• COVID-19: Vaccinations: FAQs

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  • COVID-19 Vaccinations: General FAQs


    • Yes.

      The Australian Technical Advisory Group on Immunisation (ATAGI) statement on revised recommendations on the use of the COVID-19 AstraZeneca vaccine in response to new vaccine safety concerns (dated 18 June 2021) states that the Pfizer vaccine is preferred over the AstraZeneca vaccine for adults under the age of 60.

      However, ATAGI have also issued subsequent statements about the use of COVID-19 vaccines in an outbreak setting and the NSW outbreak in July 2021. These statements provide additional guidance on the benefits, risks and vaccine brand availability when outbreaks are occurring.

        The AstraZeneca vaccine can be used in adults under 60 where:
      • The benefits are likely to outweigh the risks for that individual.
      • The person has made an informed decision based on an understanding of the risks and benefits.
      • You have informed the person of signs and symptoms for which they should seek urgent medical care.
       
        When considering the risks and benefits of administering the AstraZeneca vaccine, you and your patients should consider the:
      • prevalence and potential prevalence of COVID-19 in the community
      • benefits of the vaccine in reducing the risk of death or severe disease
      • risks associated with the AstraZeneca vaccine, including that it appears to be causally linked with a risk of thrombosis with thrombocytopaenia syndrome (TTS)
      • risk of developing TTS is remote:
        • studies suggest that it may occur in approximately four to six people in every one million people in the four to 20 days after the first dose of vaccine
        • higher rates have been reported in Germany and some Scandinavian countries
         
      • availability and accessibility of alternative vaccines
      • vulnerability of specific groups, including those with significant medical conditions.
       

      Any discussion surrounding the risks and benefits of any medical management, including COVID-19 vaccination, should be documented in each patient’s medical record.

        You should also:
      • Provide the patient with the Department of Health’s Consent form for COVID-19 vaccination.
      • Inform the patient of the possible signs and symptoms of TTS and provide them with the Department of Health’s Patient information sheet on AstraZeneca COVID-19 vaccine and TTS.
      • Explain how to seek immediate medical care for signs and symptoms that could potentially be caused by TTS.
      • Provide patients with the Australian Government’s factsheet "After your COVID-19 AstraZeneca vaccination."
       

      You may also wish to view the Avant FAQs about indemnity cover for providing COVID-19 vaccinations.


    • On 17 June 2021, ATAGI have stated that the Pfizer vaccine is the preferred vaccine for people aged 16 to 59.

        However, the ATAGI recommendations also state the AstraZeneca vaccine can be given to people aged 16 to 59 when the:
      • Pfizer vaccine is not available
      • benefits to the patient are likely to outweigh the risks for that patient
      • patient is prepared to accept the risks and has made an informed decision based on understanding the risks and benefits.
       

      You should discuss with your patient what the options are for vaccination and the relative benefits and risks of those options, relevant to the patient’s individual circumstances.

      You should also consider the ATAGI statements about the use of COVID-19 vaccines in an outbreak setting and the NSW outbreak in July 2021. These statements give additional guidance in relation to the benefits, risks and vaccine brand availability when outbreaks are occurring.

      Your discussion should include the risks of thrombosis with thrombocytopaenia syndrome (TTS).

      You may also wish to explain to your patient that you cannot give them definitive advice on when Pfizer (or Moderna) will be available to them, as well as what the prevalence of COVID-19 will be in the future.

        If your patient proceeds with the vaccination, you should:
      • document their consent
      • advise them of the signs and symptoms of TTS for which they should seek immediate medical attention.
       
       

      You should document all discussions in your records.


    • The answer to this question is complex.

      Your practice may decide that it will have a policy of not offering the AstraZeneca vaccine to patients under the age of 60. This policy will need to be clearly documented and communicated to patients.

        You may decide not to offer the AstraZeneca vaccine to individual patients under the age of 60, based on their particular circumstances and given the ATAGI statement on revised recommendations on the use of the COVID-19 AstraZeneca vaccine (dated 17 June 2021) which states that:
      • The Pfizer vaccine is preferred over the AstraZeneca vaccine for adults under the age of 60.
      • The AstraZeneca vaccine can be used in adults under 60 where:
        • the benefits are likely to outweigh the risks for that individual
        • the person has made an informed decision based on an understanding of the risks and benefits
        • the person has been informed of the post-vaccination signs and symptoms for which they should seek immediate medical care.
        When considering risks and benefits, you and your patients should consider the:
      • prevalence and potential prevalence of COVID-19 in the community
      • risks of the vaccine, including that AstraZeneca appears to be causally linked with a risk of thrombosis with thrombocytopaenia syndrome (TTS)
      • risk of developing TTS is remote:
      • studies suggest that TTS may occur in approximately four to six people in every one million people in the four to 20 days after the first dose of vaccine
      • higher rates of TTS have been reported in Germany and some Scandinavian countries
      • availability and accessibility of alternative vaccines
      • vulnerability of specific groups, including those with significant medical conditions.

      Any discussion surrounding the risks and benefits of any medical management, including COVID-19 vaccination, should be documented in each patient’s medical record.

      You should also consider the ATAGI statements about the use of COVID-19 vaccines in an outbreak setting and the NSW outbreak in July 2021. These statements give additional guidance in relation to the benefits, risks and vaccine brand availability when outbreaks are occurring.

      The Australian Government Department of Health recommends that when you advise patients, including about the risk of TTS, you include the information in the Department of Health’s Consent form for COVID-19 vaccination and Patient Information Sheet on AstraZeneca COVID-19 vaccine and TTS.

      You will need to have mechanisms in place to refer patients under the age of 60 who would still like to receive the AstraZeneca vaccine.

      For example, you could direct them to the Vaccine Eligibility Checker. If they are eligible to receive the vaccine, it will take them to the Vaccine Clinic Finder where they may be able to locate a clinic that will assist them. The Department of Health has also advised it will provide further information about access to the Pfizer vaccine as an alternative for these patients.

