Welcome to a special issue of our newsletter where we focus on the revised Registration standard: Professional indemnity insurance (PII) arrangements and share some helpful information with you about audit for osteopaths.
The PII arrangements registration standard is the last of the Osteopathy Board of Australia’s (the Board) revised registration standards to come into effect, after the continuing professional development (CPD) and recency of practice (ROP) registration standards that were featured in our last newsletter.
The new PII arrangements registration standard introduces changes that take effect from 1 July 2016. To support you when you next renew your PII arrangements we want to explain well in advance of 1 July 2016 why you may notice changes in the policies provided by insurers.
We are holding a webinar on 5 May 2016 when I will speak to you about the PII arrangements changes and the current audit which has just started. You will also have the opportunity to ask any questions you may have about PII and audit.
Each year the Board and the Australian Health Practitioner Regulation Agency (AHPRA) audit a number of osteopaths as part of our work to protect the public. In this newsletter we want to explain the important ‘behind the scenes’ part of the Board and AHPRA’s work when auditing registered osteopaths.
We discuss why audit is important, how practitioners are selected for audit, tips to help you be compliant and what happens once you are in the audit cycle. We also hear from a practitioner who has recently been audited.
Osteopathy is a small profession, and registered osteopaths are likely to be audited a few times in their professional life. The audit process should be smooth if you keep informed about what to expect, you prepare in advance and make sure you are complying with the registration standards.
As always, we welcome feedback on our newsletter. We are particularly interested in hearing from you if you would like to share your experience of audit from a practitioner perspective. We are planning to use more varied communication methods like webinars, videos and social media to help you obtain information in more accessible and interactive ways.
We hope that all of our efforts to keep you informed are helpful. We would also like to know what topics you would like to hear more about. All you need to do is reply to this emailed newsletter with comments, and we will gratefully receive your feedback for further consideration.
Dr Nikole Grbin
Chair, Osteopathy Board of Australia
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The Board has published the revised PII arrangements registration standard, which will take effect on 1 July 2016. It is important that you are familiar with the revised registration standard and the related fact sheet before 1 July 2016.
The Board has also published an update on the revised PII arrangements registration standard that explains the main changes and when these will come into effect so you continue to meet your obligations as a registered osteopath. Your professional obligations as a registered practitioner include being familiar with the PII arrangements registration standard. Remember – reading about PII counts as a mandatory CPD topic.
Every year when you renew your registration you are asked to make a declaration that you have complied with the PII arrangements registration standard during the previous registration period. Because the registration and insurance policy periods are different, practising osteopaths will often have two PII policies in a single registration period.
For example, when you renew your registration in October/November 2016, the declaration you will be asked to make about PII will cover a period when the previous PII standard was in effect and a period of time when the revised PII standard has been in effect.
The main changes to note are detailed below.
Please read the Board’s revised PII arrangements registration standard and fact sheet for more detail, including an explanation of what insurance terms ‘run-off cover’ and ‘automatic reinstatement’ mean.
The revised PII arrangements registration standard is consistent with some of the other National Boards’ standards, some of which already have no stated minimum level of cover, such as the Physiotherapy Board of Australia.
Various insurers develop PII insurance products for osteopaths registered in Australia, among other health professions. Because the Board no longer requires a minimum level of cover, and due to other changes in the revised registration standard, insurers may make some changes in the cover that they offer in your next PII policy.
The Board and AHPRA are not able to provide advice about the levels of cover to practitioners or discuss your individual policy needs with you.
Information and advice on PII arrangements is available by contacting insurers or insurance brokers who are experts in PII insurance. Professional bodies or associations may be able to discuss certain PII insurance policies with you or provide profession-specific information.
The Board expects that you disclose honestly and fully to your insurer the scope and nature of your practice. A registered health practitioner’s ‘scope of practice’ is defined as: the professional role and services that an individual health practitioner is educated and competent to perform.
The insurer is then best placed to assess the adequate and appropriate level of cover based on your full disclosure of this information to them. For example, information about providing services to certain cohorts of patients (such as elite Olympic athletes, entertainers or children), or undertaking certain techniques (such as needling), or working only in administration, would quite likely be important information to disclose to an insurer.
Your insurer would then assess the appropriate level of cover tailored to your individual scope, nature, risk and domain of practice, or change to practice. You must take out appropriate run-off cover and retroactive cover, as assessed by your insurer after disclosing changes to your practice that will affect your level of cover.
You may be asked for evidence of your PII arrangements during audit or at any other time. Your compliance with the revised PII arrangements registration standard, which is coming into force in 2016, will be audited in 2017. From 1 July 2016 you must retain all documentary evidence of PII insurance for five years.
