EmailHospital Circular 24/2006
Date Issued: 30 November 2006
Distribution: Chief Executive Officers; Chief Finance Officers; Chief Medical Officers; HR Directors
Subject: 2006 Public Health Medical Workforce EBA – Guidelines and Process for Reimbursement Funding for Continuing Medical Education (CME) Support and Sabbatical Leave Backfill Premium Costs
Purpose: To outline the guidelines and process that will apply to claims by health services for reimbursement for the relevant costs of CME expenses paid to specialists and also details for claiming of the unavoidable premium cost on backfill for specialists taking approved Sabbatical Leave.
1. Continuing Medical Education (CME) Support
1.1 Specialists’ Entitlements
Clause 2.1 of the Heads of Agreement (HoA) signed by the parties on 28 July 2006 provides that full-time medical specialists directly employed by a health service or hospital is entitled to receive financial support for continuing medical education activities up to a value of $20,000 per financial year (pro-rata for specialists directly employed on a Fractional basis). The $20,000 (or pro-rata amount) is a gross figure inclusive of GST and FBT.
The CME entitlements for specialists are further outlined in a “Model Clause” recently agreed between the parties as a suitable clause for insertion into new Workplace Agreements (Attachment 1). It should be noted that it is not the intention of this clause that the purchase of capital items, or assets that would normally be available through salary packaging arrangements, (eg Notebook PCs) would be reimbursed as a CME cost.
Health services need to ensure that the reimbursements to specialists are consistent with the HoA and model clause, unless there are pre-existing entitlements, which fall outside of the CME reimbursement process. Where pre-existing arrangements are in place that provide benefits of $20,000 pa or more, the Department would not expect any claim to be made by a health service for reimbursement of costs with respect to such employees.
In the case of specialists working at more than one health service, it is important to ensure that aggregate reimbursements relating to CME entitlements do not exceed the annual entitlement of $20,000 (or pro-rata). If health services believe that there is a possibility that the specialist may work at more than one health service, it is recommended that they raise this issue with the specialist.
To assist in this regard, local claims forms for reimbursement to the specialists must include a declaration similar to that shown in Attachment 2 (this example could also be used as a guide for a declaration to be signed by junior doctors claiming their up to $1,000 (pro-rata) per financial year CME entitlement). Additionally, health service/hospital Human Resources Directors are considering adding information about financial year-to-date CME reimbursements to Certificates of Service for doctors transferring between hospitals/health services.
1.2 Australian Taxation Requirements for FBT Purposes
Health services will need to ensure that they comply with the ATO’s requirements under Fringe Benefits Tax legislation. This includes completion of the appropriate FBT declaration and, where required, completion of a travel diary.
In all other aspects, health services will need to establish a reimbursement process and record keeping, which is consistent with the requirements of the Department as a condition of reimbursement. These requirements are detailed later in this Circular.
1.3 Reimbursement by the Department
Health Services will be reimbursed for qualifying CME costs, up to a ceiling of $20,000 per annum for a full time specialist (inclusive of FBT and GST) and pro-rata based on $2,000 per 0.1 FTE for Fractional specialists.
The reimbursement to health services is reduced by the baseline expenditure for CME that hospitals/health services incurred in the 2005/06 year. Where firm data about previously paid entitlements is unavailable, hospitals/health services should make a “best-estimate” of the value of such entitlements based on known information (eg destination and duration of recent conferences attended, etc).
As a matter of priority, health services must establish a baseline of CME expenditure paid to specialists in 2005/06 (or over a longer period where such data is available). This requirement will form part of the claim certification process. Health services must to be able to produce appropriate documentation to verify that they have taken reasonable steps to establish this baseline as it may be subject to audit by the Department.
This baseline is inclusive of payments made to specialists through Trust structures, which in some cases, may be held outside of health service financial records. In the case of Trust structures maintained independently of the hospital/health service, it is sufficient to establish CME expenditure at the aggregate level.
Unless a hospital/health service believes that it will be significantly disadvantaged in relation to cash flow, it is recommended that a claim be forwarded to the Department at six monthly intervals covering the six-month periods to 30 November and 31 May. Reimbursement of expenses for the month of June will be accounted for in the following year. It is unlikely that hospital/health services will incur significant additional expenses for CME until the second half of fiscal 2006/07.
Hospitals/health services will not be required to forward details to the Department of individual reimbursements to specialists as a condition of payment. However from the commencement of financial year 2006/07, hospitals/health services will be required to maintain a record of CME reimbursements, in a prescribed format (Attachment 3), and make these details available for audit by the Department on request.
The summary of claims will also provide a useful summary of expenses associated with CME entitlements, for negotiations in the next round of EBA negotiations.
Hospitals/health services will be entitled to reimbursement in accordance with the claim form. The claim should be reduced by the aggregate baseline CME expenditure for 2005/06 (or a longer period where such data is available), pro-rata for the period of claim.
