Criteria B, C, D, and E) is more than 1 month”. We therefore recommend that the Guidelines be amended from specifying “at least six months” to “more than one month” to align with the DSM-5-TR criteria for a PTSD diagnosis.
  • Why is the full diagnostic criteria not met until at least six months after the trauma (when PTSD can be diagnosed one month post trauma)?
  • There is an opportunity to better recognise Acute Stress Disorder (ASD) - ASD and PTSD share the same physiological and stress symptoms. However, ASD is only differentiated from PTSD by its limited duration, with symptoms present for more than three days, but less than one month. Where symptoms persist beyond a month, a diagnosis of PTSD should be considered.
    Implementation – Considerations
  • A structured clinical interview to assist with making a clinical diagnosis of PTSD according to DSM-5-TR criteria is recommended.
  • The following interview tools are recommended for use in the diagnosis of PTSD:
    • Clinician Administered PTSD Scale (CAPS)
    • PTSD Symptom Scale - Interview Version (PSS-I), and
    • Structured Interview for PTSD (SI-PTSD).
  • It is also important to note that while self-report measures can also provide useful information at the screening stage, these should not be used as a primary tool for diagnosis as they do not routinely provide an accurate picture of a client's symptoms or their severity
  • Recommend updating the Guidelines to ensure all references to the “DSM-5” are amended to refer to the most recent version, the DSM-5-TR.
Recommendation was based on the included trials. However, we have amended TF-CBT implementation considerations to include: “TF-CBT can also include prolonged exposure (see section 16.12 exposure therapy for chronic WAD), eye movement desensitisation and reprocessing, and cognitive processing therapy techniques.”
Implementation – Indications
Removed any reference to length of time for diagnostic criteria for MVC related PTSD. See response above in relation to following recommended guidelines for diagnosing PTSD.
HCPs are recommended to assess for PTSS and refer for psychological assessment if elevated. Mental health professionals can then make a diagnosis of ASD or PTSD.
Implementation – Considerations
See amendments detailed above relating to diagnosis of PTSD using the DSM-5-TR in accordance with PTSD guidelines. Amended DSM-5 references to DSM-5-TR.
Guideline changed (see responses).
Section 17.5: Additional symptoms: Jaw symptoms, upper limb disabilities and sleep quality
CommentGuideline developer responseAction taken

Implementation

  • We are unclear about the rationale to include ‘sleep quality’ within the category of jaw symptoms and upper limb disabilities. Sleep is an essential pillar of good health and while sleep disturbances may initially appear as a symptom of another disorder (e.g., depression, PTSD) or injury, this is not always the case.
  • It is important to acknowledge that sleep disturbance can be an independent problem that should be assessed or treated by appropriately experienced medical practitioners, sleep physicians or psychologists.
  • Note: other scales commonly used by psychologists to assess sleep disturbance include the Epworth Sleepiness Scale (ESS), STOP-BANG Sleep Apnea Questionnaire, and the Dysfunctional Beliefs and Attitudes about Sleep (DBAS).
These were other symptoms associated with poor prognosis that primary HCPs could be aware of.
Thank-you for the comments. These sleep resources could be added in the websites that will be used to implement key recommendations (e.g., MyWhiplash Navigator). These scales have been added to the implementation considerations for assessing additional symptoms (sections 13.3 and 17.5).
Scope appropriate sleep resources such as these and add to websites used to implement recommendations.
Guideline changed (see sections 13.3 and 17.5).
It’s strange that sleep is not more highlighted here but suspect it’s due to the low number of research articles.Only one included study evaluated sleep quality in people with WAD. This could be an area for future research. Sleep quality has been added as an additional outcome in future clinical trials of treatments for acute and chronic whiplash (see sections 14 and 18).Guideline changed (see response).
Risk stratification
CommentGuideline developer responseAction taken
Risk-stratification and referral to a specialist practitioner in whiplash management sounds like a very rational approach, and it is a pathway that could be implemented relatively easily. However, I think mention should be made of a recent publication (after the systematic reviews were undertaken), as these Clinical Guidelines will likely not be updated for another 5-10 years. The paper reports on an NHMRC funded RCT that tested this model of care (risk stratified care with specialist referral for individuals identified at medium or high risk) for acute WAD. It found that there was no benefit of risk-stratification followed by specialist care for patients at medium/high risk of poor recovery compared to usual care for the primary outcome of pain-related disability. There was a small effect on the secondary outcome of pain self-efficacy, but this was of questionable clinical relevance. This is only one RCT, but as evidence is scarce in all areas of treatment for WAD, it should be included. It should be referred to as initial evidence that may not support this approach. If not included, it tends to conflict with the otherwise excellent evidence-based approach to the development of the Guidelines and leave them open to criticism.We acknowledge that reference to the recent stratified care trial should be made. The panel have taken the outcomes of Rebbeck et al 2023 into consideration in the recommendations for the med/high risk group. Alterations include considering referral for med/high risk and not recovering and to consider interventions that have evidence of effect for the medium/high-risk group. We have added the following sentence in the footnote to the acute and chronic care flowcharts “This flow chart has been developed using evidence detailed in this guideline and informed by a recent stratified care trial (Rebbeck et al., 2023).”Notes to flow-charts amended (see sections 6 and 7).
Comment

