How HSV assesses health service compliance with the Purchasing Policies

Under the Health Services Act, HSV is responsible for monitoring whether health services are following the HSV Purchasing Policies and directions, and reports any issues to the Minister for Health.

If we identify a breach or non-compliance, we may:

  • ask the health service’s Chief Executive to carry out an audit and share the results
  • request information or data about how goods and services are purchased, managed or disposed of
  • report the issue to the HSV Board, the Department of Health, or the Minister for Health.

We consider each situation carefully and follow our Compliance Framework guidelines when deciding what action to take.

Wherever possible, we work with the health service to resolve issues before escalating them.

HSV's Compliance Framework

The Compliance Framework is a set of structured guidelines and practices that:

  • encourages low level intervention for compliance issues
  • considers a health service’s capacity to comply
  • considers a health service’s behaviour and compliance history
  • promotes actions in proportion with the assessed level of risk
  • provides flexibility to escalate or de-escalate issues as required
  • promotes evidence-based decision making.

The Framework has three pillars, including:

  1. Support and prevention
  2. Compliance monitoring
  3. Compliance priorities

Compliance Framework guidelines

Read detailed information on HSV's Compliance Framework and guidelines for health services in the HealthShare Victoria Compliance Framework guidelines document.

Graduated compliance model

HSV's Compliance Framework is underpinned by a progressive approach to addressing situations where health services have not complied with HSV's Purchasing Policies, referred to as the graduated compliance model.

The model is transparent and promotes tailored, measured and consistent responses to compliance issues faced by health services.

If a health service fails to comply with the Purchasing Policies, we will assess the circumstances against a set of criteria and then use the graduated model to decide on an appropriate course of action.

The model provides a range of scenarios and responses and encourages lower levels of intervention where appropriate.

The model outlines a clear path of action for HSV to take based on:

  • the level of risk assigned to the situation (risk rating)
  • the health service’s history of compliance with the Purchasing Policies
  • the frequency of a health services failure to comply.

Graduated compliance guidelines

Read detailed information on our graduated compliance model and guidelines for health services in the HealthShare Victoria graduated compliance guidelines document.

 

 

Content reviewed: August 2026