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Government to push ahead with mandatory vaccination reporting Bill


Matt Woodley


4/12/2020 4:07:25 PM

Should the changes pass, providers will face a $6660 penalty for not reporting newly administered vaccines to the Australian Immunisation Register.

Person holding a vaccine syringe
Currently, the recording of vaccinations on the Australian Immunisation Register is encouraged, not mandatory.

The proposed amendment, tabled in Parliament earlier this week by Federal Health Minister Greg Hunt, would compel GPs and other vaccine providers to report all newly administered vaccines to the Australian Immunisation Register (AIR).
 
Currently, the recording of vaccinations on the AIR is encouraged, rather than mandatory, which has resulted in vast under-reporting from some sectors and been identified as an area of ‘great concern’ by the RACGP.
 
A public submission signed by former Acting RACGP President Associate Professor Ayman Shenouda was broadly supportive of the amendments, but did express concerns regarding punitive compliance measures, such as fines, aimed at increasing reporting rates.
 
‘There are many reasons which may impact on a GP’s ability to report a vaccine to [the] AIR; temporary technological failure or limitations, lack of consent from the patient, or workforce shortages,’ Associate Professor Shenouda wrote.
 
‘GPs and general practices must not be penalised or prevented from providing future vaccines under these circumstances.
 
‘Instead, the focus should be on identifying the reason for under-reporting and finding solutions to improve reporting levels.’
 
However, despite these reservations, the changes – which have bipartisan support – include provisions for a civil penalty of ‘30 penalty units’ (equivalent to $6660) should the provider not report ‘within the period prescribed by the rules and in the manner prescribed by the rules’.
 
Upon tabling the Bill in Parliament, Minister Hunt said the proposed changes will ensure Australians can access their vaccine history through the ‘safe and secure’ AIR.
 
‘The need for the Australian Immunisation Register Amendment (Reporting) Bill 2020 arose from the need to provide Australians with information about their immunisation history, to support the rollout of a COVID-19 vaccine and the ongoing administration of the NIP [National Immunisation Program],’ he said.
 
‘There is currently no statutory mechanism by which the Government can require vaccination providers to report all vaccines administered. Without such a mechanism on which to rely, the Government will be unable to enforce the mandatory reporting of COVID-19 vaccines administered, once a vaccine becomes available for clinical use.
 
‘The amendments in the Bill will support Australians’ health and wellbeing by improving reporting to the AIR to better inform vaccine projections, purchasing, delivery and program performance, and analyses of vaccine effectiveness and safety, which will be particularly important for the COVID-19 vaccines.
 
‘The details of the reporting obligations, including who is obliged to report and what information is to be reported in what time frames, will be prescribed in the Australian Immunisation Register rules to be made under this Bill.’
 
Minister Hunt also indicated that civil penalties will likely only be pursued as a last resort when trying to tackle non-compliance.
 
‘It is conceivable that the vaccination providers who have failed to report a single vaccination event and are otherwise compliant with legislation are likely to have experienced isolated issues,’ he said.
 
‘In such circumstances education and support will be provided in the first instance.
 
‘For those vaccination providers not reporting any vaccines to the AIR and who do not undertake behavioural change even after education and support is provided, more serious compliance action, such as a civil penalty, could be considered.’
 
He also stated that the Department of Health is working with Services Australia and the Australian Digital Health Agency on system enhancements designed to ensure providers are able to ‘easily meet’ their obligations under the new arrangements.
 
Associate Professor Shenouda had previously expressed concerns about adding to GP workloads and called for more funding to support the implementation of the proposed changes.
 
‘GPs will need time to discuss these issues with their patients, and obtain consent, prior to uploading any information to AIR,’ he said.
 
‘This presents an additional cost that will need to be supported by Government. It cannot be absorbed by general practice.’
 
It has not yet been announced whether any additional funding will be forthcoming.
 
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Dr Mai Huynh Thi Tran   8/12/2020 7:43:00 AM

I strongly oppose this penalty to GP . GP should not be fined $6600 for administrative errors. GP have enough burdens on clinical matters. Please do not put more stress to GP’s. Let us focus on patients’ care.
What do we do to block this change?


Dr Mai Huynh Thi Tran   8/12/2020 7:47:54 AM

GP’s should not be penalised for such a administrative matter. It is ridiculous


Dr Daniel Thomas Byrne   8/12/2020 8:08:29 AM

Irony is that the biggest systemic offender (at least in SA) is our public health system. The thousands of immunisations given in ED each year are never uploaded to the AIR.
Does the bill cover State governments?


Juno   8/12/2020 8:52:00 AM

Data collection of private health information continues unabated. Clearly this is the new normal where there is no presumption of privacy in regard to doctor patient prescribing or immunisation in terms of the state. What next, a social credit system where our presumed rights are conditional on complying with government mandates. This leads down the path of coercion through implicit intimidation and ultimately reducing individual autonomy. The medical profession owes much of our income to the state but this does not mean we are obligated to comply where there is erosion of ethical principles. Politicians will always seek more power and this willingness to seeks damages against GP’s who by accident or design don’t hand over this information indicates our diminishing ability to be regarded as independent of the state.


Dr Gregory Alan Wyatt   8/12/2020 9:02:28 AM

I fully support mandatory reporting of all vaccines to AIR - we report weekly from our software. However, this link is one way - we receive no acknowledgement from AIR that this report has been received or if any are rejected. We have to chase this up via HPOS and who has the time to do that. Not infrequently we get a call from a parent, "Medicare says little Johnny did not get his 18 month immunisation and you gave it." A search shows that it was reported but the system failed somewhere outside our control. Some money needs to be spent on real time acknowledgement! Heavy fines are not the answer.


Dr Elizabeth Lee Clark   8/12/2020 10:41:46 AM

Using a carrot approach ie offering an immunisation payment as was previously available would work. This is an important task that should be encouraged.


Dr Michael Lucas Bailey   8/12/2020 12:31:13 PM

If this penalty comes in it makes no sense for GPs to vaccinate anyone. While encouragement to report on the AIR is good the penalty is excessive. A GP flu clinic would need to successfully vaccinate 275 bulk billed patients to cover the penalty. Immunisation recording would needs to be better than 99.6% accurate to justify the fiscal risk.


Dr Christopher A. Harrison   8/12/2020 11:42:56 PM

I fully support this move. Quite frankly GPs /our Nurses work hard at notifying/uploading AIR data and take pride in our ability ...it is other providers eg pharmacy , health department/ED, infant immunisers ,corporates who decline/lack skill or $ to notify. Stick is needed.


Dr Siva Kumar Raju Muppala   11/12/2020 6:24:23 PM

Please make communication easy between providers and AIR. As some doctors suggested we send details of vaccinations to AIR but don’t receive acknowledgment from them.GPs can challenge punitive measures without proper structure. I hope governments act responsibly.


Dr Irandani Anandi Ranasinghe-Markus   15/12/2020 8:25:39 AM

As a colleague has mentioned above, an incentive for doing something will be a more positive approach than a fine for not doing it! Give incentives to practices to build the notification to AIR into their software so that as the immunisation is recorded, it is automatically sent to the AIR. Another example of enabling systems to communicate with each other that avoids the need for extra time, energy and resources being spent on doing it later. Also, don’t just target GPs - all immunisation providers (hospitals, pharmacies etc) must do the same!!


Dr Urmila Sriskanda   7/02/2021 11:16:07 PM

Sounds like this will apply to all adult as well as children's vaccines .