CURRENT CIRCULATION: 7,843 th DATE: 8 August, 2011 ISSUE NO: 183

Welcome to Health & Lifes free email newsletter service. Tell a friend that we would be happy to add their email address to the distribution list. This service is to provide Health and Lifes clients and those who attended our presentations with up to date information on key financial and practice management issues that may affect your practice. Please do not use this as a substitute to seeking professional advice. Writer in charge: Mr David Dahm BA.Acc, FCPA, FTIA, Ffin, FAAPM, GLFG.

Employee v Contractor and GP Registrars?

Don't follow any advice, no matter how good, until you feel as deeply in your spirit as you think in your mind that the counsel is wise. - Joan Rivers STOP PRESS
STOP PRESS 1. Oops sorry about the error...! We are open again. Please be advised that our office re-opened from the 1 August 2011 as we have been migrating our IT to a new server IT solution. There was an error in our last news alert and we appreciate all those that let us know. We apologise for any inconvenience. 2. Nurses Award Claim - more industrial activity practices cannot afford. As advised in our earlier news alert see http://bit.ly/iMPihR we are concerned that the nursing union is making significant wage claims beyond the statutory 3.4% p.a increase. Of more concern is that employer associations are encouraging this activity in conjunction with the nursing union particularly in Victoria. This is unnecessary if practices have correctly paid and documented any over award payments in practice employment contracts. Contact us for a low cost employment template solution to avoid an expensive and unnecessary negotiation process that involves external representatives. We note some Divisions may be accidentally promoting to practices to respond to these claims not realising in the majority of instances there is no legal requirement for practices to enter into collective enterprise bargaining agreements.
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Practices are advised not to respond. Confidentially, we are happy to extend at no charge or obligation some clear advice on this matter. Make sure you send us your employment contracts so we can comment on your arrangements. Our advice remains the same, which is not to respond to these claims unless you feel you have a problem. We are concerned intimidation tactics are being used to entrap practices in a long and unnecessary negotiation process. 3. Medicare Fraud - Make sure patients sign your Medicare Forms Due to the continuing and challenging economic conditions expect more Medicare audit activity. On the positive side more doctors are coming out of or delaying their retirement and wanting to invest in practices and medical property! The national media has recently reported a threefold increase in over servicing and mistakes made by practices: see http://bit.ly/rplzVY. We dont condone rorting the system (there are some questionable practices out there), however we support natural justice rules in relation to any prosecution and better guidance and education to practices when using the Medicare Benefits Schedule. We are planning on putting in a submission after receiving a number of concerning emails from subscribes to our News Alert and the industry on the conduct of Medicares audit activities and the lack of education and guidance on Medicare Benefit Schedule interpretations. The Professional Service Review Committee has recently lost some major Federal Court challenges in this area. This is an issue we did write about three years ago. Now there is a Federal Senate enquiry on the Professional Service Review Committees behaviour. Medicare Australia, the AMA and Royal Australian College of General Practice have all publicly stated earlier this year it is not their role to interpret the Medicare Benefits Schedule! So you are not going mad. We need real reform in this area, like working out who is responsible for systems and education, before prosecuting providers and practices for breaches. This uncertainty is placing the sustainability of a variety practice arrangement under question. We believe there are some simple solutions that dont involve or encourage more red tape and regulation. Start getting patients to sign their Medicare claim forms. We are aware due to the Swine Flu contagion this requirement was relaxed. Technically it remains as a legal requirement according to the Governments websites. Charging a small patient gap so patients scrutinize your bills is better than having a Federal audit. A trade off is required to achieve a fair, open transparent system. We encourage all of you to consider making a submission and reviewing your practice arrangements. These submissions will be made public see http://bit.ly/q2F0HE .

4. AAPM October 2011 National Conference in Perth catching up with David Dahm From time to time I have been asked when I will be next in town for a chat. One way to meet is at the AAPM national conference which I am planning on attending: see www.aappm.org.au. This is a great conference to attend and it will also be a great opportunity to catch up with old friends and have a chat about anything. Thanks to those that have contacted us. If you are planning on going and want to catch up without any obligation let us know at pa@healthandlife.com.au, it will be great to see everyone again.

