Since the agency’s formation in 2011, IHPA’s accountable authority has established a robust system of risk management and controls to assist in the governance of the agency.
The Pricing Authority delivers the functions defined in the National Health Reform Act 2011. The Pricing Authority approves IHPA’s core business activities—determination of the national efficient price and the national efficient cost for public hospital services annually, and building national classification systems for all hospital services. The Chief Executive Officer is responsible for IHPA’s day‑to‑day administration.
IHPA’s enterprise approach to risk management remains with the administration of risk, using tools that address the strategic and tactical risks of all significant decisions. IHPA updated its risk management framework and developed a detailed risk appetite statement, which is reviewed annually.
Strategic risks are identified with reference to current business and environmental issues facing IHPA. These risks fall into three major risk categories:
- reputational risks
- data and information governance risks
- corporate risks.
Additionally, IHPA developed a shared Strategic Risk Register with the National Health Funding Body, which identified two risks that both agencies have agreed to manage jointly:
- incorrect calculation of Commonwealth funding entitlements
- changes to models that have not been effectively modelled and/or implemented.
IHPA’s strategic risks are actively managed through audits, assurance, and internal control processes. Where new risks emerge, resources are assigned to understand and manage those risks. They are reviewed bi‑annually or as required.
Tactical risks are managed through a decision‑based risk management tool, which requires recording of the risk and a formal decision on the managed likelihood and consequence of the risk. The assessment tool forms part of any major decision, ensuring that the final decision maker is fully informed and cognisant of managed risk outcomes during the decision‑making process.
IHPA has a mature enterprise risk management framework in place, and risk management is considered a business‑as‑usual activity for all IHPA staff.
During the period of this annual report, IHPA closely monitored and managed the operational and technical risks associated with the COVID-19 pandemic.
IHPA has a broad range of compliance obligations, including key statutory obligations set out in the National Health Reform Act 2011 and the National Health Reform Agreement, the Public Governance Performance and Accountability Act 2013, and the Public Governance Performance and Accountability Rule 2014.
Other legal and compliance obligations include, work health and safety, privacy, freedom of information, intellectual property, the Protective Security Policy Framework, website accessibility and records management.
The Chief Executive Officer as the accountable authority receives management assurances on IHPA’s compliance obligations through an organised system of controls and special exercises, including substantive testing, monthly reports, exception notifications, and compliance audits undertaken by an independent internal auditor.
Compliance achievements during the year include:
- IHPA’s internal compliance audits continue to show that information and communications technology systems were assessed as appropriately addressing the top risks defined by the Australian Signals Directorate.
- No compliance issues arising from IHPA’s administration of relevant sections of the National Health Reform Act 2011.
- No material compliance issues emanating from the Public Governance Performance and Accountability Act 2013.
As a corporate Commonwealth Agency, IHPA is not required to adhere to the Commonwealth Procurement Rules, but chooses to do so as a matter of best practice. All IHPA’s procurement decisions are made in accordance with the Commonwealth Procurement Rules. Line managers have value and purchase class limits in accordance with the delegation of financial authorities that is approved and reviewed regularly by the Chief Executive Officer, as the accountable authority.
Audit, Risk and Compliance Committee
The IHPA Audit, Risk and Compliance Committee provides independent advice to the Chief Executive Officer on managing IHPA’s financial and business risk.
During the reporting period, members of the Audit, Risk and Compliance Committee comprised:
- Mr Robert Butterworth, Chair and Independent member
- Ms Angela Diamond, Chair and Independent member
- Mr Alan Bansemer, Independent member
- Mr Glenn Appleyard, Member of the Pricing Authority.
The IHPA Audit, Risk and Compliance Committee met on three occasions between 1 July 2019 and 30 June 2020. The Chief Executive Officer, James Downie, as the accountable authority, attended all three meetings.
Details of Audit, Risk and Compliance Committee during the reporting period (2019–2020)
Qualifications, knowledge, skills and experience
Number of meetings attended/
total number of meetings
Total annual remuneration
Robert Butterworth is a retired Australian Public Service (APS) officer. His career in the APS spanned 32 years including 23 years at Senior Executive Service (SES) level and 17 years as a Band 2. Robert has held SES positions in the three central agencies of Finance, Prime Minister and Cabinet and the Treasury, and in the Environment Department. He has also worked in the Canadian and Papua New Guinea civil services. His most recent position was Division Manager of the Asset Sales and Shareholder Division in the Department of Finance and Deregulation.
Robert was Chair of the Comcover Advisory Board and Chair of the Audit and Risk Management Committee of the Migration Review and Refugee Review Tribunals. In addition, he has also been a member of the Building and Construction Code Monitoring Group and the Sydney Harbour Federation Trust Audit and Risk Management Committee.
Robert also undertakes short-term contract work assignments in the APS, including assurance reviews for the Department of Finance.
Robert has an Honours degree in Economics from the University of Sydney and a Graduate Diploma in Economics from the Australian National University.
Angela Diamond has held several senior finance positions within the public service including First Assistant Secretary Financial Performance and Management at the Department of Defence and is currently the Chief Financial Officer for Services Australia.
Angela has a Bachelor of Commerce from the Australian National University and is a Certified Practising Accountant (CPA).
Glenn Appleyard was a member of the Australian Accounting Standards Board from 1 January 2003 to 31 December 2011.
Glenn has held several senior positions within the public service including Deputy Secretary in the Tasmanian and Victorian Departments of Treasury and Finance, Regional Director for the Australian Bureau of Statistics in Tasmania.
He was a member of the Commonwealth Grants Commission for 11 years and was the Chair of the Tasmanian Economic Regulator.
Glenn has been a member of the Independent Hospital Pricing Authority since 2012.
Glenn has a Bachelor of Economics from the University of Tasmania and is a Graduate Member of the Australian Institute of Company Directors.
Alan Bansemer has over 35 years’ experience in the health sector, including six years as the West Australian Health Commissioner and eight years as the Deputy Secretary to the Commonwealth Department of Human Services and Health (as it then was).
Alan has chaired a number of committees including the Medicare Schedule Review Board and General Practice Consultative Committee. In addition, he has served as a member of numerous health advisory committees including the Australian Health Ministers’ Advisory Council, Health Insurance Commission (now Medicare Australia) and the Australian Institute of Health and Welfare.
Alan has a bachelor’s degree in economics from the University of Adelaide and postgraduate diploma in business administration from the South Australian Institute of Technology.
Fraud control plan
IHPA’s fraud control plan is recognised as a critical internal tool used to mitigate the act and consequences of authorised use of IHPA data and financial resources. It was updated in October 2018 to incorporate changes to the Commonwealth Fraud Control Framework. The plan encourages ethical behaviour through use of business processes designed to prevent deceptive activities, supported by monitoring controls to detect fraud and deter offending behaviour, and is reviewed annually or as required.
Inter-agency financial activity
During the 2019–20 financial year, IHPA received shared services resourcing from the Department of Health.
The Department of Health charged IHPA $374,000 to provide these services covering treasury, processing of financial transactions, information and communication desktop services, and parliamentary support.
Ecologically sustainable development and environmental performance
IHPA does not undertake any substantive work that is covered by s. 516A of the Environment Protection Act 1999.