Our graduated compliance model

As part of our legislative function and approach to health service compliance, we have developed a graduated compliance model and guidelines. The model and guidelines apply to all mandated health services and promote tailored and measured responses to compliance issues faced by health services.

We use the graduated compliance model to assess health service compliance issues and to decide on an appropriate course of action. The model supports transparency and consistency and assesses compliance issues against key assessment criteria relating to our HSV Purchasing Policies and the Health Service Act 1988 (Vic). See the Graduated Compliance Guidelines and the HSV Purchasing Policies for further details.

Levels of intervention

The model encourages lower levels of intervention where appropriate and determines a clear path of action according to the risk rating, frequency of incidence and compliance history of a health service.

A range of scenarios and recommended actions are available.

Level 1: education and support

We will work with health services to help them achieve compliance. This includes offering tailored advice and support, educational tools, templates and access to online training.

Level 2: administrative action

Responses under level 2 administrative action require more consideration and will be tailored to the circumstances of the compliance issue. Depending on the severity of the issue, we may choose to escalate the issue within the health service, or ask the health service to provide more information. In more serious cases, we may require health services to undergo a spot audit.

Level 3: HSV direction

In accordance with the Health Services Act, we have the power to give written directions to health services to ensure that probity is maintained within procurement activities. Health services must follow these directions, provided they are not inconsistent with an existing HSV collective agreement.

Level 4: report to the minister

We have the legislated responsibility to monitor compliance and report irregularities to the Victorian Minister for Health. However, we will only do this in the most serious cases. Our response may include referral to investigative government bodies, such as the Independent Broad-based Anti-corruption Commission. In most cases, we will give health services an opportunity to respond before we take further action.

Image caption: A graphical representation of the graduated compliance model

Download an accessible version of our graduated compliance model.

Notification of compliance assessment

We will notify health services of our assessment of their compliance issue and give them an opportunity to respond before we take any further action. We recognise that procedural fairness promotes good governance and a fair decision-making process.

How to lodge a complaint

We have formal mechanisms in place to investigate complaints made about us by organisations. See the Complaints Management Procedure which also outlines the process for submitting a complaint.