2.1.4 Implementation

Healthcare professionals
CommentGuideline developer responseAction taken
Osteopathy must not be overlooked as a profession providing essential care within this space. Osteopaths should be included alongside physiotherapists and chiropractors in examples that reference allied health professionals providing management of musculoskeletal conditions, for example in T.4.1 regarding multimodal physical therapy. Osteopathy Australia should be included as an allied health professional body referenced in Table 1: Proposed strategies for target audiences within the Draft Dissemination and Implementation Plan.The majority of the clinical trials that inform the evidence were conducted by physiotherapists. In an Australian context, it is noted that allied-health professionals who manage whiplash include osteopaths. Recommendations refer to “healthcare professionals” as we acknowledge that treatment modalities are within the scope of practice of multiple professions.
The guideline panel has added osteopaths as an included target audience in the guideline document and draft dissemination plan.
Guideline changed (osteopaths have been added to the list of allied health practitioners in Section 4.3 of the guidelines).
There is reference to pain physicians and occupational physicians in the third edition of the guidelines but no reference to these physicians or other medical specialist groups in the fourth edition. Acute and chronic whiplash management crosses the domain of many health professional groups; this document relies heavily on the domain of the physiotherapists. The scope and title of the guidelines should be changed to reflect the restricted application and limited relevance to physiotherapists. There is also a sense that the guidelines aim to minimise medical practitioner involvement in the management of whiplash.Physiotherapist-led interventions were the most prevalent in treatment trials. The term Healthcare Professionals was used throughout the document to highlight that management crosses the domain of many disciplines. The list of HCPs that the guideline applies to is detailed in the target populations section (4.3) in the main guideline.
Pain and occupational physicians are also considered “whiplash specialists”.
“Specialist medical practitioners” are included in the explanation about “whiplash specialists”.
Clinicians must have sufficient scope to use their expertise and acumen to treat patients depending on the local community and cultures that they serve. It is important that the specialist clinician can select the appropriate treatment based on the complete biopsychosocial picture of the patient, which may not be possible for compensable patients if these guidelines are adopted.The intent of the referral to the “whiplash specialist” is to achieve this. That is the specialist undertakes an assessment of the complex biopsychosocial factors that can contribute to the individual presentation, then liaises with all stakeholders to facilitate individual management. Many of these biopsychosocial factors are detailed in the assessment section.

The role of the whiplash specialist is detailed in My Whiplash Navigator and can be amended in the implementation phase.

