On 21 April 2017 and 15 February 2018, the Department of Health wrote to general practices that were identified as not meeting the shared health summary upload requirements under the ePIP incentive.
These frequently asked questions are designed to assist practices who received a compliance letter to better understand the compliance activity and how to contact the Department.
Why have I received this compliance letter?
You received this letter because your practice is registered for the ePIP incentive and it has either not uploaded the required number of shared health summaries in one or more quarters over the period 1 May 2016 to 31 January 2018 or beyond or your practice ID cannot be linked to your HPI-O number.
What should I do if I have reviewed my records and I do not agree with the Department’s assessment?
If you have reviewed your records and do not agree with the assessment made by the Department of Health with regards to your shared health summary upload figures for any quarter over the period 1 May 2016-31 January 2018 or beyond, please email the department at epip.compliance [at] health.gov.au with the following information:
- Your practice name
- Your HPI-O
- Your PIP ID
- Evidence of your shared health summary uploads completed by your practice. This could include screen shots from your software program. Any screen shots provided should not include information that could identify a patient or otherwise breach their privacy.
Why have I not received a response to my email I sent to you?
The Department has received a high volume of enquiries and will endeavour to reply to your email as soon as possible. To enable the ePIP Compliance Team to prioritise your enquiry, please include your reference number and one of the following in the subject line of your email:
- General Enquiry <CSEXXXXXXXXX>, or
- Compelling Circumstance <CSEXXXXXXXXX>, or
- Voluntary Acknowledgement <CSEXXXXXXXXX>
If you have emailed the epip.compliance [at] health.gov.au, an automated response will be generated advising you that the Department of Health has received your correspondence.
If the Department requires further information to assess a compelling circumstance, you will receive a follow-up email requesting the necessary information.
If I have contacted the ePIP Compliance Team but have not received a response within the 28 days will I automatically be issued a formal debt recovery notice?
No, each email will be reviewed and appropriate action will be taken.
How can a General Practice find their HPI-O?
Healthcare Provider Identifier – Organisation (HPI–O) — identifies the healthcare provider organisation where healthcare is provided, such as hospitals, medical practices, pathology or radiology laboratories and pharmacies. When an organisation applies with the Healthcare Identifier (HI) services to participate in My Health Record they are assigned with an HPI-O. If your organisation has participated in the My Health Record you would have received a HPI-O.
If you are unaware what your HPI-O is, you can easily find out in the following ways:
1) The letter you received from Department of Human Services.
2) If you are participating in the ePIP, your software has been setup with your HPI-O.
Are you able to waive my debt if I commit to meeting my shared health summary upload targets in the future?
Debts cannot be waived. Under the Public Governance and Accountability Act 2013, the Federal Government is required to collect all monies it is owed on behalf of Australian taxpayers. It is a requirement that shared health summary upload targets are met within the specified ePIP cycle.
How do I calculate what I owe?
For letters dated 15 February 2018
Following feedback from practices that received compliance letters in April 2017, compliance letters dated 15 February 2018 specify the amount owing.
For letters dated 21 April 2017
Repayment of funds: Practices that did not upload the required number of shared health summaries over the period 1 May 2016 to
31 January 2017 fall into three categories:
Category 1: No shared health summary uploads
All money received for the ePIP incentive is required to be repaid. The amount you received is detailed in paragraph 2 of the letter.
Category 2: 1 to 49% of shared health summaries uploaded
Practices that uploaded less than 50% of their required number of shared health summary uploads are required to repay all funds received, however if they met their shared health summary upload targets in a single quarter the funds received for that quarter may be retained. The table at the top of your letter provides information of which quarter (if any) you met your upload target in.
The amount received each quarter is detailed in your quarterly payment advice statement from the Department of Human Services.
Category 3: 50 to 99% of shared health summaries uploaded
Practices that uploaded more than 50% of their required number of shared health summary uploads are required to repay the portion of the target that wasn't met. For example:
Total funds received $24,375
1 May -
31 Jul 2016
1 Aug -
31 Oct 2016
1 Nov -
31 Jan 2017
Shared health summary target = 75 Shared health summary uploads = 60 Percentage of uploads = 60 / 75 * 100 = 80% Percentage to be repaid = 20% Funds to be repaid – $24,375 * 0.2 = $4,875
Am I able to pay back the money I owe on a payment plan?
A payment plan may be available. Please complete the Voluntary Acknowledgement of Incorrect Payment form and return to the department. An invoice will be issued to you outlining the repayment options, including how to request a repayment plan.
Am I able use future ePIP payments to repay my debt?
Future ePIP payments cannot be reduced in order to repay this debt.
What will happen if I do not complete the Voluntary Acknowledgement of Incorrect Payment form?
If you have sought an exemption due to
compelling circumstances, the department will review the information provided and make an assessment. You will be contacted with the decision and what action will be required.
If you are not seeking an exemption due to compelling circumstances and do not complete the Voluntary Acknowledgement of Incorrect Payment form, a formal debt recovery notice will be sent to your practice.
Will I be charged interest if I do not complete the Voluntary Acknowledgement of Incorrect Payment form?
No. Interest will not be charged. Penalties may apply if you do not respond to a formal debt recovery notice. Your practice may also be withdrawn from the ePIP for continued non-compliance.
In which circumstances can I seek an exemption for circumstances outside my control?
You can seek an exemption for one or more quarters if your practice experienced ongoing technical difficulties, that prevented the upload of shared health summaries for the majority of a quarter. You should also provide evidence to demonstrate what steps were taken to resolve the issue.
Ongoing technical difficulties relate to problems with your practice software uploading shared health summaries to the My Health Record system. Practices should demonstrate that they made attempts to upload shared health summaries but could not and that they tried to resolve the issues.
What should I do if there were circumstances outside my control that prevented me from meeting my ePIP shared health summary upload targets?
Please email epip.compliance [at] health.gov.au with the following information:
- Your practice name
- Your HPI-O
- Your PIP ID
- The quarter(s) in which you are seeking an exemption
- The reasons that you are seeking an exemption
- Evidence to support the reasons you are seeking an exemption. Evidence should not include any information that could identify a patient or otherwise breach their privacy.
Can I seek an exemption due to issues with my internet connection?
No. If a practice has been able to upload claims information to Medicare it is considered that there has been sufficient access to the internet to also upload shared health summaries.
Can I seek an exemption due to extended staff absences?
No. A practice is able to opt out of an individual quarter if it has insufficient staff to meet its upload targets.
Can I seek an exemption due to insufficient patients with a My Health Record?
No. More than 5.5 million Australians have a My Health Record. The percentage of registered My Health Record users significantly exceeds the percentage of shared health summary uploads required by each practice. If you do believe that you are unable to participate in the ePIP incentive you may opt out or withdraw at any time.
I operate two or more practices under a shared database arrangement. This has resulted in one or more of my practices being identified as not uploading any shared health summaries.
The Department acknowledges that those practices operating under a shared database arrangement and using older software products will only show shared health summaries uploaded against a single practice. You are encouraged to contact your software vendor to consider whether a newer version of your software will allow you to work more effectively under a shared database arrangement.
If you have reviewed your records and do not agree with the shared health summary upload figures for your practice supplied by the Department due to a shared database issue, please email epip.compliance [at] health.gov.au with the following information:
- The individual names of all your practices
- HPI-O numbers of all your practices
- PIP IDs of your all practices
- Evidence of the shared health summary uploads completed by each practice operating under the shared database arrangement. This could include screen shots from your software program. Any screen shots provided should not include information that could identify a patient or otherwise breach their privacy.