SPECIAL TOPIC - Employee v Contractor and GP Registrars? Employee v Contractor and GP Registrars? The 10 Most Frequently Asked Questions about employee and independent and/or contractor arrangements answered! INDUSTRIAL ISSUES: 1. I dont have to worry about the Fair Work Act or malpractice I make our providers sign an Independent Contractors Agreement! 2. What is an employee, independent contractor and tenant doctor/provider? The downside to being an employee or independent contractor MEDICO LEGAL ISSUES: 3. My insurance gives me enough coverage for employees, contract and GP registrar doctors you are just scare mongering? TAXATION ISSUES: 4. Are service trusts or entities the solution, the Australian Taxation Office does not like them because they are used to avoid tax? Is it legal? 5. GP Registrars and Overseas Doctors do we really have to employ them, is there anything wrong with this? 6. Can my service trust employ doctors? What are the tax and legal consequences? 7. Can owner doctors have a higher service fee percentage than the non owner doctors, will this be considered tax fraud? My adviser says this is dodgy. 8. Practice Companies - do doctors/providers need one or use them with or without a service trust? ACCOUNTING & BOOKKEEPING ISSUES: 9. The Practice or Billing Entity has a Legal Responsibility when handling someone elses money. 10. Should you rely on the government unions or representative organisation for advice? Are there any limitations? What should you do?

Employee v Contractor and GP Registrars?

The 10 Most Frequently Asked Questions about employee and independent and/or contractor arrangements answered! Introduction If you are confused on how to employ or engage a provider we dont blame you. Recently more conflicting information is coming from unions and GP Training bodies on this issue purporting to be from legal advice which only tells half of the story. Some have argued these union statements are self serving statements to ensure these bodies are embedded. This can interfere in the legal relationship between employees and employers and unionise the practice environment. A common misunderstanding is that independent contractors do not have similar rights to employees. In fact the Fair Work Act can apply to both together with penalties up to $33,000 for any breaches. Medico-legally there is a legal way to arrange your affairs to avoid this and many other pitfalls from employing and contracting providers. There is also significant financial freedom, medico-legal and tax benefits to providers and not just practices. For more information click here http://bit.ly/pR7m9R

Background Still confused which is better - an employee or an independent contractor or something else? Practices are currently being told they have to employ Registrars for legal and taxation reasons, which is not correct. This unnecessarily forces practices to employ providers which creates serious medico-legal and taxation consequences. The bottom line is this issue is causing much uncertainty, less flexibility and more costs for everyone to administer, including the introduction of a new layer of bureaucracy that is not legally necessary. To end this discord, we have written a response to the issues raised as a definitive assessment for the practice and advisors to consider the implications of employing professional staff and how to go about it. So why Does Health and Life Think they have got it right? Many of you are aware for over twenty years we have used national legal advisers, served on national committees and boards including providing advice to the federal Tax Office and have made serious public statements on these issues without any adverse findings or even audit enquiries. Most importantly we have used and won many arguments based on High Court rulings that many advisers are not aware of or their advice has not been sought on. This seems to be source of the confusion.