Scope and/ or amend role of the whiplash specialist in implementation phase.
Provide clarity on the scope of practice required from suitability credentialled primary contact practitioners to undertake the recommended assessment and interventions.
Provide clarity on the recommendations about evidence-based care specific to both the management of acute and chronic whiplash associated disorders.
The guidelines recommend that most registered HCP’s can undertake the simple assessments required to establish diagnosis. We note that some of the assessments and treatments do require advanced training and have attempted to make this clear. For example, a “whiplash specialist” is defined and includes specialist physiotherapists (see amended definition in section 4.3).Guideline changed (addition of “registered allied health professionals” to target population section – 4.3).
Insurers and access
CommentGuideline developer responseAction taken
This is a consensus document that significantly limits the ability for WAD patients to receive appropriate assessment and treatment. It presents itself as a guide to insurers and insurers have already started to deny payments for this treatment on the basis of the Draft Guidelines.SIRA have met with NSW CTP insurers and advised against using draft guidelines in their decision-making process for treatments until they are finalised. SIRA is committed to working closely with insurers regarding implementation of the Guidelines to support evidence-based decision-making.Actioned.
The treatments, such as radiofrequency neurotomy, are endorsed by the Department of Health as reflected by the Medical Benefits Schedule and its recent review. The treatments are available to patients with neck pain who are not covered by third party insurance. If the guidelines are followed, there will be a two-tiered system of medical management. The third-party claimants are discriminated against. This is counter to the concept of patient-centred care. Patients could be deprived of choosing these evidence-based options.This comment is noted.As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
While the post-injury flowchart refers frequently to ‘follow medical specialist advice’ as an outcome, it simultaneously provides no guarantee that appropriately selected and supervised specialised treatments will be funded. This is an insurance industry document, and the implications of the recommendations are clearly not just academic in nature. SIRA should clarify exactly what treatments it will fund specialist pain medicine practitioners to provide and the reasons for denial of expertly chosen and managed treatments in support of individual patients’ rehabilitation programs.These comments are noted. They are outside the scope of topics that are addressed in a clinical guideline.Nil.
The recommendations will result in delayed medical investigation and treatment which has serious implications for negligence for medical practitioners and the allied health community. This also applies to SIRA and insurers who commonly delay, deny or prevent approval for appropriate medical recommendations.These concerns are acknowledged. As a state government regulator of the NSW compulsory third party (CTP) insurance scheme, SIRA is committed to working closely with insurers and decisionmakers such as the Personal Injury Commission to support evidence based decision-making and ensure recommendations in the guidelines are appropriately interpreted and applied in practice by relevant stakeholders.SIRA will work closely with insurers and decisionmakers, particularly during implementation of the Guidelines to ensure decisions are consistent with recommendations.
Training
CommentGuideline developer responseAction taken
The need for training is mentioned in several areas of the guidelines. The amount of information provided on training varies and in relation to neck-specific exercises and psychologically informed exercise, there is little detail except to say that training by healthcare professionals is required for the treatment to be effective. We recommend the inclusion of details related to training implementation and/or governance be considered.We agree with the suggestions. However, the dissemination and implementation are to be subsequent phases of the guideline process. Plans for the implementation phase include the development of bespoke materials including infographics, short versions of guidelines, PowerPoint presentations and videos suitable for dissemination to the target audiences. Implementation science projects such as the design, implementation, and evaluation of an educational module(s) embedded in existing allied-health professional education will be conducted. Findings from these projects may inform future training requirements and/or mandates.
Guidance for treatment is detailed in the implementation considerations of these guidelines and examples on how to conduct these assessments and treatments are on the Whiplash Navigator website. Several treatments (e.g., neck-specific exercises), prognosis and assessment recommendations (e.g., assessment of range of motion, muscle endurance, balance) are within scope of these HCPs (specific to the response organisation) to implement in accordance with considerations detailed in these Guidelines.
Scope and ensure training requirements are detailed during the implementation phase.
Information to target audiences
CommentGuideline developer responseAction taken
Draft Dissemination and implementation plan: The strategies to reach target audiences are not strong enough. Giving an insurance clerk a script or graphic or giving healthcare professionals a graphic doesn't guarantee it will reach the injured person. Also, this information coming from those avenues will be seen by the injured person as being in the interest of the insurer. Can you mandate that when a claim is made that the insurer must send information to the injured person, and likewise when a HCP submits a plan, that they show that they have given the injured person information about prognosis (on the new SIRA AHRR form).This suggestion is reasonable and could be explored in the focus groups and will be piloted with Allianz.Ensure we address mandating sending information in our focus groups and Allianz pilot.