      You may also direct them to state/territory vaccination services.


    • It has been widely reported that with the current strain(s) of COVID-19, the AstraZeneca vaccine has minimal efficacy after the first dose, and that the efficacy after the second dose is reduced if the interval between doses is shortened from the recommended 12 weeks.

        For members and patients in areas with a COVID outbreak (such as Greater Sydney):
      • ATAGI issued recommendations on 13 July 2021:
        • Where the Pfizer vaccine is not immediately available, patients should re-assess the benefits of being vaccinated with the AstraZeneca vaccine, versus the rare risk of a serious side effect.
        • In outbreak situations, an interval between doses of four to eight weeks is preferred.
      • In the early stages of this recommendation, it is anticipated that supply of the vaccine may be difficult for some GPs to obtain to be able to offer early second doses.
      • Patients can still elect to receive their second dose at 12 weeks. Discussions with these patients should include informing them that this is contrary to what ATAGI states is preferred and that they may have no protection until they receive their second dose.
        For members and patients in non-outbreak settings:
      • The ATAGI recommendations on 13 July 2021 continue to state the preferred interval between doses is 12 weeks.
      • You and your patients may choose to shorten the interval between doses. Individual patients will attach different significance to risks and benefits, particularly where there is much uncertainty. Discussions with your patients about whether or not to shorten the interval should cover:
        • the benefit of some early level of protection, if the interval is shortened, along with the risk of a lower level of ongoing protection (possibly until a third dose is available).
        • the risk of having minimal or no protection until after the second dose, if the interval is kept at 12 weeks, along with the benefit of a higher level of ongoing protection.
      • Other variables include the local prevalence of COVID-19 in your area now or in the future, the availability of doses (particularly if the interval is shortened) and the possibility of a third/booster dose being available in the future.

    • ATAGI has recommended a seven-day interval between the COVID-19 vaccine and other vaccines such as the FluVax.

      A shorter interval is acceptable in certain circumstances, including when there is increased risk of COVID-19 during an outbreak.

      For more information see ATAGI’s advice on seasonal influenza vaccines and COVID-19 vaccines in 2021.


    • To check whether a patient is eligible for a COVID-19 vaccination, you can use the Australian Government’s COVID-19 Vaccine Eligibility Checker.

      Please note that some states are offering the vaccine to other groups, including adults aged under 50. Check the appropriate health department website in your state for details.


    • No. At present, you should not administer a different brand of vaccine for the second dose.


    • Some key points:

      1. 1. You should not provide any certificate unless you form the clinical opinion that it is appropriate.
      2. 2. Specific forms must be issued in some circumstances. They set out the criteria for when an exemption may be granted. For example:
        1. a. entry into the Australian Immunisation Register (Australian Immunisation Register (AIR) - immunisation medical exemption form (IM011) - Services Australia)
        2. b. NSW Government: COVID-19 Vaccine Medical Contraindication
      3. 3. Be aware that the states and territories may also introduce other specific requirements.

      In order to assess whether it is clinically appropriate to provide a medical certificate granting a COVID-19 vaccination exemption, we suggest you take the following steps.

      Step 1: Take a patient history

      You should first take the patient’s history, including the patient’s reasons for the request and the context in which they wish to use the certificate.

      Step 2: Determine whether it clinically appropriate to provide a certificate

      In determining if it is clinically appropriate to provide a certificate, you should have regard to:

      In addition, you should take into account:

      • the nature of the request – a belief that vaccines are not necessary or harmful is not a reason to provide an exemption certificate.
      • whether the patient is asking you to be untruthful.
      • whether a specific form is required for the exemption.

      Please note that it may be helpful for you to use a specific exemption form even if the form is not strictly required.  It gives you and the patient clear guidance about clinical contraindications for vaccination and may be helpful in your discussions with the patient.

      In practice, there are very limited circumstances where a patient would have a contraindication to every type of vaccine that may be available.

      Step 3: Discuss the issues surrounding COVID-19 vaccines with your patient

      • If your patient wishes to discuss information they have obtained from sources that you believe are not credible, you may wish to discuss that information with them.
      • If it is clear their views are fixed, you can advise them that you will only be guided by information provided from credible sources, including the departments of health, ATAGI, TGA and specialist colleges.
      • You may choose to advise them that you cannot meet their request and terminate the consultation.

      Would you like further information?


    • Unfortunately, the answer to this question is complex.

      To help you navigate this issue and minimise the chances of running into a legal problem, we suggest you consider the following issues before you refuse to treat an unvaccinated patient.

      Step 1: Check public health directions in your state and territory

      State and territory public health directions do not currently prevent a person from entering a medical practice if the person is not vaccinated against COVID-19. 

      Step 2: Obligation to treat a patient

      As general rule, a doctor does not have to treat a patient (even in an emergency) if there is a risk to the doctor’s health and safety or the health and safety of other patients under the doctor’s care (see clause 3.5 of Good medical practice: a code of conduct for doctors in Australia).

      In NSW, the situation is slightly different because under the Health Practitioner National Law (NSW) it is unsatisfactory professional conduct to refuse or fail to attend a person in need of urgent attention when requested to do so. The exception is when the practitioner has taken all reasonable steps to ensure that another medical practitioner attends instead within a reasonable time.

      Step 3: Consider whether not treating a patient could be discrimination

      You can refuse to treat an unvaccinated patient except when the patient is unvaccinated for a reason such as:

      • the patient’s medical condition(s)
      • the patient’s age (for example, because the TGA has not approved vaccination for their age group)
      • the patient’s religious beliefs.

      Even then, it can be lawful to discriminate to protect the health and safety of people in the practice.

      In order to minimise the risk of a complaint, you should consider whether there is another way that the medical service can be provided to the patient (for example, via telehealth or in a part of the practice that other patients and staff cannot access).

