Compliance
The Pharmacy Programs Administrator (PPA) is authorised under its service agreement with the Department of Health and Aged Care (the Department), to undertake monitoring and compliance activities in relation to programs funded by the Department. These activities inform and support audit activity undertaken by the Department and assist the Department and PPA to maintain compliance with the Public Governance, Performance and Accountability Act 2013 (Cth).
Overview
From 1 February 2020 the PPA will commence active monitoring and compliance activities and these activities will be ongoing. The monitoring and compliance program includes approaches and mechanisms to prevent, detect, investigate and correct claims which are inaccurate, inappropriate or are not in accordance with the relevant Program Rules (i.e. are ineligible).
The purpose of the PPA and Department’s monitoring, compliance and audit activities is to ensure that Service Providers in receipt of Department of Health and Aged Care Program funds:
- Register, claim and deliver services in relation to each Program in accordance with the Program Rules
- Comply with the PPA General Terms and Conditions
For further information regarding the PPA and Department’s monitoring, compliance and audit activities please refer to this Factsheet.
Corrective Actions
In circumstances where inaccurate, unsubstantiated or ineligible claims are identified, the PPA may refer the Service Provider and all evidence to the Department for consideration. Any corrective actions taken will be based upon a range of factors, including but not limited to, the nature, scale and value of any inaccurate/inappropriate claiming activity as well as whether the issue identified is a first, or repeat occurrence.
A range of corrective actions may be pursued, including, but not limited to, one or more of the following:
- The issue of an official caution or warning
- Implementation of enhanced monitoring activities in relation to the Service Provider
- Repayment of all or part of claims found to beinaccurate or unsubstantiated
- Suspension or cancellation of the Service Providers’ registration for one, multiple or all Programs
- Review of all government funds provided to the Service Provider (e.g. PBS)
- Referral of pharmacist(s) to AHPRA for investigation
- Referral to law enforcement agencies, as appropriate
- Any other action provided for under the National Health Act 1953 (Cth).
Tip-Offs
As part of the monitoring, compliance and audit activities, the PPA via the Support Centre, accepts and reviews ‘tip-offs’ from individuals, including members of the public, who believe that a particular Service Provider:
- Has made one or more potentially inaccurate or unsubstantiated claims; or
- Is delivering services in a manner which is not in accordance with the Program Rules and is claiming in respect of these services (i.e. has made ineligible claims).
Please note the PPA cannot investigate tip-offs related to PBS dispensing or Medicare. If you wish to submit a tip-off related to the PBS/Medicare you can do so here: https://www1.health.gov.au/internet/main/publishing.nsf/Content/health-provider-tip-off.
Submitting a tip-off
Individuals wishing to submit a tip-off to the PPA can:
- Contact the Support Centre on 1800 951 285 to discuss their concerns with a member of the team directly. Individuals can choose to withhold their identity from the subject of their tip-off
- Email their concerns directly to support@ppaonline.com.au
- Submit their concerns in writing by completing the form located below. This form will automatically submit the tip-off to our Support Centre and there is an option to remain anonymous.
Please note:
You may make your tip-off anonymously and you may choose not to provide contact details. However, if you submit your tip-off anonymously, the PPA will not be able to contact you if it needs to verify details or request additional information.
If you would like to provide further evidence to substantiate your tip-off but wish to remain anonymous, please post documents to:
Pharmacy Programs Administrator
Locked Bag 3
Collins Street East
VIC 8003
Compliance FAQ
Compliance FAQ
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What are the objectives of the PPA’s audit and compliance program?ExpandClose
The purpose of the PPA and Department’s monitoring, compliance and audit program is to ensure that Service Providers in receipt of Department of Health and Aged Care Program funds:
- Register, claim and deliver services in relation to each Program in accordance with the Program Rules; and
- Comply with the PPA General Terms and Conditions.
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How will I know if my business has been selected for audit?ExpandClose
The PPA will email you if your business has been chosen for a random review, desktop review or site visit. The email will contain details regarding the claims being reviewed, such as the claim ID, as well as a list of supporting documentation required to substantiate the claims.
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How long do I have to produce the requested supporting documentation?ExpandClose
The PPA requests that all documentation be provided within 10 business days from the date of the email notification.
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What supporting documentation may the PPA request I produce to substantiate my claims?ExpandClose
Examples of supporting documentation that the PPA may request include, but are not limited to, the following:
- Patient Consent Forms
- DAA Packing Reports
- Reports from dispensing software programs
- Copies of Scripts
- RMMR reports
- GP referrals
- Pharmacist time sheets
- QUM Activity logs.
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How long must I hold onto supporting documentation?ExpandClose
Service Providers must retain all records of supporting documentation for seven years to demonstrate that services claimed through the PPA Portal have complied with the General Terms and relevant Program Rules.
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What happens if I’m unable to produce the requested supporting documentation to substantiate one or more of my claims?ExpandClose
In circumstances where inaccurate, unsubstantiated or ineligible claims are identified, the PPA may refer the Service Provider and all evidence to the Department for consideration. Corrective actions to be taken will be based upon a range of factors, including but not limited to the nature, scale and value of any inaccurate/inappropriate claiming activity as well as whether the identified issue is a first, or repeat occurrence.
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What are the corrective actions that may be taken by the Department and/or PPA?ExpandClose
A range of corrective actions may be pursued, including but not limited to one or more of the following:
- Issue an official caution or warning
- Implementation of enhanced monitoring activities in relation to the Service Provider
- Require the repayment of all or part of the inaccurate or unsubstantiated claims
- Suspend or cancel the Service Providers’ registration for one, multiple or all Programs
- Review of all government funds provided to the Service Provider (e.g. PBS)
- Referral of pharmacist(s) to AHPRA for investigation
- Referral to law enforcement agencies, as appropriate
- Any other action provided for under the National Health Act 1953 (Cth).
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What authority does the PPA have to audit my business?ExpandClose
The Pharmacy Programs Administrator is authorised under its service agreement with the Department of Health to undertake monitoring and compliance activities in relation to programs funded by the Department.
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I’ve inadvertently submitted an ineligible claim and/or claim with incorrect details. How do I amend my mistake?ExpandClose
If you become aware of any inaccurate or ineligible claim, we request that you contact the PPA Support Centre and notify us as soon as possible. Depending on the nature and timing of the error, we may either update the details within the claim directly, or cancel the claim and ask you to resubmit with corrected information.
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I’m aware of an individual/organisation who I suspect has submitted ineligible claims and/or have concerns about. How do I notify the PPA?ExpandClose
Individuals wishing to submit a tip-off to the PPA can:
- Contact the Support Centre on 1800 951 285 to discuss their concerns with a member of the team directly
- Email their concerns directly to support@ppaonline.com.au
- Submit their concerns in writing by completing the tip-off form located in the Tip-Offs section of this page.
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Can I provide a tip-off if I wish to remain anonymous?ExpandClose
Yes, you can by leaving the optional name and email fields blank in the tip-off form, available at the Tip-Offs section of this page.
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I have a question that wasn’t addressed here.ExpandClose
Please contact the PPA Support Centre via support@ppaonline.com.au or by telephone on 1800 951 285 and ask to speak to a member of our Compliance Team.