2.1.5. Public consultation questions

1. Is the recommended care pathway feasible to implement?
CommentGuideline developer responseAction taken
Whilst recognising that there is a need to meet standards for training and care pathways, the guidelines may not be feasible to implement in the rural and remote context due to resourcing and workforce challenges. Clarification about regional, rural and remote provision of care, particularly considering implementation practicalities and barriers if specific training for healthcare providers is required and/or mandated in these contexts should be provided. It is recommended that the challenges of rural and remote services be acknowledged in the guidelines with adaptions or workarounds discussed for regional, rural and remote context.We agree that there are challenges of resourcing and workforce in regional, rural, and remote areas in Australia. Access to health services was considered when developing recommendations under the ‘feasibility’ domain in the GRADE Evidence to Decision Framework, however, solutions to these challenges were not directly addressed. Access to healthcare professionals and the associated care pathways in these communities will be detailed as a possible limitation of these Guidelines. For some interventions, online resources for people with WAD and telehealth approaches may be applicable where access to healthcare is limited, however, this depends on internet access and technology proficiency. Further research is required to evaluate the effectiveness of these modes of treatment delivery in the context of whiplash injury in Australia.
We aim to conduct a focus group in a regional community to evaluate the acceptability and feasibility of implementing the recommended care pathways in these communities.
Evidence based prognostic and assessment tools are freely available on Whiplash Navigator. Tools and resources that have been recommended and are currently not available on Whiplash Navigator will be added. Guidance for self-management following whiplash injury is also available freely on Whiplash Navigator.
Exercises could be delivered face-to-face or virtually and have amended the neck-specific exercises section accordingly.
Guideline changed (see section 9.9 for addition to limitations).
Guideline changed (see sections 12.2 and 16.2 for consideration of virtual mode of delivery).
We aim to conduct a focus group in a regional setting.
‘Table 3: Executive Summary of Diagnostic recommendations for people with acute whiplash’ (page 23) may cause confusion. There is potential for the diagnostic process to be misinterpreted as rows two and three indicate that a healthcare professional can either complete a clinical neurological examination or refer for imaging to confirm cervical radiculopathy for WAD III. We suggest that the Domain description in row three be amended to the following to reflect the developed recommendation: “If cervical radiculopathy is suspected following clinical neurological examination, refer for imaging (MRI) to confirm”.
There may also be value in providing a brief key in the executive summary on page 23 to explain the different ratings that have been used in the summary tables. This would assist practitioners to understand the difference between conditional “for” and conditional “against”.
Amended to “If cervical radiculopathy (WAD III) is suspected following clinical neurological examination, refer for imaging (MRI) to confirm” in section 8.1.1.
While the recommendation classifications are described in detail in section 9.8, we agree that a key(s) for the executive summary tables should be provided as it precedes section 9.8. Summary of strength of recommendation classifications was added to each recommendation summary table in the Guideline documents (see sections 8.1 and 8.2).
Guideline changed (see responses).
It is feasible, although early intervention is highly recommended. It would be good to have 6-8 pre-approved physio sessions, to start treatment as soon as possible.Opinion noted. Early treatment is recommended in the flow-chart.Changes made to flow charts (sections 6 and 7).
In developing guidelines specific for CTP insurers, it is recommended that these be provided in easy to interpret formats so claims staff have clear guidance to support evidence-based treatment and are able to clearly interpret the conditions when treatment should be supported or declined. For example, providing instructional guidance relating to the use of medications, such as pregabalin, and imaging such as MRIs in any care pathway for managing WAD.Bespoke materials for insurance personnel will be developed in consultation with insurers as suggested as part of the implementation phase of these guidelines.Will be developed in the implementation phase of the guidelines.
Implementation would be facilitated by expanding on the term ‘psychologically informed physiotherapy’.The term “psychologically informed exercise interventions” was amended to “exercise plus simple psychological strategies” which included psychological techniques in addition to exercise to address stress symptoms (Sterling 2019), behavioural activation (Bring 2016), and psychological strategies for example travel anxiety (Lamb 2013). Research is underway to develop and assess the effectiveness of educational modules for HCPs to implement the intervention detailed in Sterling et al. (2019).Nil.
There is a considerable number of conditional recommendations within the Guidelines, which we understand is largely due to the paucity of national and international psychological research specific to WADs. While the development of the Guidelines is methodologically sound, drawing on research with a specific focus on WADs has resulted in a potential limitation in terms of the guidance provided to psychologists.
Future reviews of the Guidelines may benefit from considering the effectiveness of psychological therapies for broader chronic pain and trauma related conditions. This would enable guidance on evidence informed psychological assessment and treatments for whiplash-associated disorders.
To ensure the Guidelines are being implemented appropriately and as intended to achieve desired outcomes, it will be important to undertake an evaluation of the pathways model.
These suggestions can be considered during the implementation phase.These will be developed in the implementation phase of the guidelines.