      Step 4: Consider work health and safety issues

      Under the Medical Board’s code of conduct (see clause 3.4.5 of Good medical practice: a code of conduct for doctors in Australia), as a doctor, you have an obligation to keep yourself and your staff safe when caring for patients: “If a patient poses a risk to your health and safety, or that of your staff, take action to protect against that risk. Such a patient should not be denied care if reasonable steps can be taken to keep you and your staff safe.”

      You also have obligations as a worker under work health and safety laws to ensure the health and safety of those at the practice.

      The law says that you must undertake a risk assessment in consultation with the practice and practice staff to work out the risks associated with managing unvaccinated patients and what measures should be put in place to minimise or eliminate those risks. You can consider the following matters in undertaking your risk assessment:

      • advice from state and federal health departments
      • advice from work health and safety bodies
      • your practice’s policy on patient COVID-19 vaccination
      • rate of community transmission in your location and the patient’s location
      • risk of transmission in your practice, having regard to the specific features of your practice
      • nature of the services provided
      • consequences of refusing access to the medical service
      • type of people who use the medical service and whether there is a heightened risk they will suffer severe symptoms if they contract COVID-19 (for example, people over 60 or people with pre-existing health conditions)
      • whether the business could put alternative measures in place to protect staff and patients (for example, telehealth appointments or seeing the patient outside the physical practice)
      • how long people generally stay inside the medical practice when receiving medical services.
      • whether it is possible to socially distance in the practice
      • availability of COVID-19 vaccinations.


      Step 5: Other factors

      A patient might still make a complaint even if you are not discriminating against the patient and you have determined that you can only treat vaccinated patients for health and safety reasons.

      Some things you can consider to minimise this risk include:

      • you may choose to treat a patient who is partially vaccinated or who has an appointment to be vaccinated in the near future
      • you may choose to treat unvaccinated existing patients with a known history of compliance with safety rules but not new patients
      • you may choose to terminate the doctor patient relationship with patients who become aggressive in response to requirements about vaccination
      • you should consider the capacity of the patient to obtain treatment elsewhere (for example, denying treatment at a small country GP practice, as opposed to a city practice)
      • the patient’s need for continuity of care (having regard to factors such as the urgency of care, the value of an ongoing treating relationship etc).

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    COVID-19 Vaccinations: Consent


    • Consent is more than signing a form. Rather, it is an ongoing process.

      Fundamental to the consent process is the discussion you have with your patient..

      What is a consent discussion?

      A consent discussion should be a shared decision-making process, which aims to understand the patient’s particular situation and concerns, and clarifies their expectations.

      You need to give the patient context to understand the potential outcomes (positive, negative or neutral) and what it might mean for them. A patient will give consent to receiving the COVID-19 vaccine on that basis.

      Consider the following issues

      Capacity
      • Does your patient have capacity?
      • Patients over the age of 18 (16 years in South Australia) are presumed to have decision-making capacity.
      • If you have any concerns about their capacity, ask the following questions:
        • Are they able to make this decision for themselves?
        • Do they understand the information and consequences relevant to the decision?
        • Can they retain the information and recall the details?
        • Can they weigh up the information throughout the decision-making process?
        • Can they communicate their decision and understanding?
      Voluntariness
      • Is your patient making this decision voluntarily?
      • Are they making the decision freely?

      Information
      • Does your patient have sufficient information so they can make an informed decision about whether or not to have the COVID-19 vaccination?
      • You need to tailor this information to the patient’s specific needs.


    • The Department of Health has confirmed that health professionals are authorised to deliver the vaccine in line with federal and state/territory legislation and requirements (see below as to training requirements).

      As a result, the health professional who provides the vaccination can obtain consent from the patient.

      It is important to remember that consent is a process, not a form. It is always necessary to ensure the information provided meets the principles stated above.

      A doctor can delegate the consent process to an appropriately trained nurse or other authorised healthcare worker. However, under Medicare requirements, the doctor retains responsibility for the administration of the vaccine, and this includes ensuring the consent process is being undertaken appropriately.

      For questions about Medicare billing see further below.


    • There is no legal requirement to use a written consent form for the COVID-19 vaccination. However, your practice or hospital may have a policy that requires a written consent form.

      If you wish to use a written consent form, you can modify an existing vaccine consent form or use the template form that has been developed by the Australian Government Department of Health (Department of Health).

      If you do not use a written consent form, you should document the consent in the patient’s medical records, as well as the fact you had a consent discussion. It is also good practice to record that you gave an information sheet to the patient. You should also document in the records if a patient declines to have the vaccine.


    • If you are using a consent form, it is preferable to have an original form signed by the patient.

      This will enable you to verify that the form was signed on a particular date and provides evidence that the patient consented to be vaccinated.

      However, under Australian law, it is permissible for a patient to sign a consent form electronically. You should ensure you have a record that consent was obtained.



    • The Department of Health has developed information that includes clinical guidance to enable GPs to have informed discussions with their patients, as well as information sheets for patients.

      Practitioners should read the Department of Health’s information carefully and ensure they provide information to patients as outlined in the Department of Health’s material.

      Please note that if your patient was not informed of the risk of TTS when they received the first dose of the AstraZeneca vaccine (prior to 8 April 2021), you should obtain a new consent after they have been informed of the risk.


    • RANZCOG and ATAGI recommend that pregnant women are routinely offered the Pfizer vaccine at any stage of pregnancy. They also advise that the Pfizer vaccine is not thought to be a risk to the breastfeeding infant.

      Ultimately, the decision about vaccination rests with the woman based on the available information and their personal circumstances.


    • The Pfizer vaccine is provisionally approved by the Therapeutic Goods Administration for administration to children from the age of 12.

      From 9 August 2021, ATAGI and the Department of Health have approved the administration of Pfizer to children aged 12 to 15 years:

      • with specified medical conditions that increase their risk of severe COVID-19, including severe asthma, diabetes, obesity, cardiac and circulatory congenital anomalies, neuro developmental disorders, epilepsy, immuno-compromised and trisomy 21
      • Aboriginal and Torres Strait Islander children
      • all children aged 12–15 years in remote communities.