The practice and practice advisers must have a clear understanding of all, and not just some, of the issues in order to arrive at the correct conclusion. This also means asking the right questions. A common defence used by advisers is you did not ask us as we did not give our opinion or this is beyond our scope. Unfortunately this is not a good enough answer as the buck still falls on the practice. The fact your adviser did not tell you is not a defence. In simple terms why employ or contract doctors or providers if there are better ways to achieve the same objective? In this edition we will cover the most frequently asked questions and common mistakes such as: The 10 Most Frequently Asked Questions about employee and independent and/or contractor arrangements answered! INDUSTRIAL ISSUES: 1. I dont have to worry about the Fair Work Act or malpractice as I make our providers sign an Independent Contractors Agreement! This is not correct. In both cases the practice is 100% liable for all medico legal claims and may be subject to the Fair Work Act attracting fines up to $33,000 per breach. Using service agreements that treat doctors including GP Registrars as tenant doctors is an alternate solution we have detailed in this edition. There is no legal requirement for doctors to be employees in any legislation. A common misunderstanding is that independent contractors, (see The Independent Contractors Act 2006. http://bit.ly/rc6qJu) unlike employees do not have similar rights to employees under the Fair Work Act. This is incorrect as they have access to general protection such as the right to appoint representatives including unions and engage industrial dispute http://bit.ly/nlG52N . Furthermore because a practice is subcontracting their work then the practice and its directors/owners are 100% personally vicariously liable for any mistakes of any kind including not following up test results and patient notification. A practice was sued last year for $300,000 because a medical receptionist failed to update and correctly notify a HIV patient. The doctors were sued for $1,000,000. This is the real risk. 2. What is an employee, independent contractor and tenant doctor/provider? There are a number of indicators to help tell the difference between an employee and an independent contractor. We have also detailed what is a tenant doctor/provider as an alternative solution. Note: No single point below makes a person either an employee or independent contractor. Employees Master - Servant relationship do as you are told Perform work, under the direction and control of their employer, on an ongoing basis Generally work standard or set hours Bear no financial risk (this is the responsibility of their employer) Are entitled to have superannuation contributions paid into a nominated superannuation fund by their employer

Have income tax deducted from their pay by their employer Are paid regularly (e.g. weekly / fortnightly / monthly) Are generally entitled to get paid leave (e.g. annual leave, personal / carer's leave, long-service leave) if they are a permanent employee.

Independent Contractors or Contractors Subcontracts medical services to the practice, the practice on sells these services to the patient Decide how to carry out the work and what expertise is needed to do so Bear the risk for making a profit or loss on each job Generally pay their own superannuation and tax, including GST Generally have their own insurance Are contracted to work for a set period of time (for example, 2 months), or to do a set task Decide what hours to work to complete the job Generally submit an invoice for work completed or are paid at the end of the contract or project Do not get paid leave.

Tenant Doctor/Provider (sub contracts practice management services from the practice) There is a better way which is to use service agreements and get the practitioner to contract the practices management services on behalf of the practitioner. This is akin to running a serviced office on behalf of the treating practitioner. Contract the running of their practice to a practice that is called a service entity or trust which provides facilities, staff, systems and site goodwill for a percentage of the patients fee. This is usually called a service entity relationship. Most practices have a service trust or a derivative of this The patients are its customers and the practice is not the sole customer so the personal services income tax legislation that denies business deductions will not apply The practice bills on the treating providers behalf using the providers ABN on letter heads and tax invoices Decide how to carry out the work and what expertise is needed to do so Bear the risk for making a profit or loss on each job and are fully responsible for all conduct Generally pay their own superannuation and tax, including GST Generally have their own insurance Are contracted to work for patients and not the practice Decide what hours to work to complete the job Generally submit an invoice for work completed or are paid after providing medical services to patients Do not get paid leave

The downside to being an employee or independent contractor The practice must closely supervise daily all clinical and nonclinical activity Business tax deductions and 100% GST refunds on deductible expenditure are denied for example car, insurance and conference expenses Less freedom to practice Higher unnecessary legal and administration costs means less money Less freedom and flexibility to cash out. For example use cash to pay off nondeductible debt home loan because of forced superannuation savings and leave entitlements. Payroll tax liability and other employer on costs means the practice cant offer higher remuneration to the provider. Personal service income legislation will deny Independent Contractors some business deductions and unnecessarily force doctors to work in other locations resulting in poor continuity of care and inconvenience Higher administration, insurance and accounting costs reduces a practices ability to provide higher remuneration Less work flexibility Higher malpractice insurance premiums, medico-legal risks and industrial relation compliance obligations and risks may incur significant penalties. Opens the practice to industrial disputes and interference by unions, representatives and government agencies

