"Every breach you look at occurred because somebody inside did something they weren't supposed to do. Sometimes there's an accomplice, but most of the time, it's innocent."


  Considered Health

Issue 15 - Health Newsletter

The Red Book

Guidance on Laws Relating to Pathology and Diagnostic Imagining-Prohibited Practices

In 2008, we saw the introduction of The Red Book from the Department of Health (DoH), outlining  regulations on prohibiting practices in commercial relationships between referrers and providers of pathology and diagnostic imaging services.

In the 2017-18 Budget, the Government announced it would be seeking to strengthen the Compliance and Enforcement Strategy for the 5,797 Pathology Approved Collection Centres rental arrangements.   

Changes in the DoH's Red Book include the following:

  • Information about the compliance and enforcement strategy and its implementation.
  • Inclusions of examples of scenarios in which issues with rents have been identified by or to the DoH.
  • Questions and Answers section on submitting leases following changed arrangements and reporting inappropriate practices.

The focus is also increased through seeking independent assessment of market value, and a clearer explanation of ways in which parties could break the competition and consumer laws.

The legislation has not changed as a result of the industry consultation process undertaken by the DoH.  It still dictates that rental rates should not be more than 20% variance from the market value, but the means of determining market value remains ambiguous. The Red Book states that "market value does not have a special meaning under these laws, but instead has its ordinary common law meaning". 


Our understanding is that the DoH are actively scrutinising the annual applications and reviews submitted by the Pathology providers with a view to target "Outliers" where rental rates are considered well above market rate.  

Our commitment is to ensure you are aware of these changes DoH will be implementing and if your Medical Practice is one of the 5,797 nationally. You could potentially be receiving a "Request for Information Notice" shortly and you'll have only 10 days to provide a written response. We suggest it is prudent that practices review the rental rates around existing leases to consider the potential risk to your financial position and determine a strategy around this.

Notifiable Data Breach Scheme

The Notifiable Data Breach Scheme commenced on the 22 February 2018. The Office of the Australian Information Commissioner (OAIC) said there was substantial involvement in consultations around this scheme, and as such these new obligations are an extension of the existing privacy law around collection, use and disclosure of health and other personal information as part of caring for your patients.

Providing a service that upholds the privacy of health information has always been crucial to the relationship of trust and confidence between doctor and patient. The NDB scheme will strengthen the protections provided to everyone's personal information and as such significant penalties will apply if there is a breach. 

We've provided some potential examples of unauthorised access, disclosure or loss which might lead to an obligation to inform your patient and OAIC as follows: 

  • A patient receives another patient's test results,
  • Disclosing inappropriate health information to a family member or friend ( i.e. being not permitted under the privacy laws or in breach of a Court order).
  • Accessing and viewing health records by unauthorised practice staff members or contractors.
  • Insufficient processes to remove and destroy sensitive information on your practice's computer hardware before it is disposed of.
  • Failure to appropriately firewall your practice's computer system or cloud storage provider from hackers.
  • Break-ins and theft of information from your practice or storage provider.
  • Patient information stored separately (i.e. USB or Paper) being lost or misplaced. 
  • Mistakably placing health or other personal information on a publicly accessible website.

Identifying ways your practice responds to serious data breaches should be a priority, which may include the following preventative measures:

  • Assessing your practice's privacy policy and procedures, are these in place and up-to-date?
  • Does everyone in your practice understand their privacy obligations in line with the new scheme?
  • Identifying all outside contractors, such as IT or cloud service providers and as such making sure there is a suitable agreement in place dealing with privacy and notifiable data breach obligations.
  • Reviewing potential risk areas of your practice and taking the appropriate steps to reduce risk.
  • Create a notifiable data breach plan and deliver this to all employees so your practice is fully aware of the required steps when there is a potential breach. 
  • Review your cyber security measures with your IT Provider to ensure they are up to standard.
  • Consider a cyber insurance policy if you haven't already got one.?
For further information we suggest the following links.



Practice Incentive Program Quality Improvement Incentive

GP practices were expecting to transition to the new PIP arrangements in May 2018 incorporating the PIP QI incentive.  These changes have been postponed for 12 months and will now commence on 1 May 2019. The delay provides extra time for all departments to address any implemented issues and also allow General Practices time to prepare.

The five incentives that were identified to cease on the 1 May 2018 will continue through to 30 April 2019.

The five incentives are:
  • Asthma Incentive
  • Quality Prescribing Incentive
  • Cervical Screening Incentive
  • Diabetes Incentive
  • General Practitioner Aged Care Incentive
    There are six incentives that will remain unchanged as follows:
  • eHealth Incentive
  • After Hours Incentive
  • Rural Loading Incentive
  • Teaching Payment
  • Indigenous Health Incentive
  • Procedural General Practitioner Payment
  • The delay is in response to feedback which recognised the importance that General Practice readiness is critical to the effective implementation.

    The Practice Managers Networking Groups

    Practice Manager Networking Groups offers the opportunity to connect with like-minded practice managers to share ideas, experiences, and to provide and seek support.

    These groups ideally meet a few times a year, either over a coffee, breakfast, lunch or dinner. To find a group near you, click the link below to find out further details and how you can be involved.

    AAPM National Conference-Canberra 2018

    Powering Your Journey, Driving Change

    2018 Annual Conference

    16-19 October, National Convention Centre, CANBERRA

    Registration has now opened for the 2018 AAPM Annual Conference . Register early and save up to $100 with the early-bird registration packages. Full registrations includes the welcome reception and dinner.

    AAPM aims to ensure excellence in healthcare management for better patient outcomes. As the peak association supporting practice management, AAPM provides education, support, advice and advocacy for those involved in healthcare practice management.

    AMPHEat Workshop Events

    AMPHEat in conjunction with Brentnalls SA will be presenting a FREE session on the topic of "Understanding the basics so you can understand your accountant" on 17 May 2018. 

    This information session will cover the following topics:

    • How to read and interpret financial statements.
    • What is the difference between accounting and cash profit.
    • What financial measures should you monitor in the practice throughout the year.
    • Questions you should be asking your accountant.

    To register please click the link below.


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    The information provided in this newsletter does not constitute advice. The information is of a general nature only and does not take into account your individual objectives, financial situation or needs. It should not be used, relied upon, or treated as a substitute for specific professional advice. We recommend that you contact Brentnalls SA before making any decision to discuss your particular requirements or circumstances. Brentnalls is not a partnership or a joint venture. Instead, the business of Brentnalls SA is independently owned and operated and it is an independent member of the Brentnalls Affiliation of Accounting Firms. Individual member firms do not accept responsibility or liability for the actions or inactions of any other individual member firm.
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