Graduated compliance

HealthShare Victoria (HSV) has a responsibility to monitor and support compliance across Victoria’s health service procurement sector. Our graduated compliance approach promotes tailored and measured responses to compliance issues, focusing on strategies that guide and support health services to do the right thing:

  • Where possible, we encourage the lowest level of intervention for compliance action.
  • Our approach recognises the capacity of health services to become compliant and responds to the behaviour and compliance history of the health service.
  • We promote compliance action proportionate to the level of risk and provide flexibility to escalate or de-escalate compliance action if required.
  • We champion an evidence-based decision making process.

The Graduated Compliance Model and guidelines further outline our approach to compliance. Access the HSV Graduated Compliance Guidelines to learn more.

Health services can access support tools to help them meet required compliance standards.

Our team uses a Graduated Compliance Model to assess compliance issues and decide upon an appropriate course of action. The model supports transparency and consistency, allowing HSV staff members to compare key assessment criteria against instances of non-compliance against the Health Purchasing Policies, or Act.

  • Reflective of our wider approach, the model encourages lower levels of intervention where appropriate.
  • The model determines a clear path of action according to the risk rating, frequency of incidence and compliance stance of the health service.

HSV will inform the health service of its assessment and provide it an opportunity to respond before taking further action. HSV recognises that procedural fairness promotes good governance and a fair decision-making process.

The model

Graduated compliance model graphic

Download an accessible version of the Graduated Compliance model.

The model explained

A range of scenarios and recommended actions are available to complement the recommended compliance responses.

Level 1 - education and support

HSV staff members will work with health services to ensure they achieve compliance. This includes offering tailored advice and support, educational tools, templates and access to online training.

Level 2 – administrative action

Responses under the ‘administrative action’ layer require a little more consideration and will be tailored to the individual circumstances of the non-compliance. Depending on the severity of the compliance issue, HSV may choose to escalate the issue further within the organisation, or ask the health service to provide more information. In more serious cases, HSV may require health services to undergo a spot audit.

Level 3 – HSV direction

In accordance with the Act, HSV has the power to give written directions to one or more public hospitals to ensure that probity is maintained in purchasing, tendering and contracting activities. Health Services must adhere to these directions, provided they are not inconsistent with an existing contract.

Level 4 – report to the minister

While HSV has the legislated responsibility to monitor compliance and report irregularities to the Minister, we will only do this in the most serious of cases. HSV’s response may include referral to investigative government bodies, such as the Independent Broad-based Anti-corruption Commission. In most cases, health services will be given an opportunity to respond before HSV takes further action.


HSV has formal mechanisms in place to investigate complaints from organisations including mandated health services, suppliers and other stakeholders. HSV will manage any complaint submitted in accordance with the Complaints Management Procedure. This document also outlines the process for submitting a complaint.