MEDICO LEGAL ISSUES: 3. My insurance gives me enough coverage for employees, contract and GP registrar doctors you just are scare mongering? There are loop holes in your professional indemnity insurance contracts. Unless you see it in writing it does not exist. Relying on telephone advice from your medical indemnity organisation is not worth the telephone call. Expect to pay higher premiums for higher cover. You dont receive this by default. After closer reading of some of the major insurance funds we have found the following common Exclusion clauses. These insurance loop holes exist because many practitioners do not understand their existing legal and tax structure and/or do not adequately insure or asset protect. Most insurance contracts exclude: Directorships, Partnerships or Associateships, for example doctors who have listed their names on the same letter head and tax invoices, unless all doctors are with the same insurer. It is impossible to ensure all doctors are going to be with the same insurer; Medical Practice Company Directors who are not doctors e.g. spouses or unnamed Directors; Overseas trained / Employee Doctors & Contractors including those paid a percentage; Employee doctors will not have insurance if they are to be indemnified by their employer;

Agency relationships; Locums after a certain period; Practice staff that provide services to specialists and allied health workers; Practice staff if employed by a service entity (e.g. service trust or corporate) and not all doctors are directors or trustees of the service entity; Where there is a failure to check the doctor has malpractice insurance; and Internet or telephone advice, unless followed up by a face to face consult.

TAXATION ISSUES: 4. Are service trusts or entities the solution, the Australian Tax Office does not like them because they are used to avoid tax? Medico-legally and for succession planning purposes practices really have no choice but to use service trusts First of all, if the only reason you think you have a service trust is to dodge tax and this is your explanation when the ATO call, then expect to lose your tax audit. This is what they want to hear, or that my accountant set it up for me. These unfortunate statements are what unnecessarily attract a full scale tax audit. Yes there are tax benefits but they are incidental and not the main reason for using such a structure. The real reason is detailed below and should be committed to memory. Unfortunately many advisers are not aware of the succession planning argument. For asset protection and succession planning purposes, group practices have no choice but to use a service trust as a common entity that owns and runs the practice. The asset protection argument falls a bit thin if you have no real assets like a practice building being owned by the trust. We dont recommend this in any case. Service trusts are run by professionals such as doctors, accountants and lawyers. They operate as independent businesses owned by a company or trust. The entity usually owns most of the practice assets and employs staff, while the practice entity meets professional standards. The trust is usually owned by practice principals and charges for practice management services, equipments hire, branding rights, debt collection and premises. This is called a service fee. For medical practices it can be expressed as a percentage of gross receipts, for example 40%. Typically the entity packages and sells these services. A service agreement is entered into with each provider which is known as a tenant doctor/provider and a not contractor. Where there is a group of providers that do or dont own the practice, this is also sometimes referred to as an Associateship whether they are registrars or not. The main reason for a discretionary unit trust is because the alternative structures, such as a partnership or company, unnecessarily make the owners/partners/directors personally vicariously liable (i.e. responsible for each others malpractice mistakes) and they make profit sharing and succession planning very onerous on outgoing and incumbent owners. An associateship with the use of a service trust effectively carves out and/or reduces this responsibility and risk and significantly makes a practice easy to sell with the correct practice owner agreements in place. Contact us for more information about these template agreements that the practice can purchase.