      The AstraZeneca COVID-19 vaccine is provisionally approved to be given to people 18 years and older. For more information, please refer to our factsheet on Children and consent.


    • It is mandatory for healthcare providers who administer the COVID-19 vaccine to a patient to record details of the vaccination in the AIR.

        From 1 March 2021:
      • The Department of Health has advised that vaccine providers will need to provide a card to patients noting their vaccination when they leave the clinic.
      • Patients will be able to view their immunisation history on the AIR via their My Health Record or My Gov account or Medicare online.

    • You cannot force a patient to remain in the practice.

      You should treat this like any situation where a patient refuses treatment or discharges themselves against medical advice.

      We recommend that you advise the patient why they should stay, and about the risks of leaving, and document this advice in the medical record. Make a note in the patient’s record if the patient leaves contrary to medical advice


    • If your patient was not informed of the risk of thrombocytopaenia syndrome (TTS)

      when they received the first dose of AstraZeneca vaccine (prior to 8 April 2021), you should obtain a new consent after they have been informed of the risk.


    • As with any course of treatment, if your patient does not complete the course, you should explain the potential outcomes.

      You cannot force your patient to have the second dose if they do not wish to have it. We recommend you document your advice and the patient’s decision in their medical record.

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    Avant Resources on consent and capacity

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    COVID-19 vaccinations: Multi-dose vials (MDVs)


    • Many doctors and practices will have little or no experience with the use of MDVs. 

      The risks include sepsis, transmission of blood-borne infections and dosage errors. 

      Tips to minimise these risks include:

      • Do not be complacent – both you and your staff should recognise that the correct use of MDVs differs from usual practice.
      • Consider adjusting your appointment intervals so that your staff can take extra care when administering vaccines.
      • Complete the mandatory COVID-19 Vaccination Training Program before providing any COVID-19 vaccinations, including making sure you have enough time to complete the modules.
      • Take the time to set up correct processes in your practice.
      • Ensure that all staff follow the step-by-step procedures outlined for the use of MDVs in the training, including displaying a copy of these in your practice wherever anyone will be diluting, drawing up and administering the vaccines.
      • Run simulations in your practice before you start administering the vaccines, including outlining each of the steps (from when you are preparing to open a vial until when you discard a needle/syringe after use). 
      • Repeat the simulations frequently, especially when new team members are joining your practice.
      • Be aware that different batches of the same vaccine may have different doses available in each vial (for example, the AstraZenica vaccine vials may contain either eight or ten doses).
      • Consider having a separate area for drawing up each vaccine dose rather than doing this next to your patients.
      • Clean the bung with an alcohol swab and allow 30 seconds to dry before inserting a needle into it.
      • Do not leave a drawing-up needle inserted in the vial unless you are drawing up all doses out of the vial at the same time.
       

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    COVID-19 vaccinations: Medicare


      • For practices participating in the COVID-19 vaccination rollout, there are three types of Medicare item numbers specifically associated with the provision of COVID-19 vaccinations:
      • 1 Vaccine Suitability Assessment Services
      • 2 In-Depth Patient Assessments
      • 3 Flag-Fall Arrangements.

      These Medicare items are only available for participating practices.

      Vaccinations must be bulk-billed for everyone living in Australia who is Medicare-eligible, including all Australian citizens, permanent residents, and most visa-holders.

      Vaccine Suitability Assessment (VSA) Services

      The Department of Health has released information about these 16 item numbers.

      The services have to be billed in the name of the supervising GP, who must be present at the location at which the service is undertaken (including for the observation time).

      The services can be undertaken face-to-face by a suitably qualified health professional. However, the supervising GP must accept full responsibility for the service.

      The assessment cannot be done by telehealth.

      A supply of the vaccine must be available for immediate administration. However, the item number should be billed if a patient declines the vaccine after the assessment has been performed.

      If a patient undergoes a VSA and declines the vaccine at that visit but then returns to have the vaccine on another day, a second VSA can be billed when they return.

        You need to ensure you comply with record-keeping requirements to demonstrate a VSA has been conducted appropriately, including:
      • patient name
      • separate dated entry for each attendance for a VSA
      • recording of consent
      • clinical information adequate to explain the service
      • be sufficiently comprehensible so another doctor can rely on the record to effectively undertake ongoing care as it relates to COVID-19 vaccinations.

      In-Depth Patient Assessments

        The Department of Health has released information about these two item numbers:
      • must be billed in conjunction with a Vaccine Suitability Assessment Service.
      • can only be claimed where an in-depth clinical assessment regarding a patient’s individual health risks and benefits associated with receiving a COVID-19 vaccine is undertaken.
      • must take at least 10 minutes.
      • can only be claimed once per patient, at either the first or second dose. It cannot be claimed if it has already been claimed by another doctor.

      The doctor must attend the patient in person, you cannot delegate this task to anyone else. Please note that you cannot undertake the assessment by telehealth.

      Flag-Fall Arrangements

        The Department of Health has released information about this item number, which:
      • can ONLY be billed when a doctor is performing a COVID-19 vaccine suitability service in:
        • a residential aged care facility
        • a residential disability facility setting
        • a patient’s place of residence
      • must ONLY be billed in conjunction with the first patient seen on each occasion the doctor attends the facility
      • is NOT available for other site visits external to a doctor’s practice.

      Bulk-billing incentives

      Bulk-billing incentives (double for dose one, single for dose two) will be incorporated into the value of the items and will not need to be claimed separately ($10 per dose).

      The double payment of the bulk-billing incentive for the first dose is in recognition that some patients will need longer explanations about the vaccine than others.

      Where both doses have been provided to the patient by the practice, the practice will be eligible for a PIP incentive of $10 (per patient) on completion of the second dose.


    • No, it is not permissible under Medicare rules to charge a fee or co-payment for a service that is bulk-billed.

      The Department of Health has advised general attendance items cannot be used to triage or screen patients before booking or performing a Vaccine Suitability Assessment.

