eHealth Incentive compliance update - shared databases
The AMA recently sought advice from the Department of Health on the treatment of practices with multiple sites sharing one data base for the eHealth Incentive.
Some of the practices received an ePIP compliance letter advising that they did not upload any shared health summaries during the period 1 May 2016 to 31 January 2017 and were withdrawn from the ePIP incentive.
These practices subsequently wrote to the Department of Health disputing the shared health summary (SHS) upload figures. On investigating these disputes, it became apparent that practices operating under a network and seed arrangement with software that allowed for only one HPI-O were having all shared health summary uploads recorded against only one practice.
The Department of Health has advised it will be responding to all practices that have contacted the Department with the following advice:
- Where the shared health summary uploads of the network organisation meet or exceed the cumulative total of all practices that work under this arrangement all practices will be considered to have met their shared health summary upload requirements.
- Where the shared health summary uploads of the network organisation do not meet the cumulative total of all practices that work under this arrangement the Department will work with those practices to determine how debt will be managed.
- Practices that have been withdrawn are able to reapply at any time or can be manually reinstated if there are problems with the reapplication process.
- Practices that have missed payments as a result of the withdrawal will have all payments made in full.
It is the responsibility of individual practices to advise the Department of their network and seed arrangements, as it is not possible for the Department to have visibility of local database arrangements.
Although there are currently limited solutions to this issue, as only one software vendor provides functionality for more than one HPI-O, the Department will be working with the Department of Human Services and the Australian Digital Health Agency to consider a way forward that does not disadvantage practices.
In the short term, future compliance activity will seek to review those practices that are known to share a database before correspondence is sent, noting that the Department is reliant on information received directly from practices.
Any similarly affected practices are advised to contact the Department of Health at email@example.com