Is it legal? Yes, these arrangements have been thoroughly tested in the High Courts and by the Federal Australian Tax Office over the last 30 years. Taxation Ruling TR 2006/2 and a booklet called Your Service Entity Arrangements NAT th 1308604.2006 has been issued on 20 April 2006: see http://bit.ly/qxhLfL Many advisers have been reluctant to use them because they are not aware of the non taxation benefits of the trust structure when used correctly. This is important because it does justify the legitimate commercial use of the structure which keeps the Tax Office off ones back and the taxation, risk and succession planning benefits can be preserved. 5. GP Registrars and Overseas Doctors do we really have to employ them and is there anything wrong with this? This has been the number one frequent question asked when employing, in particular GP registrars. The reason is because for commercial, and not legal reasons, various training programs (see http://bit.ly/nk4pt2) seek to enforce the GP Registrar Training Minimum Award conditions that are not legally enforceable under the Fair Work Act or the Medical Practitioners Award (the law does not recognise these well intentioned and possibly misguided organisations that are parties to these basic Award terms) unless you voluntarily agree to their terms. They are not mandatory. Some practices have argued they are being pressured by various training consortiums to enter into these arrangements or trainees will not be sent to them. This is another point to consider. This is a commercial and not a legal requirement. In fact, the less generous Medical Practitioners Award 2010 sets the legal minimum: see http://bit.ly/okr91Q. This should not be ignored or it will constitute a Fair Work Act breach if you employ or contract your doctors and do not use the alternative tenant doctor arrangements. The reality is there is a shortage of doctors and registrars. They are free to negotiate better terms as an employee, contractor or tenant doctor. Any arrangements should not affect the credentialing of the Registrars training program so long as it meets the training accreditation requirements which has nothing to do with how they are employed in the practice. Meeting these Basic Terms and Conditions are industrial relation claims. They do not have anything to do with clinical accreditation but a union requirement which is not mandatory. Practices would not be mistaken if they feel they are unnecessarily being pressured or poorly advised to undertake these arrangements. This edition rebuts many of the statements made by such organisations in the interest of clarity and ensuring sustainable arrangements continue to exist in practice, so excellent junior doctor training programs will prevail. 6. Can my service trust employ doctors? What are the tax and legal consequences? No. The basis of using any service trust is not to employ professional staff which includes GP registrars and overseas doctors. The Phillips case and Tax Office rulings specifically require non professional people to not be employed in the service trust. Accordingly patient fees should never be deposited into a service trust. There are no laws including immigration visa laws that prohibit overseas doctors or registrars from becoming self

employed doctors. Using a properly prepared service agreement arrangement is critical. Contact us to purchase our templates. The problem is if a practice employs professional people they end up tainting the service trust by employing and rendering services from this entity. The purpose for the trust for asset protection and succession planning is defeated and it throws into question the legitimacy of the structure. This means the next owner that buys into the practice as a director will automatically be liable for any malpractice claims up to 25 years that arises from an employee or contractor malpractice claim. We suggest doctors either employ these doctors directly in their own name or in a partnership and not practice company arrangement to avoid this problem. Ensure there is a service agreement and appropriate monthly administration with this entity as well. 7. Can owner doctors have a higher service fee percentage than the non owner doctors and will this be considered tax fraud? My adviser says this is dodgy. A common question is, can you justify owner practitioners say having a 60% service fee, when the arms length non-owners have a service fee of 40%? The simple answer is yes, you can even have a sliding scale of percentages and discount if a practitioner uses more sessional time. It is always useful to financially benchmark your practice. We can assist with our national benchmark series. This study investigates practice costs and the impact it has on ownership returns, pricing strategies and recruitment and retention. Most importantly it justifies any commercial arrangements to the Tax Office. One of the many rationales why owners have higher service fees is that they are subsidising the non-owners with a view to selling an interest in the practice. You cant sell a practice unless it makes a profit. Rental holidays and rent discounting is common place in shopping malls to attract tenants. A medical or healthcare practice is no different. The practice must have this strategy and document this in practice agreements that the objective is to one day sell their interest to non-owner doctors so this strategy is a teaser to securing the long term financial interests of the practice. Many do not realise this is a legitimate argument and can be a primary motive for service fee discounting. Practices should consult us before using this argument. The actual service fee rate can significantly vary from the Tax Offices rates according to the law. The bottom line is that there is no set legal allowable rate. It is against the Australian Constitution for the Tax Office to set a rate. For general practice, service fee rates can vary from 40% to 60% and some specialities up to 90% such as radiology where plant and equipment costs are very high. Specifically the Tax ruling states... It is not for the Commissioner to tell a taxpayer 'how to run his business profitably or economically': Tweddle v. Federal Commissioner of Taxation (1942) 180 CLR 1; (1942) 7 ATD 186 at CLR 7; ATD 190. The Commissioner must take the results of the taxpayer's activities as he finds them, regardless of whether those activities give rise to good or bad commercial outcomes. Charging low management fees to owners is fraught with danger as it makes a practice less profitable which then makes the practice more difficult to sell and harder to raise finance. More importantly this makes the practice insolvent. This is ironically not a commercial arrangement in itself which the Tax Office will prosecute. Telling a judge you are insolvent because the Tax Office told me is not a defence. Finally there is a Federal Court case that