      This means that, for patients who are making bookings to have the vaccine, you cannot routinely book and charge them for a general attendance item first.

      You cannot charge any “new patient fee” or similar.


    • You can only do this if your patient requires a service unrelated to the vaccine. You cannot claim any item other than a VSA, In-depth Assessment or Flag-fall for the administration of the vaccine.

      The Department of Health’s prefers that patients presenting with multiple clinical matters be encouraged to book a separate consultation, and preferably with their usual practice. However, there may be some circumstances where deferring treatment is not feasible or in the patient’s best interests. In these situations, standard MBS multiple same-day attendance rules apply.

      Your medical record will be important to demonstrate that this is a separate service. We recommend you make detailed notes about each service. The Department of Health recommends that you state: “The additional service [MBS item…] is clinically relevant but not related to the vaccine suitability assessment service [MBS item…].”

      The practice must obtain and document the patient’s informed financial consent to ensure that the patient understands there is no cost associated with the COVID-19 vaccine. You must inform patients if any other service that they receive on the same occasion will be bulk-billed or subject to a patient co-payment.

        The vaccine suitability assessment service items cannot be co-claimed with:
      • MBS bulk-billing incentive items 10990, 10991 and 10992.
      • MBS item 10988, for an immunisation service provided by an Aboriginal and Torres Strait Islander health practitioner on behalf of, and under the supervision of, a GP.
      • The Department of Health has provided scenarios to help you understand where co-claiming might be suitable.

    • No.

      The Department of Health has stated that the new COVID-19 vaccination temporary MBS items have been exempted from the 80/20 rule.

      Any general attendance items billed where COVID-19 vaccinations are discussed will still be included in the 80/20 rule.


    • You can claim other Medicare items numbers when a patient suffers a significant adverse reaction to a vaccine to allow you to provide appropriate treatment.

        Significant adverse reactions include:
      • syncopal episode
      • severe allergic reaction such as anaphylaxis
      • strong, adverse mental or emotional reaction.

        The Department of Health further advises:
      • the treatment is the responsibility of the same doctor who undertook or supervised the Vaccine Suitability Assessment
      • the treatment must be bulk-billed
      • the adverse reaction must be reported to the TGA or state/territory health department.

    • The Department of Health has confirmed that in situations where doctors at participating practices have a discussion with a patient in relation to their suitability for the vaccine and the vaccine is not available to be given immediately, you can bill general attendance Medicare items.

      These general attendances do NOT need to be bulk-billed.

      For example, a patient books a normal visit with you and when they arrive they only wish to discuss the vaccine and their suitability, but you do not have a vaccine dose available for them at that time.

      All general attendance items will be subject to the 80/20 rule.

      However, the Department of Health has advised general attendance items cannot be used to triage or screen patients before booking or performing a Vaccine Suitability Assessment. This means that you cannot routinely book and charge patients who are making bookings to have the vaccine for a general attendance item first. You cannot charge any “new patient fee” or similar.

      In circumstances where it is unforeseen that a vaccine is unavailable to be given when a patient attends for a vaccine suitability assessment, the Department of Health has advised that the VSA can be billed at the time and another one can be billed when the patient returns for the vaccine. For example, you may experience a delay due to an unanticipated staff absence. However, valid reasons do NOT include inadequate staff rostering or when there is insufficient supply of vaccine doses.


    • Yes, however, you cannot charge for this, either to Medicare or by private billing.

      You are not expected to provide this service as part of any agreement with the Department of Health.

      You may choose to refer patients who are not Medicare-eligible to a state-based vaccine delivery site, to a Commonwealth Vaccination Clinic (previously known as a General Practitioner-led Respiratory Clinic) or to another other clinic as advised by the Department of Health if these facilities are not available. They will not be charged at these clinics.


    • All practices that are selected as vaccination providers must offer vaccination to people who are not currently patients of the practice. However, practices can certainly encourage their own patients to be vaccinated and can make appointments for those patients.


    • Doctors at non-participating practices can bill general attendance items for discussions relating to the vaccines. These do not need to be bulk-billed.

      Non-participating practices are not able to bill Vaccine Suitability Assessments, In-depth Patient Assessments or Flag-Falls.


    • The Department of Health has advised that action will be taken for any use of Medicare items that is not in accordance with guidelines and legislation.

      In addition to usual Medicare compliance, doctors and practices are being contacted by the National COVID Vaccine Taskforce when complaints have been made about their billing. In some cases, doctors and practices are being required to undertake extensive audits, and to repay considerable amounts to patients or Medicare.

      The Taskforce states it may revoke a practice’s participation in the vaccine rollout if necessary.

      We recommend that you contact Avant for advice if you are contacted by the National COVID Vaccine Taskforce or Medicare.

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    COVID-19 vaccinations: Practice management


    • Unfortunately, the answer to this question is complex.

      To help you navigate this process and minimise the chances of running into a legal problem, we suggest you take the following steps.

      Step 1: Ask your patients to comply

      As a starting point, you should simply ask patients to provide a recent negative COVID-19 test when they attend the practice. Most patients will be happy to comply.

      If a patient refuses to comply, a medical practice can impose a condition of entry on any person entering the practice, provided the practice complies with work health and safety, discrimination and other laws.

      For this reason, you should work through Steps 2-5 before you make a final decision to require the patient to provide evidence of a negative COVID-19 test as a condition to entering your practice to receive treatment.

      Step 2: Check whether the public health directions in your state mandate a negative COVID-19 test before a person is allowed to attend for medical treatment

        It is important to be aware that:
      • “Lockdown” public health directions generally allow a person to leave their home for medical treatment and do not require a negative COVID-19 test before a person does so.
      • The health departments in each state and territory can issue specific directions to residents in relation to COVID-19. For example, a person who is a “close contact” may be required to quarantine for a defined period and may only be allowed to leave quarantine if they have had a negative COVID-19 test.
      • The police are responsible for enforcing public health directions, NOT the practice or doctor.

