New laws make vaccination reporting mandatory

Morgan Liotta

5/02/2021 4:14:26 PM

With the COVID vaccine rollout only weeks away, newly passed legislation means GPs will soon have to report all administered vaccines to the AIR or face a potential fine of more than $6000.

Vaccine vial in front of an Australian flag
The RACGP largely supported the Bill, but also raised some concerns.

From 1 March, all vaccine providers will be required to report influenza vaccinations to the Australian Immunisation Register (AIR), with all other National Immunisation Program vaccinations to be reported on from 1 July.
Reporting of all COVID-19 vaccinations will also be mandatory once the rollout commences in Australia – ensuring top-level public health measures are covered.
RACGP President Dr Karen Price told newsGP the new legislation will help strengthen Australia’s public health position.
‘We welcome the changes to better enable close monitoring and a reliable dataset of vaccine administration – particularly the COVID-19 vaccine – and strengthen nationwide vaccine coverage,’ she said.
‘GPs have a central role as vaccine providers. They are well placed to support patients in ensuring their immunisations are up-to-date, as well as alleviate any hesitancy in receiving vaccines.’
The Australian Immunisation Register Amendment (Reporting) Bill 2020 was tabled late last year to amend reporting advice, which previously recommended that vaccine providers only have a discretionary duty to report any vaccinations they administer.
The RACGP largely supported the Bill in its 2020 submission, but also raised some concerns – particularly regarding the proposed punitive measures related to increasing reporting rates.
According to the college, the potential for non-compliant providers to receive a $6660 penalty could have a negative impact on patient access to immunisations.
Although broadly supportive of the changes, Dr Price is disappointed the punitive measures were not replaced with a more positive approach to compliance.
‘The college advocated strongly for members an amendment to this proposal, but it was not adopted,’ Dr Price said.
‘There needs to be greater appreciation of the practice and work environments to build professional trust between Government and the general practice sector.  
‘We understand education and support are provided to those vaccine providers who don’t report in the first instance, and civil penalties will only be applied as a last resort, but we would have preferred some incentives to help increase compliance as well.’
In its initial submission, the RACGP highlighted that compliance measures should focus on identifying the reason for under-reporting and finding solutions to improve reporting levels through support strategies to vaccine providers.
Federal Health Minister Greg Hunt welcomed the legislation’s passage through Parliament, saying it will reinforce Australia’s vaccination system and ensure all ‘life-saving’ vaccinations are recorded on the AIR.
‘[This] will mean health authorities can avoid unnecessary re-vaccination and let individuals and their vaccination providers know which vaccines a person has had and when they are overdue,’ Minister Hunt said.
‘The changes will mean more comprehensive reporting of vaccinations, which over time will help increase vaccination coverage rates and the effectiveness of Australia’s world-leading vaccination programs.’

Minister Hunt told Parliament last year that fines will only be imposed as a last resort and that education is the first option, a point that was reinforced during the Bill’s third reading.
‘It is conceivable that vaccination providers who have failed to report a single vaccination event and are otherwise compliant with legislation are likely to have experienced isolated issues. In such circumstances, education and support will be provided in the first instance,’ he said.
‘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.’
In addition to opposing the potential sanctions, the RACGP submission made recommendations to ensure patient access to immunisations is not negatively affected, nor that the legislation would compromise privacy or place undue financial burdens on providers.
It also underlined the support GPs need to meet the mandatory reporting requirements, given their central position in spearheading the administration of the new COVID-19 vaccine and allaying any concerns about the safety and efficacy of the vaccine.
Among the several recommendations was that the Government provide a full and detailed privacy disclosure statement and consent form, with adequate guidance for GPs to provide to their patients.
Patients should also be able to opt out of reporting their personal information to the AIR, the RACGP recommended, and a second-line option should be available for general practices to report de-identified information where a patient does not provide their consent.
In response to this recommendation, the Government confirmed that vaccination will remain voluntary, and patient data will continue to have stringent privacy measures in place.
‘There are existing and strong provisions under the AIR Act that provide individuals with control over their personal information,’ Minister Hunt said.

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Dr Alan Graham MacKenzie   6/02/2021 10:01:58 AM

Does it apply to Pharmacists and Workplace group immunisations?

Dr Peter James Strickland   6/02/2021 11:48:07 AM

Once there are punitive measures on GPs, then be suspicious. This is outside normal democratic processes. The PATIENT should report their vaccination to AIR, and not leave it up to GPs to do the work of the regulators here, and the RACGP should have been more pro-active here. Otherwise, get the AIR staff to do the administration, and contact and visit every vaccination site in Australia themselves, and that failures on their part be scrutinised and punished by censures, pay cuts, redundancies etc --it is their job to acquire and evaluate data. GP surgeries should only have lists of those vaccinated, and AIR now go out and get the data, AND ensuring privacy is preserved for patients everywhere ---that is their responsibility, and what they are paid for!

Dr Michael Lucas Bailey   6/02/2021 12:34:14 PM

Just a disincentive for GPs to do immunisations, which we will still mostly do anyway.

How many level A rebate COVID19 vaccinations does it take to cover the fine from failing to report one of them? What other industry would
accept that financial risk?

Dr Janice Faye Sheringham   6/02/2021 12:41:41 PM

How on earth did this regulation receive legal approval? Has no-one considered the ramifications for doctors providing healthcare to immigrant families, returning travellers and all the other situations where immunisations may be given and not forwarded to AIR? Utter madness! Yes of course every Australian-approved immuniser should be held accountable for ensuring their record-keeping and AIR data transfers are accurate and up to date, but penalising another provided for incomplete data entry by another? Only ones to penalise are those who do not meet their legal requirements in this country! Ensuring data accuracy from international sources is difficult, slow and time-consuming as all who have attempted this for immigration medical care will testify! This impost is WRONG, WRONG, WRONG!!!!!

Dr Alireza Eskandaripour   6/02/2021 5:38:59 PM

In our practice it is the nurse who registers the vaccination so if nurse forgets to add one I will have to pay the penalty ?

Maybe I need to reconsider my interest in doing the COVID vaccination so the ones who set this penalty can do the vaccination themselves !!!

Dr Marc Houghton Heyning   6/02/2021 6:29:06 PM

I agree with the comment above - there are other vaccinators in our health system who do not notify the AIR with the biggest offender being the state-run-hospital system. I work in both private practice and at the local public hospital - I do not even know how to notify the AIR that an immunisation occurred for a patient in either the in-patient or outpatient environment. (eg influenza and pertussis vaccinations administered to pregnant women in antenatal clinics).

In my other role as a GP, the software makes it easy and essentially automatic for the AIR to be notified with every vaccination

With the first roll out of Covid vaccinations being through hospital hubs starting soon, I have yet to hear how the hospital system is going to notify the AIR of each vaccination dose. As far as I am aware, NSW's Powerchart software does not even have a mechanism to upload information to the AIR .

Dr D   7/02/2021 2:03:16 PM

What is the fine for pharmacies not reporting? How will they be monitored?

Dr Primo Phillip Bentivegna   8/02/2021 12:47:59 AM

Nanny state.
Do these fines also relate to pharmacists?