It is important to keep all evidence of formal interactions with insurers, such as payments, policies and disclosures, for five years, as the Board may occasionally want you to provide more detailed information about your compliance with the PII arrangements registration standard. For example, you should keep printed or online copies made at the time of disclosures or interactions with insurers, or you may need to keep concurrent policies relating to different workplaces. You must keep all records for five years even after you change your employment.
While audits are conducted by AHPRA regularly, many practitioners have not been involved in an audit, and the Board would like to provide information about the audit process so that you can be prepared.
If you are compliant, you do not need to worry unnecessarily about the process. We have many common questions asked about audit and we have listed these for you below.
Each year we audit one or more registration standards. The audit in 2016 is CPD and letters were sent out in March to those osteopaths being audited.
A tip sheet for this year has been produced: Tips to help prepare osteopaths for practitioner audit on continuing professional development (CPD). As other standards are audited in future years messages, tip sheets and common questions will be updated.
Practitioner audits provide a nationally consistent approach to check practitioners’ compliance with the mandatory registration standards, and that the declarations made at renewal are true and correct.
It is also a way to provide reassurance to the Boards, practitioners and the public that registered health practitioners understand and comply with their Board’s mandatory registration standards and obligations under the Health Practitioner Regulation Law, as in force in each state and territory (the National Law).
While most practitioners do comply with the registration standards, audit is the only way that we can obtain evidence to demonstrate that this is the case. Also, audit allows the Board to identify any practitioners who are not compliant and to take appropriate action.
The Board has a set number of practitioners it audits each year. This number is recommended by an independent statistician. The sample size ensures that the results from the audit can be extrapolated across the profession with confidence. Audit does not apply to non-practising osteopaths or students.
If you have previously been audited, including for another profession, you will still be part of the pool of osteopaths from which a number are selected for audit. The selection of practitioners for audit occurs annually, but the time of year can vary.
The Board may audit different combinations of registration standards each year.
When you apply for registration to practise or to renew your registration each year, you make declarations on the application form about whether you comply with the Board’s mandatory registration standards. Audit checks your declarations in relation to the registration standards.
When you are audited, you are required to provide evidence to substantiate your declarations. For example, if you declare you met the CPD registration standard in the previous registration period, you will be asked to provide evidence to show that this declaration is true, i.e. records of your completed CPD.
If you are being audited, you will get a letter from AHPRA. It will include a checklist for providing further information and the details for how to submit copies of your evidence.
AHPRA has a specialised audit assessment teamand if you are selected for audit, they can be contacted on 1300 419 495. When you call, please ask to speak to a member of the audit assessment team.
In most cases you will not be assigned an individual case officer. This will only occur if you supply insufficient or incomplete information, or if you are assessed as not being compliant with the requirements of the standards under audit.
You need to keep records to show you meet the registration standards and it is easiest to keep these records as you go rather than wait for an audit notice letter. You should anticipate that you could be contacted at any time and take steps to collate, routinely update and store records.
For CPD, we suggest you record learning activities as you learn and keep in a safe place your original or scanned CPD attendance records or completion certificates and senior first aid certificates. Review your CPD learning needs and plan and evaluate your CPD activities.
For the Recency of practice registration standard, we suggest you keep employment references or records, and regularly refresh your CV to accurately document your employment history. Talking to your colleagues who have been audited might also help with some tips on how to be ready for audit.
As reported in the April 2015 newsletter, 100 per cent of osteopaths were compliant in 2014 audit; and more recently 98% per cent were compliant in 2015. This is good news for the public and the profession.
From time to time the Board may publish on its website further information that can be used for preparing for audit, such as tip sheets, webinar information and suggested templates
David Yaksich is a registered osteopath based in Western Australia. He took some time out of his busy practice to fill us in on his recent experience of audit.
David has been an osteopath for 30 years, practising from his Bayswater clinic in Perth with his two brothers. They also have practices in South Perth and Lesmurdie.
David received a letter from AHPRA on the 15th May 2015 stating he had been randomly selected to be audited on his criminal history and the CPD and PII registration standard. David recalls that ‘The advice clearly outlined what I was being audited on and the steps I needed to take to supply information to support the statements I made when I renewed my registration the year earlier.’
When asked if he already knew what audit involved he added: ‘I was confident in all but the CPD requirements, as although I had completed the required minimum hours, including the mandatory Board requirements, I was still a little apprehensive that it would be accepted in the format I had used to record my hours. However, I was not surprised to be audited. I knew there was random selection across the profession.’