Example for Claim Prepared to 30 November (July to November 2006 in this first instance):
Total CME expenditure for 5 months to 30 November |
$400,000 |
(a) |
Total CME expenditure baseline for 2005/06 |
$600,000 |
(b) |
Total CME expenditure for 2005/06 pro-rata for 5 months |
$250,000 |
(c) |
Reimbursement due from DHS |
$150,000 |
(d) = (a)-(c) |
1.4 Format of Claims
Claims should be submitted to the Department electronically via Health Connect. An example of the claim format is provided at Attachment 4. Health Services staff who currently submit the monthly F1 returns to the Department through Health Connect will also be able to access the CME electronic claim form.
The claim includes a certification from the Chief Financial Officer or other senior officer.
1.5 CME for Non-specialists
The above funding process is not relevant to the up to $1,000 (pro-rata) per financial year CME entitlements for non-specialists (HMOs, Registrars, etc.) as funding for this entitlement has already been incorporated into health services’ budgets.
2. Sabbatical Leave Backfill Premium
2.1 Undertaking of the Department
Clause 6 of the HoA provides that the Department will provide a level of funding support to hospitals/health services with respect to the unavoidable premium backfill costs associated with the approval of Sabbatical Leave for medical specialists. That agreement was predicated on the basis that all specialists employed in Victorian public hospitals should have reasonable opportunity to access their accrued Sabbatical Leave entitlements, regardless of the size or location of their employing health service, or of the specialty area in which they are engaged.
This undertaking is particularly directed at the smaller health services, but larger health services are not precluded from making a claim.
2.2 Funding Support
Sabbatical Leave is a long-standing entitlement with funding built into base budgets. Backfill costs associated with Sabbatical Leave needs to be met by hospitals/health services from their annual budget allocation.
However, where a hospital/health service cannot backfill the staff member taking Sabbatical Leave with another salaried staff member and needs to backfill using a locum or fee for service contractor, a hospital/health service may apply to the Department for assistance in meeting the difference between backfill at an employed salary rate and backfill at a reasonable locum or fee for service rate.
To ensure that reasonable access to accrued Sabbatical Leave entitlements is available across all locations, the Department has established an ongoing funding pool from which Victorian public hospitals (particularly rural hospitals) will be able to draw. Available funding is limited and will be reviewed on an annual basis.
This funding is not intended to cover the “normal cost” of replacing the specialist on Sabbatical Leave.
2.3 Eligibility to Access Funding Support
The following rules will apply to access to the funding support:
- The Fund will only be available to Victorian public hospitals that directly employee full-time or fractional specialists and are listed in Schedules 1–5 of the Health Services Act 1988 (Vic); and
- The Fund is only available to support backfill of Sabbatical Leave accrued by specialists and approved by the public hospital in strict accordance with the terms of Clause 25 the Hospital Specialists and Medical Administrators Award 2002; and
- The Victorian public hospital must have a genuine medical requirement to provide at least 50% backfill of services delivered in the relevant medical specialty.
2.4 Limit on Support
The following limitations apply to support available:
- An eligible Victorian public hospital can draw on the Fund only in respect of the necessary cost of replacing the specialist(s) embarking on a period of approved Sabbatical Leave of 13 weeks or more; and
- The eligible Victorian public hospital is responsible for backfill at the normal replacement salary cost; and
- Funding support will be generally capped at 200% of the normal cost of providing the medical services for the leave period, subject to an assessment of the merits of each case; and
- Funding support generally will not be considered for the purpose of paying fee-for-service payments to existing employees to provide in-hours backfill cover, especially where such staff are employed on a less than full-time basis.
2.5 Claim Process
Eligible Victorian public hospitals must submit a claim with supporting information no earlier than 8 weeks prior to the intended commencement date of the period of approved Sabbatical Leave and no later than 8 weeks after the leave period has commenced.
2.6 Format of Claims
Claims should be submitted to the Department electronically via Health Connect. An example of the claim format is provided at Attachment 5. Health Services staff who currently submit the monthly F1 returns to the Department through Health Connect will also be able to access the CME electronic claim form.
The claim includes a certification from the Chief Financial Officer or other senior officer.
3. Grant Payments to Health Services
Payment will be processed via the normal grant process and does not require a tax invoice. As with all grants, the payment to the health service will include GST.
4. Further Information
Enquiries about the reimbursement process may be directed to Mr Phil Willmer, Manager Financial Management & Budget Operations (Tel. 9096 8511 or e-mail Phil.Willmer@dhs.vic.gov.au).
Enquiries relating to specialists’ entitlement to reimbursement of CME related expenses should be directed to the Victorian Hospitals’ Industrial Association.
Attachments
Attachment 5 - Claim for Funding Support for Sabbatical Leave Backfill Premium (MS Excel File 14KB)
Lance Wallace
Executive Director
Metropolitan Health & Aged Care Services