prohibits a tax deduction for an expense where a business is not designed to make a profit Ell v. Commissioner of Taxation (10 February 2006). Unlike many advisers, we are confident because we have benchmarked over 1200 practices over 20 years and from this information we have prepared a 17 page commercial assessment to justify the higher rates to ensure the sustainability of a practice which are based on sound commercial reasons. The key is to ensure your adviser can provide a sound commercial reason and benchmark data to support the higher or lower service fees. Most have difficulty in this area and therefore are nervous to advise confidently in this area other than to follow the tax offices recommendations which are still not a safeguard if the appropriate agreements and systems have not been implemented. 8. Practice companies - do doctors/providers need one or use them with or without a service trust? No. This is a real problem for practices and doctors who use them. It is not necessary unless you like paying for accounting fees and payroll tax under the grouping provisions. The main reason for using a medical practice company was for asset protection and superannuation. Asset protection The corporate laws have lifted the corporate veil and avoiding lawsuits behind a $2 company is no longer legal. Patients can personally sue directors and can go after the family home. Superannuation In 2007 the superannuation laws were changed to allow self-employed taxpayers to have the same access to superannuation that employees have. Payroll Tax This is a tax many advisers are not aware of because it is a State and not a Federal Tax. In 2008 national payroll tax harmonisation laws was introduced: see http://bit.ly/r2YAQa. This applies in all States. The interpretation follows the NSW rulings in relation to medical practices see: http://bit.ly/nLPN3N. Simply, this means any remuneration paid from the service trust will be grouped with any practice company. Payroll tax from 4% to 6% will be charged to a doctors practice company. This will be a nasty surprise and it only affects doctors who own practice companies or employ people in their own name such as spouses that are outside the service entity structure.

ACCOUNTING & BOOKKEEPING ISSUES: 9. The Practice or Billing Entity has a Legal Responsibility when handling someone elses money. Dont bank patient money in the service trust. Our Doctors Pay Calculator service fee database program can get your paperwork right and leave an accurate audit trail where substance over form is everything when it comes to arguing with the Tax Office or with providers who want to challenge your calculations. Unfortunately Excel spreadsheets dont cut it anymore. It leaves the practice open to embarrassing errors and inefficiencies. More

importantly it messes up yours and the providers tax return and could cost everyone a lot of time and money to fix. Why? see below. In writing, by doing or saying you or the practice will handle or do the billing and/or banking of someones income on their behalf leads to a serious legal obligation to make sure it is right. A practice can be sued for negligence for not having the right system or procedures in place. The practice must account for every cent and is liable if money goes missing. In addition at the end of each BAS period and at the end of the financial year a practice must report to each provider (who are not employees or sub contractors): Gross Receipts/Billings GST Free and Not GST Free Pay 100% of all GST collected on behalf of the practitioner (depending on their arrangement) Issue a tax invoice for management fees charged and add 10% GST Issue an official amended tax adjustment invoice if there have been calculation errors. Many practices do not do this because it is time consuming and hard to do. Ensure that the correct amount has been collected on behalf of and paid to the practitioner by reconciling it with the practices bank account (MYOB/QuickBooks) NOT just the billing software and the practices calculations such as a spreadsheet. This last step is the one most overlooked or poorly administered.

