Compliance

The Pharmacy Programs Administrator (PPA) is authorised under its service agreement with the Department of Health (the Department), to undertake monitoring and compliance activities in relation to programs funded under the Sixth Community Pharmacy Agreement (6CPA). 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).

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 6CPA 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.

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).

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).

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 wish to remain anonymous, please note that we will be unable to contact you if there is a need to verify details or request additional information. Additionally, depending on the nature of the issue raised and the level of detail provided, we may not be able to investigate the matter.
If you provide your email address you will receive confirmation that we have received your tip-off and you may be contacted to request additional information.
Please provide as much detailed and specific information as you can, i.e. who, what, when and where.

 

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

  1. The purpose of the PPA and Department’s monitoring, compliance and audit program is to ensure that Service Providers in receipt of 6CPA 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.
  2. 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.

  3. The PPA requests that all documentation be provided within 10 business days from the date of the email notification.

  4. Examples of supporting documentation that the PPA may request include, but are not limited to, the following:

    1. Patient Consent Forms
    2. DAA Packing Reports
    3. Reports from dispensing software programs
    4. Copies of Scripts
    5. RMMR reports
    6. GP referrals
    7. Pharmacist time sheets
    8. QUM Activity logs.
  5. 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.

  6. 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.

  7. 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).
  8. 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 under the 6CPA.

  9. 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.

  10. 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.
  11. 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.

  12. 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.