Delayed implementation is recommended to allow for proper consultation.Stakeholders will be consulted during the implementation phase.Consultations to occur in the implementation phase.
2. Is the recommended care pathway acceptable to key stakeholders?
CommentGuideline developer responseAction taken
Insurers will need to be provided with information on who “whiplash specialists” are and how to access them. It is anticipated that access will rely on identification of a specialist, location of the injured person and the specialist as well as specialist availability. To support insurer access to healthcare professionals with the appropriate expertise, it is recommended that SIRA consider developing and publishing a register of whiplash specialists.The panel agree that a register of whiplash specialists be made available. This is currently included in My Whiplash Navigator and can be added to.During implementation phase, scope and expand list of whiplash specialists.
Chronic WAD is defined as between 24 weeks and up to 12 months post injury. After 12 months the draft Guidelines advise that the Clinical Framework for the Delivery of Health Services is followed for ongoing management of treatment. With the implementation of CTP Care there is the need to manage ongoing treatment and care needs for injured people who are post 5 years from accident date. The reference to the clinical Framework should be strengthened by quoting directly from the framework “setting expectations about discharge from treatment, and informing the person when recovery plateaus that their needs will be reassessed to determine whether any ongoing intervention will assist.”The suggestion about the direct quote from the Framework – quote was modified and included in the Week 24-12+ (addition of “12+”) months section of the chronic WAD care flowchart (see section 7) “Set expectations about discharge from treatment and inform the person when recovery plateaus that their needs will be reassessed to determine whether any ongoing intervention will assist.”Guideline changed (see section 7, Week 24 to 12+ months).
It was not clear whether consultation had been undertaken with pain specialists. It is suggested that consideration be given to including specific interventional pain treatments within the Guidelines.Consultation with Pain Specialist has occurred as part of the response to submissions. See responses to other submissions around consultation and the changes made to several intervention pain management treatment recommendations. Interventional pain management treatments recognised in public consultation submissions for which there is no applicable evidence have been added to a list of additional treatments. See previous response for full list of these treatments and how these treatments will be presented in the guidelines.Guideline changed (see response to other submissions related to interventional pain management recommendation)
As consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
No. The Guidelines lack credibility due to serious flaws in concept and development.Credibility will be part of the evaluation undertaken during the implementation phase.
See other responses in relation to the Guideline development procedures.
Outcomes of implementation will include perceived credibility.
3. What would be the impact on health equity?
CommentGuideline developer responseAction taken
The recommended care pathways indicate that advice, exercise and medications are first line recommended treatments for whiplash associated disorders. It is noted that resources related to these interventions can be accessed through the My Whiplash Navigator website and that the link for this website is included on the flowcharts. We believe that this will assist in enabling health equity. It is suggested that an infographic could also be developed to assist injured people locate relevant information.We agree that infographics may assist people in finding relevant information. Infographics will be developed as part of the dissemination and implementation phases of these guidelines.Nil.
There may be equity issues that relate to cultural sensitivities, challenges with language barriers and varied capability with navigating digital platforms – skills such as the proposed online information centre My Whiplash Navigator and self-administered tools such as WhipPredict.Implementation likely will involve development of materials suitable for CALD populations.To be developed in the implementation phase of the guidelines.
It is noted that the Guidelines recommend referral to a whiplash specialist if recovery is not progressing. Stakeholders may not know where or how to access whiplash specialists and there may be some instances when this type of care is difficult to access (for example in rural areas), and this may have the potential to impact on health equity. SIRA could consider developing a centralised listing of practitioners who are whiplash specialists. It is noted that there is currently a WAD specialist listing on the My Whiplash Navigator website however it is difficult to locate and only available once a practitioner has signed up to the website.A whiplash specialist registry to be developed further in the implementation phase.
Amended gaps in practice section (4.3) in implementation plan to include “…and access to these specialists in rural and remote areas may be limited.” In the implementation phase we will consider how to add to the list of existing whiplash specialists including if they provide telehealth services to address the rural, remote issue.
Develop / add to list of whiplash specialists during implementation phase.
Implementation plan changed – see response.
There are flawed treatment recommendations which would create a ‘second-class patient’ with compensable WAD compared to privately insured clients who could access the full range of potentially useful specialised treatments such as botulinum toxin, ketamine infusions, cervical radiofrequency neurotomy and access to expert pain management teams.As per previous responses, recommendations are derived from robust systematic reviews, following GRADE process.Note that a list of treatments for which no evidence is available has been added. However, as consensus was not reached with pain medicine stakeholders with reference to radiofrequency neurotomy the draft section of the Guidelines addressing this topic has been withdrawn.
4. What would help you to apply these recommendations in practice?
CommentGuideline developer responseAction taken