      • Step 3: Consider whether a negative COVID-19 test is ‘reasonably necessary’ to ensure work health and safety

        Under work health and safety laws, medical practices must implement control measures to eliminate or minimise the risks of COVID-19 and ensure the health and safety of their workers, patients and others at the workplace.

        This means that you will need to undertake a risk assessment in conjunction with workers to determine the appropriate control measures.

        In undertaking a risk assessment to determine whether persons should be required to have a negative COVID-19 test before they enter a practice, you should consider factors including:
      • current public health directions.
      • advice from state and federal health departments.
      • advice from work health and safety bodies.
      • rate of community transmission in your location and the patient’s location.
      • risk of transmission in your practice, having regard to the specific features of your practice
      • nature of the services provided.
      • consequences of refusing access to the medical service.
      • type of people who use the medical service and whether there is a heightened risk they will suffer severe symptoms if they contract COVID-19 (for example, people over 60 or people with pre-existing health conditions).
      • whether the business could put alternative measures in place to protect staff and patients (for example, telehealth appointments or seeing the patient outside the physical practice).
      • how long people generally stay inside the medical practice when receiving medical services.
      • whether it is possible to socially distance in the practice.
      • availability and practicality of COVID-19 testing.

      If your risk assessment identifies that requiring patients to provide evidence of a negative COVID-19 test before entering your practice is a ‘reasonably necessary’ measure to ensure health and safety, your practice can direct those patients not to attend the practice (unless doing so would amount to unlawful discrimination).

        If a patient makes a complaint to a discrimination tribunal or the Medical Board, you will need to prove that the requirement for a negative COVID-19 test is ‘reasonably necessary’. This could be difficult for the following reasons:
      • A COVID-19 test is a point-in-time test and does not guarantee the patient is COVID-19 free at the time of the appointment.
      • A patient could receive a false negative test result.
      • The practice should already have measures in place to protect against the risks of COVID-19. If a discrimination claim is commenced, the practice will need to prove to a court or tribunal why a negative COVID-19 test is a necessary measure on top of the measures already in place.

      To assess whether using rapid antigen testing could be classified as “reasonably necessary’, please see the Department of Health advice, including the PHLN and CDNA joint statement of SARS-CoV-2 rapid antigen tests.


      Step 4: Consider whether refusing entry could amount to discrimination

      State and federal legislation prohibits discrimination on the basis of attributes including disability.

      The term “disability” is defined differently in each jurisdiction but generally includes the presence in the body of organisms capable of causing illness or disease. COVID-19 would fall into this definition and therefore a person with COVID-19 would be considered a person with a disability for the purposes of discrimination law. A person also has a disability if the person is presumed to have the disability (i.e. the practice presumes that everyone without a negative COVID-19 test has COVID-19).

        It is unlawful for a practice to discriminate against a person on the basis of the person’s disability by refusing them medical treatment or access to practice premises unless:
      • the discrimination is reasonably necessary to ensure health and safety.
      • the practice is unable to make reasonable adjustments without it imposing unjustifiable hardship on the practice (for example, the practice should consider whether it can hold an appointment with the patient via telehealth or while wearing full PPE – these would be considered to be “reasonable adjustments”).

      Step 5: Consider whether the situation is an emergency and you have an obligation to provide medical care

      Medical practitioners do not have an absolute obligation to provide medical care to patients, even in an emergency situation.


    • Unfortunately, the answer to this question is complex.

      To help you navigate this issue and minimise the chances of running into a legal problem, we suggest you consider the following issues before you refuse entry to an unvaccinated patient.

      Step 1: Check the public health directions in your state and territory

      State and territory public health directions do not currently prevent a person from entering a medical practice if the person is not vaccinated against COVID-19. 

      Step 2: Obligation to treat a patient

      A medical practice does not generally have to allow a person to enter the practice.

      Step 3: Consider whether the decision not to treat the patient may be discriminatory

      You can refuse to allow an unvaccinated patient to enter your practice except when the patient is not vaccinated for a reason such as:

      • the patient’s medical condition
      • the patient’s age (for example, because the TGA has not approved vaccination for their age group)
      • the patient’s religious beliefs.

      It can be lawful to discriminate if it is necessary to ensure the health and safety of people in the practice.

      However, the practice should first consider whether there is another way to provide a service to the patient other than through entry to the practice (for example, via telehealth).

      Step 4: Consider work health and safety issues

      Under work health and safety laws, practices must ensure the health and safety of their workers, patients and others at the workplace.

      Your practice should undertake a risk assessment in consultation with practice staff to determine whether patient vaccination against COVID-19 is necessary to ensure health and safety in the workplace.

      In undertaking a risk assessment to determine whether people should be required to be vaccinated against COVID-19 before they enter a practice, you should consider factors including:

      • advice from state and federal health departments
      • advice from work health and safety bodies
      • rate of community transmission in your location and the patient’s location
      • risk of transmission in your practice, having regard to the specific features of your practice
      • nature of the services provided
      • consequences of refusing access to the medical service
      • type of people who use the medical service and whether there is a heightened risk they will suffer severe symptoms if they contract COVID-19 (for example, people over 60 or people with pre-existing health conditions)
      • whether the business could put alternative measures in place to protect staff and patients (for example, telehealth appointments or seeing the patient outside the physical practice)
      • how long people generally stay inside the medical practice when receiving medical services
      • whether it is possible to socially distance in the practice
      • availability and practicality of COVID-19 testing.

      Your practice should already have policies in place for dealing with:

      • how you initially see patients
      • the use of personal protective equipment (PPE)
      • how you manage cases where patients have COVID-19 symptoms.

      Telehealth may be an option for treating a patient who is unvaccinated.