When a practitioner receives notice that they are to be audited they also received a checklist, David found the checklist very easy to understand and where he needed to ask questions he did so. ‘In relation to CPD compliance I had to gain clarification on exactly what format would be acceptable for my portfolio and what the relevant information required would be.’
During his audit David contacted AHPRA’s audit team to ask questions about the CPD requirements and went to the Board’s webpage for more information. He said, ‘I called the audit team to clarify the CPD requirements and format that would be suitable in lodgement of my documentation. I was wary as I thought that if I asked questions it might affect how I was audited. However, I must say the audit team made me feel comfortable and were very helpful when assisting me.’
‘After speaking with the audit team on several occasions, via email and phone, it was made clear they were supportive and understanding and very helpful, which allayed my fears that they were “out to catch me” for not being compliant. If you have completed the requirement there is absolutely nothing to worry about.’
Commenting on the audit process he said, ‘The deadlines were more than ample and two of the three requirements (criminal history check done by AHPRA) and the supply of my PII certificate were completed almost immediately. The CPD compliance documentation did take some extra time to make sure the format was appropriate.’
He continued, ‘On reflection I can see the value in keeping my records up to date. Being busy in the practice and life in general, updating of my CPD was always left to a later date, which can slip from month to month. However, it is very important. Since my audit last year there has been a lot of information supplied to osteopaths on the requirements for CPD and how best to record it, which has been very helpful.’
David agrees that audit is important for osteopaths and believes that as a profession, osteopathy needs to be audited to make sure obligations are current. He added, ‘We also have a responsibility to the public and our patients to give them confidence in the osteopathic profession as a whole, so that when they visit an osteopath they are confident in the knowledge that all osteopaths have the same minimum standards of registration requirements across Australia, and that we are rigorously audited to maintain these standards.’
When asked if he had any tips or advice for other osteopaths who are currently being audited he said, ‘Yes, first keep your CPD portfolio up to date and in an acceptable format. This is important as it will save you time when you get audited – and be prepared, you will be audited eventually.’
‘Second, the audit team are very helpful and are not out to “catch you out”. They are there to make sure you are compliant. If you keep your requirements current there is absolutely nothing to worry about.’
‘Third, I pay my PII monthly with direct debit so there is no chance of the cover lapsing inadvertently, and this makes it easier for me to get the certificate of currency for the audit requirements.’
‘As a final note, I sent my documents via registered mail person to person – remember, scanned copies emailed are not accepted.’
Visit the audit page for advice on preparing yourself for audit and staying on top of your CPD.
If you still have questions about PII and audit after reading this newsletter, do not worry!
The Board is hosting a free one-hour webinar on preparing for CPD audit and changes to the PII arrangements registration standard. The webinar will give you the opportunity to directly interact with the Board and AHPRA about the PII changes and audit.
The webinar is taking place on 5 May 2016 from 2pm to 3pm AEST.
The first half-hour will be on the important changes to the PII registration standard including question and answer time. The second half-hour will be allocated to the current audit of the CPD registration standard and will also include question and answer time. You can join or leave the webinar at any time.
Dr Nikole Grbin, Chair of the Osteopathy Board of Australia, will host the webinar, and she will be joined by AHPRA staff from the audit and policy team for the Q&A session.
Places are limited, so please register now to secure your place.
You can attend from any location provided you have an internet connection and a computer, tablet or smartphone. You should have already received an email about this event on 12 April 2016, with additional information on how to register and join in.
If you are unable to participate on the day, a record of the webinar will be available on the Board’s website two weeks after the broadcast and we will share this in our next newsletter.
We expect that a vacancy arising on the Osteopathy Board for a practitioner member from a small jurisdiction (Tasmania or the ACT or the NT) will be advertised in May in the national and relevant metropolitan newspapers.
All National Board appointments are made by the Australian Health Workforce Ministerial Council. If you are interested, please monitor the National Boards recruitment page on AHPRA’s website. More information will be available on the website as soon as the vacancy is advertised.
The Board has published an individual profession profile on its website. Keep an eye out for other profession profiles on the other Board websites and AHPRA’s website.
State and territory summaries of the annual report are also now available on the AHPRA website. The summaries provide a view of national data about our work to keep the public safe through a state or territory lens. We provide national comparisons to show how the state or territory compares with the national average and where possible, we provide two years of data, to identify and track trends over time.
More comprehensive data are in the 2014/15 annual report of AHPRA and the National Boards which was published in November 2015. The annual report also includes more detailed profession-specific information.