ePIP Compliance Letters

The Department of Health (the Department) writes to general practices that have been identified as not meeting the shared health summary upload requirements for a payment quarter under the Practice Incentives Program eHealth Incentive (ePIP). 

The following frequently asked questions can assist general practices that have received a compliance letter to better understand the compliance activity and how to contact the Department.

Why have I received a compliance letter?

You received a letter because your practice is registered for ePIP and it has not uploaded the required number of shared health summaries in one or more quarters.

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 with regards to your shared health summary upload figures for any quarter, you must submit a dispute of upload figure request substantiating your claims.

Please email epip.compliance [at] health.gov.au. Your correspondence with the Department should include:

• The name your practice is registered under for ePIP
• Your HPI-O number
• Your PIP practice ID
• Evidence of your shared health summary uploads for the relevant quarter, such as an SHS upload report or screenshot taken directly from your clinical software and/or PenCAT. Manually created reports will not be accepted.

Please note: Any evidence provided should not include information that could identify a patient or otherwise compromise their privacy. All supporting information should have individual patient information de-identified prior to submission.

Example:

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 software products that only allow one HPI-O number to be used will only show shared health summaries uploaded against a single practice. This means that compliance activity against the other practices may occur each quarter until such time as you update your software to a version that allows multiple HPI-O numbers to be used. You are strongly encouraged to contact your software vendor to consider whether a newer version of your clinical software will allow the uploads from all of your practices to be separately identifiable 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 – please indicate which practice is the seed organisation
• HPI-O numbers of all your practices
• PIP practice IDs of your all practices
• Evidence of your shared health summary uploads for each practice for the relevant quarter, such as SHS upload reports or screenshots taken directly from your clinical software and/or PenCAT. Manually created reports will not be accepted.
• Please note: Any evidence provided should not include information that could identify a patient or otherwise compromise their privacy. All supporting information should have individual patient information de-identified prior to submission.

In which situations can I seek an exemption from ePIP requirements due to compelling circumstances?

You can seek an exemption due to compelling circumstances only if your practice experienced ongoing technical difficulties that prevented the upload of shared health summaries for the majority of a quarter.

Ongoing technical difficulties relate to problems with your practice software uploading shared health summaries to the My Health Record system that were beyond the control of the practice. Practices should demonstrate that they made attempts to upload shared health summaries but could not and that they tried to resolve the issues during the relevant quarter.

What should I do if I want to submit a request for exemption due to compelling circumstances outside my control that prevented me from meeting my ePIP shared health summary upload targets?

If you believe there were compelling circumstances that meet the above criteria and you wish to apply for an exemption, you must submit a request for exemption substantiating your claims to the Department.

Please email epip.compliance [at] health.gov.au with the following information:

• HPI-O number of your practice
• PIP practice ID number
• Evidence of the software used and the technical issues experienced, such as screen shots of error messages, evidence of unsuccessful shared health summary uploads.
• Evidence of contact with your software vendor or IT provider such as emails, call log audits, service docket requests, and support letters regarding these technical issues.
• The steps taken by your software vendor or IT provider to resolve these issues.
• When these issues were resolved.
• Any other information or evidence that may support your claim.

Please note: Evidence should not include any information that could identify a patient or otherwise compromise their privacy. All supporting information should have individual patient information de-identified prior to submission.

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 throughout the relevant quarter, it is considered that there has been sufficient access to the internet to also upload shared health summaries during the quarter.

If you believe that you will not be able to meet your minimum upload requirement for the quarter, you are able to opt out of that quarter at any time before the end of the quarter.

Can I seek an exemption due to staffing issues?

No. A practice is able to opt-out of an individual quarter if staffing issues arise that could affect its ability to meet upload targets.

Can I seek an exemption due to insufficient patients with a My Health Record?

No. As at 13 January 2019, almost 6.5 million Australians have a My Health Record. In February 2019, every eligible Australian who has not chosen to opt-out will have a My Health Record created for them. 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.

Can I seek an exemption due to a NASH certificate issue?

No. It is an ePIP eligibility requirement that practices have an up to date NASH certificate and it is the responsibility of practices to be aware of its expiry date. If practices are unable to meet their shared health summary upload requirements, they are able to opt out of that quarter at any time before the end of the quarter via HPOS system. For assistance with your NASH PKI please call 1800 700 199.

How can a General Practice find their HPI-O?

A Healthcare Provider Identifier – Organisation (HPI–O) identifies the healthcare provider organisation where healthcare is provided, such as medical practices, hospitals, pathology or radiology laboratories and pharmacies. If your organisation has participated in the My Health Record you would have received a HPI-O.

If you do not know what your HPI-O is, you can find out by checking:

1) the letter you received from Department of Human Services; or

2) your clinical software that should have been set up with your HPI-O.

Once you have identified your HPI-O, the Department encourages you to enter it into the Health Professional Online Services (www.humanservices.gov.au/organisations/health-professionals/services/medicare/hpos#group-130) and ensure all other information is current.

Why have I not received a response to my email I sent to you?

The Department receives a high volume of enquiries that we endeavor to reply to 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
• Discrepancies in Shared Health Summary Upload <CSEXXXXXXXXX>, or
• Voluntary Acknowledgement <CSEXXXXXXXXX>.

If you have emailed epip.compliance [at] health.gov.au, an automated response will be generated advising you that the Department has received your correspondence. 

To ensure the Department can accurately assess your enquiry, please provide all evidence to support your claim in the original email.

Am I able use future ePIP payments to offset 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 or submitted evidence of your uploads, 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 the Department has not received any correspondence from your practice within the given timeframe in response to the compliance letter and you do not submit a Voluntary Acknowledgement of Incorrect Payment form, a formal debt recovery notice will be sent to your practice.

If I have contacted the ePIP Compliance Team but have not received a response will I automatically be issued a formal debt recovery notice?

No, each email will be reviewed and appropriate action will be taken.

ePIP Guidance Material

• National Authetication Service Health
• Practice Incentive Program (Medicare) Phone line: 1800 222 032
• Practice Incentives Program

To register for a NASH PKI Certificate or PKI Individual Certificate, go to www.humanservices.gov.au/hpos

• HI Service
• Getting started with digital health
• Practice incentives program
• ePIP FAQs
• My Health Record Training Resources

For quarters one to seven (1 May 2016 – 31 January 2018)

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, Performance 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 quarter.

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) in which you met your upload target.

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