      Step 5: Other factors

      Your practice may wish to consider other factors before making a decision to refuse treatment to an unvaccinated patient:

      • the reason the patient is not vaccinated (e.g. the patient intends to be vaccinated but has had difficulties accessing vaccination)
      • whether the patient is a new patient or existing patient
      • if a doctor elects to terminate the doctor-patient relationship or deny treatment to a patient because the patient is not vaccinated, the patient may make a complaint
      • the capacity of the patient to obtain treatment elsewhere (for example, denying treatment at a GP practice versus a specialist practice where there are a limited number of specialists in that area)
      • the patient’s need for continuity of care (having regard to factors such as the urgency of care, the value of an ongoing treating relationship etc)
      • a doctor’s right to conscientiously object to treating patients who are not vaccinated.

    • The patient is responsible for making an appointment for the second dose of the vaccine. Although they are not required to have the second dose of the vaccination at the same practice as the first dose, the Department of Health encourages patients to book both appointments at the same time and return to the same practice for the second dose.

      An additional Practice Incentive Payment (PIP) is made when both doses are provided by at the same practice.

      If a patient does not book both appointments at the same time, we suggest that you remind them at the first visit to make the appointment for the second dose and offer to make that appointment at the clinic.

      If the patient does not attend the practice within the prescribed time for the second dose (e.g. 21 days for the Pfizer vaccine and 12 weeks for the Astra Zeneca vaccine), the practice could send an SMS reminder assuming consent has been provided to communicate via SMS.

      Otherwise, we suggest you follow your usual follow-up protocol to recall patients for their second dose.


    • The Therapeutic Goods Administration is strongly encouraging practices and patients to notify any side effects as part of its role in monitoring the safety of vaccines after they are registered.

      For more information on how to report side effects, refer to Reporting suspected side effects associated with a COVID-19 vaccine. It is recommended that you report to your state or territory health department, as they will forward the report to the TGA.

      You should notify Avant about serious adverse events that arise in your practice as required under your insurance policies.


    • Yes. The Department of Health has confirmed that all authorised immunisation providers must have completed the free COVID-19 vaccine specific training to administer the vaccines.

      Non-clinical training modules are also required to be completed by non-clinical and administration staff who are involved in vaccine handling, storage and administrative reporting.

      There are frequent updates to the content in the training program. You must review these whenever you are advised they are available.


    • Yes.

      However, providing vaccinations in your car park is not something that most practices would be able to set up without significant planning.

      ATAGI have issued a statement regarding drive through vaccination clinics. This statement provides extensive guidance, and we recommend that you review and follow this prior to considering providing vaccinations in your practice’s carpark.

        The statement is relevant for all situations where you may provide vaccinations in your carpark, including:
      • Large through-put vaccination clinics.
      • Occasional vaccinations of patients in their cars, for example, patients whose mobility prevents them from exiting their car and moving inside your practice premises.
        In particular, you should give consideration to:
      • The general requirements for vaccination sites external to your premises are the same as for inside your premises, including the handling of the vaccines, patient consultation and record-keeping. The practice is required to comply with the usual state and national vaccination rules and guidelines when providing COVID-19 vaccinations and this may have an impact on where to locate the vaccination clinic.
      • An observation period after vaccine administration is still required.
      • How you will manage patients who report side-effects.
      • Management of traffic flow, including impacts on adjacent and passing people and entities.
      • Safety of staff, patients and others in an environment that differs from your usual practice.

    • The Department of Health has indicated that vaccination with the AstraZeneca vaccine during home visits is possible, as long as either of the following specific procedures are followed:

      1. Where possible, you should take a vial to your patient’s home whilst maintaining the cold chain, and draw up the individual dose immediately before administration (process preferred by Department of Health), or

      2. A dose may be drawn up into a syringe at your practice for you to take to your patient’s home for administration. If you do this, the syringe must be transported by you at room temperature (under 30 degrees), protected from light and administered within one hour of being drawn up.

      See also our FAQs on Medicare and vaccinations above (What Medicare item numbers are available for participating practices to provide the COVID-19 vaccination for patients?), particularly in relation to flag-fall arrangements.


    • The Department of Health has confirmed that practices will be responsible for appropriately storing and handling the vaccines upon receipt of the vaccine from the Commonwealth’s contracted logistics providers.

      The practice is required to report incidents involving lost or broken vials to the Vaccine Operations Centre. More details on the process for reporting incidences and investigation process is provided as part of the Department’s training modules.

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    COVID-19 vaccinations: Employment



    • Unfortunately, the answer to this question is not straightforward and, because the issue is a controversial one, you need to be aware that the law on employers requiring employees to be vaccinated could change at any time.

      At present, a privately-owned medical practice may be able to require a healthcare employee to have the COVID-19 vaccine.

      The Fair Work Ombudsman (FWO) has released detailed general guidance about mandatory vaccination in the workplace.

      If you are a practice, to determine whether you can require a private healthcare employee to have the COVID-19 vaccination, you should consider the guidance that the FWO has provided.

      If you are a practitioner, these are the factors that your practice needs to consider in deciding whether to make COVID vaccination mandatory.

      In addition, there are laws and regulations on this issue that specifically affect the healthcare sector that you will also need to consider before requiring healthcare employees in your practice have the COVID-19 vaccine.

      We suggest you navigate what is a complex legal issue by taking the following steps:

      Step 1: Speak with your employees and encourage them to be vaccinated

      As a first step, if you are considering requiring your employees to be vaccinated, you should speak with them about vaccination and encourage them to be vaccinated.

      You may be able to assist by providing your employees with information about the vaccination and by facilitating time off so they can get vaccinated or by facilitating vaccination at your practice.

      If employees refuse, you should consider the following steps.

      Step 2: Check the current public health directions and other laws in your state or territory

      The FWO’s guidance sets out the public health directions and other laws that currently mandate vaccination.

      On 18 August 2021, the Federal Government reiterated its position that:

      “… vaccination is free and voluntary, unless a state or territory public health order is in place. The Australian Government's position of voluntary vaccination does not detract from individual employers seeking their own advice and mandating for their workforce if they have assessed that it is the right decision for them.”

      In many cases, it is the employee’s responsibility to be vaccinated unless a relevant exemption applies. This type of public health direction can only be enforced by the police. Your practice does not have to enforce it. In some states and territories, the public health directions require employers to ensure their employees are vaccinated (subject to certain exemptions). You will commit an offence if you do not comply with the direction.

