COVID-19 and HPV compliance

On 16 March 2020, a state of emergency was declared in Victoria which triggered the critical incident procedures under Health Purchasing Policy 3: Market Approach (HPP3).

HPV understands that mandated health services have also activated an internal emergency event as part of their COVID-19 response and management.

During a critical incident, such as the COVID-19 pandemic – where it is impractical to apply usual procurement rules and processes – mandated health services can adopt streamlined and flexible procurement processes to expedite their crisis response. Section 4 of HPP3 details the relevant requirements.

If HPV-awarded suppliers are unable to provide the required goods and/or services within the required timeframe, mandated health services can source these services off-contract, including from non-contracted suppliers.

When will critical incident procurement cease?

Critical incident procurement will no longer apply from the date that the Declaration of a State of Emergency ceases under the Public Health and Wellbeing Act 2008.

Mandated health services are required to resume their normal procurement processes under the Health Purchasing Policies after the conclusion of the critical incident.

HPV recognises that supply chains may be affected for some time. Please speak with your Customer Relationship Manager if your health service is encountering supply challenges.

How do we report our compliance during the critical incident?

During the critical incident, to the extent it is impractical to apply them, elements of the Health Purchasing Policies may be streamlined. Procurement that meets this threshold can be considered out-of-scope when assessing compliance.

Self-assessment

In addition to the usual reporting requirements, and in light of the critical incident, HPV will seek a supplementary report from mandated health services to support the self-assessment reporting mechanism. This supplementary report will assist HPV in fulfilling its legislated compliance monitoring function.

Additional information will be sought on:

  • HPV collective agreements to which the critical incident procedure was applied.
  • Reasons why it was impractical to apply the HPV collective agreement.
  • Total value of the procurement.

This information should have been maintained in accordance with the minimum record keeping requirements under subsection 4.3 of HPP3.

Audit

The mandated health service’s chosen auditor will likely focus on the implementation of the critical incident procedures under HPP3, particularly the minimum record-keeping and Board reporting requirements.

Annual attestation

HPV has provided an exemption for the annual attestation reporting requirement for the FY 2019-20 reporting period. Mandated health services are therefore not required to include an attestation to the Health Purchasing Policies in their annual report of operations for FY 2019-20.  

How does the State Supply Chain affect compliance reporting?

All goods received from the State Supply Chain should not be included in health service compliance assessment and reporting as these items were ordered during the state of emergency.