The actions below could assist in raising awareness of the Guidelines amongst stakeholders:

  • Education sessions for emergency staff as well as primary care providers with a focus on the importance of clinical assessment.
  • Documentation of WAD level diagnosis and the recommended care pathways for each level of WAD.
  • Updated information in SIRA’s online Treatment Advice Centre.
These will be considered in the implementation phase.Will be considered in the implementation phase of the guidelines.

To assist in the application of these recommendations, it is proposed that:

  • A register of whiplash specialists is developed that includes the location and qualifications of each specialist.
  • The guidelines include a summary of expected timeframes for recovery pathways based on the WAD classifications.
  • Consideration for the whiplash specialists to be used as a resource to provide guidance and recommendations to treating providers.

Injured people should have the appropriate supports when using prognostic tools such as WhipPredict and SF-Orebro that provide a risk stratification to the user. As these tools can be self-administered online, injured people may obtain information indicating (in Week 1) that they have a poor prognosis. This may have a detrimental psychological effect that negatively impacts recovery.
In addition, it may be beneficial if the guidelines placed a stronger emphasis on positive messaging by practitioners to encourage positive recovery strategies that may not be provided via a prognostic tool used in isolation.
icare notes that the Dissemination and Implementation Plan includes the development of CTP insurer bespoke/specific guidelines and welcomes the opportunity to take part in any consultation relating to these.