      Step 3: Check awards and enterprise agreements

      Awards and enterprise agreements that apply to an employee’s employment may mandate COVID-19 vaccination.

      Step 4: Ensure that you are complying with work health and safety obligations

      Work health and safety laws require medical practices to implement control measures to eliminate or minimise the spread of COVID-19 and ensure the health and safety of their workers, patients and others at the workplace.

      This can be done by undertaking a risk assessment in conjunction with workers and determining the control measures that are necessary based on that risk assessment.

      The FWO’s guidance sets out the factors that an employer should consider in undertaking a risk assessment.

      Your practice should review and update its risk assessment as circumstances change.

      If the risk assessment concludes that COVID-19 vaccination is a necessary measure, the practice can require employees to be vaccinated.

      You can find further information at SafeWork Australia.

      Step 5: Ensure that you are not unlawfully discriminating against an employee

        It is unlawful for a practice to discriminate against an employee on grounds including a medical condition, pregnancy and religion unless:
      • the discrimination is reasonably necessary to ensure health and safety.
      • the practice is unable to make reasonable adjustments to the employee’s role without it imposing unjustifiable hardship on the practice (for example, the practice should consider whether an unvaccinated employee can work from home or work in a different area of the practice).You should seek specific advice if a requirement to be vaccinated might constitute discrimination.

      Step 6: You are entitled to give an employee a “reasonable and lawful direction”

      If the practice’s risk assessment determines that staff vaccination is required in the practice to keep workers and others safe, the practice can issue a reasonable and lawful direction to employees to be vaccinated.

      An employee’s failure to comply with a reasonable and lawful direction can result in disciplinary action which may include termination of employment.

      As an employer, you must have regard to an employee’s reason for not wishing to be vaccinated before taking disciplinary action (particularly if the reason could be an attribute on which discrimination may be based).

      The Fair Work Commission (FWC) recently found that the requirement for an employee to have the flu vaccine was a reasonable and lawful requirement. However, it is important to understand that whether a requirement is reasonable and lawful will depend on the facts of the particular case.

      Further information

      SafeWork Australia and the Fair Work Ombudsman have issued guidance about mandatory vaccination.


    • If you have a conscientious objection to receiving or administering the COVID-19 vaccine, it is important for you to comply with the joint statement from Ahpra and the National Boards on registered health practitioners and students and COVID-19 vaccination.


    • A number of states and territories have introduced public health directions which require healthcare workers to undergo mandatory COVID-19 testing. You should check the rules in your location.


    • You should check the award and/or enterprise agreement that applies to your employment as many include requirements about redeployment or alternate duties (for example, clause 22 of the AMA Victoria - Victorian Public Health Sector - Doctors in Training Enterprise Agreement 2018-2021.)

      Otherwise, as an employee, you are required to comply with the lawful and reasonable directions of your employer. If a direction is not lawful and reasonable, you are not required to comply with it.
      If you are a contractor or accredited doctor rather than an employee, you are required to comply with the terms of your agreement or the facility rules/by-laws.

      What does ‘lawful’ mean?
      A direction is lawful if you can comply with it without breaching any laws. For example, you cannot be required to do anything that you are not registered for or that you are not insured for.

      What does ‘reasonable’ mean?

        There is no single test to determine whether a direction is reasonable. The reasonableness of a direction will depend on a range of factors. In the case of a direction to work in a role in another department or outside your chosen specialty, you should consider issues such as:
      • Do you have the relevant (and current) skills and experience needed to work in the role?
      • Will appropriate supervision be provided?
      • Will you be able to ensure patient safety in the role?
      • Can you perform the role safely, particularly if you are a vulnerable healthcare worker?
      • Will the hospital provide the appropriate resources (including PPE) for you to work safely in the role?
      • Will the hospital provide the relevant training you need to be able to work in the role?
      • Will you be indemnified for your work in the role?
      • If the answer to any of these questions is “no, the requirement for you to work in the role may be unreasonable.

      If you are concerned about being redeployed to a new role, you should speak with your hospital supervisor, director or the HR team.


    • You should speak with your treating medical practitioner about the risks to your health and safety if you work in a COVID-19 vaccine clinic.

      A number of colleges and societies have issued advice about pregnancy and the risk of COVID-19, and about pregnant healthcare workers. For more information see:

      RANZCOG:

      COVID-19 Vaccination in Pregnant and Breastfeeding Women.

      COVID-19 and pregnant healthcare workers and other at-risk workers.

      Australian and New Zealand Intensive Care Society (ANZICS):

      COVID-19 guidelines.

      RACP:

      COVID-19: Guidance for pregnant healthcare workers.

      For employed doctors who are pregnant, there is legislation entitling you to transfer to a safe job or not attend work in certain circumstances. You should seek specific advice about your personal circumstances.

      This is general advice. You should consider whether there are any specific conditions or requirements in your contract of employment, services agreement and policies and procedures.


    • You are under no obligation to disclose your COVID-19 vaccination status to a patient.

      If you feel comfortable disclosing your COVID-19 vaccination status, you can do so.

        If you do not feel comfortable disclosing your COVID-19 vaccination status, you can advise the patient:
      • Our practice has systems in place to ensure it is aware of and implements the most current advice from the all relevant bodies including:
        • ATAGI;
        • the federal and state health departments;
        • Ahpra and the National Boards; and
        • the [insert name] College.
      • Our practice has a COVID-Safe plan in place to ensure that all staff and patients are safe in the practice. Our plan is reviewed and updated regularly.
      • Our practice complies with all infection control standards to manage any potential infection transfer.
      • [For GP practices] Our practice is accredited in accordance with the RACGP’s accreditation standards.
      • Due to privacy legislation, personal information about the vaccination status of medical practitioners and staff cannot be disclosed.

      The practice may wish to place a sign in its waiting room and on its website with the above information.

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