What is SAPP?
The Department of Health (Health) introduced the Special Approved Placements Program (the SAPP) in November 2003 as a special mechanism for granting interim access to Medicare Benefits Schedule (MBS) under the provisions of s3GA of the Health Insurance Act 1973 (the HIA). As a special arrangement, the SAPP caters to doctors who:
- were first registered to practise medicine with an Australian medical board on or after 1 November 1996;
- are employed by a full-time general practice;
- are not a Fellow of the Royal Australian College of General Practitioners (FRACGP) or the Australian College of Rural and Remote Medicine (FACRRM); and
- have exceptional circumstances that prevent their participation on the other more formal general practice programs recognised under s3GA of the HIA. These programs include the Australian General Practice Training Program (AGPT), the Remote Vocational Training Scheme (RVTS), the ACCRM Independent Training Pathway, and the Rural Locum Relief Program (RLRP).
The primary purpose of the SAPP is to provide doctors who are facing exceptional situations with an opportunity to progress their general practice career. Health defines circumstances as being exceptional when they are both beyond the doctor’s personal control and directly prevent them from joining, or remaining on, the other general practice programs.
While the SAPP retains its primary focus on addressing exceptional circumstances, the Program also provides Health with the scope to consider other matters. Over time, Health has used the SAPP to accommodate doctors who do not qualify as having exceptional circumstances, but who instead:
- demonstrate that their lack of either general practice experience or a general level of medical registration with the Medical Board of Australia (MBA) prevents their immediate participation on the more structured general practice programs;
- have been removed from a full-time general practice program prior to fully completing assessments for either the FRACGP or FACRRM qualification and who require more time working in general practice while they re-take assessments;
- require time-limited access to the MBS so that they can be deployed to assist a state or territory government response to a pandemic or declared emergency; or
- require time-limited access to the MBS so that they can assist the response to a regional disaster.
Health applies these considerations through the SAPP because it is more flexible than the other general practice programs as participants are not subject to a structured set of experience requirements. However, this does not mean that SAPP participants are exempted from satisfying the MBS eligibility requirements under ss19AA or 19AB of the HIA, or excluded from the requirement to work towards either the FRACGP or FACRRM qualification.
Determining a doctor’s eligibility for the SAPP
Commencing from 1 February 2018, Health applies a rigorous assessment framework when assessing requests to join the SAPP. This framework ensures Health applies consistent considerations to requests that have similar features, while having the flexibility to respond to exceptional cases, as per the intent of the SAPP.
While this framework sets out how Health intends to apply a variety of considerations that are not found in the other general practice programs, the SAPP does not offer complete discretion to a decision-maker. To request a placement on the SAPP, a doctor must meet minimum eligibility requirements. These requirements apply when assessing all requests, including those made under the exceptional circumstance provisions of this Program.
To be considered, a doctor must:
- be registered with the MBA;
- not have conditions on their medical registration that would prevent their request;
- have a current contract of employment with a general practice; and
- (in most cases) be able to provide a current (less than six months old) assessment of their general practice experience from either the RACGP or ACRRM.
A general practice experience assessment is important for Health to be able to conduct a fulsome assessment of a doctor’s eligibility to participate on the Program. Health will assess a doctor who does not yet have a general practice experience assessment if they:
- request consideration under the exceptional circumstance provisions of this program and provide evidence that either they, or an immediate first degree relative, has a chronic or life-threatening medical condition;
- can demonstrate that they have previously successfully completed some of the assessments required for attaining either FRACGP or FACRRM; or
- have been engaged as part of the response to a pandemic, declared emergency or regional disaster.
The SAPP retains its interim focus and participants are expected to achieve a definable point of progress in their general practice career while participating on the Program.
Categories of approved SAPP participants:
- Participants who demonstrate exceptional circumstances
- Participants who were removed from another full-time program before completing requirements for specialising
- Participants who were removed from the Rural Locum Relief Program two year program
- Participants seeking vocational experience
- Participants limited by their medical registration
- Participants responding to a pandemic, other national emergency, or local disaster.
Further information on eligibility and maximum participation timeframe for each of the above categories is detailed in the SAPP assessment framework.
Requesting a SAPP placement
All requests for an approved placement under each of the categories contained within the SAPP assessment framework are to be forwarded to the Access Programs Section of Health by emailing: 19AA@health.gov.au. When requesting an approved placement, the doctor must:
- complete and attach the SAPP request coversheet and checklist, which can be downloaded below;
- attach legible copies of each piece of documentation/evidence to support their assessment against the relevant placement category; and
- provide a business-hours contact telephone number.
Please note that Health will not process a placement request that does not meet the above standards or that does not provide the necessary supporting documentation that is relevant to the category of assessment. Before making their request to join the SAPP, doctors are expected to have read and understood the SAPP flow-chart that is provided with the SAPP assessment framework.
Health undertakes to assess all complete requests for SAPP placements within a 28 working day timeframe. Wherever possible, Health will assess SAPP placement requests in strict date order of receipt as a means of providing procedural fairness to doctors.
Health reserves the right to give priority to doctors seeking MBS access through the SAPP to assist a timely and comprehensive response to an emergency, pandemic or local disaster.
Health will contact the doctor if a period of more than 28 working days is required to assess their SAPP placement request. Health may require additional time to assess placement requests under category A that involve complex claims of exceptional circumstances.
Health does not grant special priority to doctors who request an extension to a previously granted SAPP placement. New applications and extension requests will be considered under this assessment framework in date order of receipt. Doctors are expected to consider Health’s assessment timeframes if they identify that they:
- have not exceeded the maximum timeframe allowable under their participant category under the SAPP framework (5 years for category A, and 2 years for categories B through F); and
- require an extension to their SAPP placement and MBS eligibility to meet the requirements Health has placed on them as part of their approved placement.
SAPP Assessment Framework
SAPP Application Form
The flowchart describes the process taken by Health to process applications to participate on the Special Approved Placement's Program (SAPP).
Department of Health Decision Phase
Step 1 Receipt of SAPP application for doctor’s participation
Step 2 Application checked for completeness
If incomplete – request further information from applicant
If complete – go to Step 3
Step 3 Assess against eligibility criteria
Step 4 Ascertain whether applicant doctor is prevented from participating in other 3GA workforce or training programs due to exceptional circumstances
f no – application declined and doctor advised of decline
If yes – go to Step 5
Step 5 Health grants approval for participation on SAPP
Step 6 Notice of doctor’s participation on SAPP sent to the Department of Human Services
Step 7 Doctor advised of decision and conditions of placement
Department of Human Services Administration Phase
Step 1 DHS receives approved doctor’s placement (and s19AB(3) exemption instrument if required) from Health
Step 2 If DHS has received an application for inclusion on the 3GA Register, DHS places doctor’s name on 3GA register
Step 2 If DHS has not yet received an application from the applicant doctor, DHS waits until the Medicare Provider Number application has been received to link the application with the placement on the 3GA register
Step 3 DHS issues the Medicare Provider Number for the doctor’s participation
For further information about the SAPP, please contact 19AA@health.gov.au. Applications are assessed by Health within 28 working days of receipt of a complete application.