A whiplash specialist registry to be developed further in the implementation phase. Whiplash specialist definition amended to “For the purpose of these guidelines, defined as an allied or medical healthcare professional with advanced clinical expertise in managing whiplash. May include but not limited to specialist physiotherapists and specialist medical practitioners. The role of the specialist is to undertake additional and more comprehensive assessments to identify other individualised biopsychosocial factors associated with poor recovery. They will then liaise with the treating HCP(s) to formulate a person-centred treatment plan with specific goals set over realistic recovery timelines.”
Agree that communication around risk needs to be delivered positively, with suggestions provided on how to do this within the guideline and on MyWhiplash Navigator.
Agree with the positive messaging around prognosis - we are developing short videos with examples of these as part of the implementation phase.
In relation to recovery pathways for WAD classifications, these are detailed in the flow chart. Separate pathways are detailed for WAD II (low and med/high risk) and WAD III (recovering/ not recovering).
Guideline changed (role of whiplash specialist amended). Whiplash specialist registry to be developed further in implementation phase.
Implementation planning will involve consultation with relevant stakeholders including SIRA.
There needs to be access to appropriate services and psychologists who are able to deliver suitable assessments and interventions to meet individual requirements. The addition of further guidance and education to inform health practitioners about referral pathways may be beneficial. This may include providing information about specific services such as pain management programs, or more general information about practitioners, e.g., psychologists, with experience in the assessment and treatment of specific WAD presentations (i.e., chronic pain). This is particularly relevant within the context of access to services (e.g., psychological) for people in rural and remote areas and/or those with reduced mobility.Psychologists and or services that have expertise in implementing or providing recommended interventions could be scoped during the implementation phase.To scope in implementation phase.
Further work should be done with adequate engagement of appropriate stakeholders in specialist care. While the Guidelines in their current form could at least potentially be adapted for use in primary care, as a template for approval of treatments in specialist care it is inadequate and will lead in practice to an increase in conciliation of claims involving specialist care.Agreed, this is intended to be done in the implementation phase.To scope in implementation phase.

2.1.6. Editorial comments and amendments

CommentGuideline developer responseAction taken
Page 67: “with respect to” instead of “with respect of” sounds more correct.Noted and amended.Amended to “with respect to” as suggested.
Page 129: Typo “felling anxious”Noted and corrected.Corrected to “feeling” as suggested.
Section 16.2 on page 135 which deal with chronic WAD includes “acute” in the recommendation. This should be corrected to “chronic”.Noted and amended.Amended error of “acute” to “chronic WAD” in section 16.2 as suggested.
The response to the question in section 16.15 on page 154 refers to “radiculopathy people” (see line 5). We suggest this be amended to “people with radiculopathy”.Noted and amended.Amended error of “radiculopathy people” to people with radiculopathy” in section 16.6 as suggested.
Table 15: Panel consensus recommendation classification on page 49: includes “Neutral” in the consensus classification column. We suggest that this be amended to “Neutral consensus”, so it is consistent with other areas of the Guidelines, for example Table 9 on pages 32 to 33.Noted.“Neutral consensus” added in table 15 as suggested.
The abbreviation “PPS WAD” is used in Table 4 on page 25, however there is no explanation of this acronym. Include explanation of “PPS-WAD” in the Guidelines.PPS-WAD refers to the modified Prediction of Prolonged Self-perceived recovery after musculoskeletal injuries Questionnaire for whiplash.Definition of PPS-WAD was included as a footnote to Table 4 and to the list of abbreviations section.
A definition of passive therapy/passive physical therapy would assist stakeholders to understand why treatments are classified as passive.Noted and guidelines amended.A definition of “passive physical therapy” was added as suggested. This was added to the first reference in the executive summary tables (acute and chronic) as a table footnote, “*Passive physical therapy refers to treatments applied to the person with WAD, without physical effort by the person.”