By not having the right systems and procedures in place, this will lead to errors and possibly fraud. Additional accounting, taxation and BAS errors lead to additional accountancy fees, right through to practices possibly being sued for negligence for failing to have the right systems in place and for failing to properly account and report the correct information to a provider and the practice on a timely basis. At the end of the day practices should try and avoid putting themselves or their staff in a position which may leave open to question the practices own competency and accountability. It only takes one doctor to complain in the lunch room before everyone finds out and there is a confidence problem. Our Doctors Pay Calculator program solves this problem see http://bit.ly/nznQUv . 10. Should you rely on the government unions or representative organisation for advice? Are there any limitations? What should you do? There is no legal requirement for practices to follow or abide by unions or representative employer organisations to comply with industrial relations. Many are trying to generate new work under the guise of enterprise bargaining agreements which is entirely a voluntary process. So long as practices have secured in writing that they are meeting minimum standards they need not concern themselves with any over award ambit claims. Practices can purchase a cost effective employment kit with employment templates, job descriptions, restraints and
occupational health and safety agreements for doctors, allied health, nurses, practice managers and administration staff. The kit offers tips and explanations so you can do this yourself with your staff

without being intimidated by external third parties: see http://bit.ly/ixOZV2 information.

for more

The biggest concern is if any confidential negotiations do fail after disclosing your sensitive work arrangements with these representatives, will this information be forwarded to the Fair

Work Ombudsman for resolution? Remember at the end of the day the buck stops with the practice and not any representative or union. The chances anybody will sue them for getting it wrong is very low, the unnecessary disruption to deal with expensive ambit claims can be very high no matter who is representing you and it can cause irreversible damage to staff morale.

Where to from here? REMEMBER GET ALL ADVICE IN WRITING AND DONT RELY ON HEARSAY ADVICE. Your advisers may feel a little outside their depth. If they are, contact us for specialist expertise in this area if you require service and practice agreements or require more information about our Doctors Pay Calculator Tax Invoice program and/or our annual practice benchmarks. For a confidential and no obligation chat, let us know if you require any assistance call us on 1800 077 222 or email David Dahm at pa@healthandlife.com.au . Which topics would you like to be covered? If there is a particular topic that you would like covered in one of our future News Alerts, please email pa@healthandlife.com.au and let us know what it is. We will then endeavor to cover your requested topic. Do we have your email address? It is apparent in feedback we are receiving that there are persons receiving this regular email who are not on our email list. If you are receiving this email second-hand from another source, we would be delighted to receive your email address and we will add you to our database so that you can receive it first-hand on the day it is sent. This invitation is open to all Practices. Please send your email address to pa@healthandlife.com.au. Do you wish to unsubscribe from our list? Please email pa@healthandlife.com.au if you wish to be removed from our distribution list.

Copyright Notice 2011 This email, including any attachments, is for the personal use of the recipient(s) only. Republication and re-dissemination, including posting to news groups or web pages, is strictly prohibited without the express prior consent of Health & Life Pty Ltd. Disclaimer Notice Health & Life Pty Ltds Best Practice News Alert is designed as a comprehensive and up-todate Accounting, Practice Management and Healthcare news service to alert readers to the latest in Practice and related developments affecting the medical, dental and allied health professions as they happen. It is published when there is news to report. No responsibility can be accepted for those who act on its content without first consulting us or obtaining specific advice. Health and Life Pty Ltd

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Which topics would you like to be covered? If there is a particular topic that you would like covered in one of our future News Alerts, please email pa@healthandlife.com.au and let us know what it is. We will then endeavour to cover your requested topic. Do we have your email address? It is apparent in feedback we are receiving that there are persons receiving this regular email who are not on our email list. If you are receiving this email second-hand from another source, we would be delighted to receive your email address and we will add you to our database so that you can receive it first-hand on the day it is sent. This invitation is open to all Medical Practices. Please send your email address to pa@healthandlife.com.au. Do you wish to unsubscribe from our list? Please email pa@healthandlife.com.au if you wish to be removed from our distribution list. Copyright Notice 2011 This email, including any attachments, is for the personal use of the recipient(s) only. Republication and re-dissemination, including posting to news groups or web pages, is strictly prohibited without the express prior consent of Health & Life Pty Ltd. Disclaimer Notice Health & Life Pty Ltds Best Practice News Alert is designed as a comprehensive and up-to-date Accounting, Practice Management and Healthcare news service to alert readers to the latest in Practice and related developments affecting the medical, dental and allied health professions as they happen. It is published when there is news to report. No responsibility can be accepted for those who act on its content without first consulting us or obtaining specific advice.