SA Single Employer Model (SEM)

The Single Employer Model (known as SEM) is a Commonwealth initiative that allows Rural Generalists and General Practice trainees to be employed by a single employer for up to four years while they complete their training in primary care and hospital settings.

The first Commonwealth-supported SEM trial was initiated by the Murrumbidgee Local Health District (MLHD) in New South Wales (NSW) and commenced in late 2020. A second trial commenced in December 2022 in the Riverland Mallee Coorong Local Health Network (RMCLHN) region in South Australia (SA).

The SEM enables GP/RG registrars to be employed by one employer under one contract, throughout their GP/RG training, and advanced skills training. This allows trainees to accrue and access employee entitlements (such as personal leave, recreation leave and parental leave), increased certainty of training arrangements including better mobility between public and private as well as a fixed salary that does not depend on their MBS billings. Both rural and metropolitan GP trainees generally need to leave public sector employment during their required training periods in private general practice which results in them losing their entitlements.

As part of the Commonwealth SEM trial, the General Practice trainee is allowed to bill Medicare whilst in the practice. Part of this revenue is retained by the General Practice to ensure all overheads are covered, and a portion is provided to the employer of the trainee to offset the trainee’s salary.

The Commonwealth will provide exemptions under subsection 19(2) of the Health Insurance Act 1973, which will allow the trainees to bill Medicare for eligible services provided during their training placements at the participating General Practice.

The SEM trials aim to improve the attractiveness of GP/RG training and increase the availability of high-quality comprehensive care in Australian communities. By participating in the trial, trainees will minimise the need to source and relocate for training placements, finding suitable supervision, negotiating contracts, concerns about work and leave entitlements, allowing them to focus on their training and providing care to the patients in the district.

Having the ability to undertake their full training in a co-located geographical area also allows them to build deeper and longer lasting connections into these communities and increases the retention of doctors to rural locations.

The SEM Trial will be delivered through a collaborative effort between the Rural Support Service and their Rural Generalist Coordination Unit under the Rural Generalist Program South Australia (RGPSA), the regional LHNs, the State and Federal governments, and local stakeholders including GP clinics. This will enable broad state-wide oversight of all placements within the rural generalist training pipeline.

Under the new trial, Rural Generalist and Rural GP trainees participating in the SEM trial can have the same single employer (in this case the regional LHN as SA Health) for the entire duration of their training and contract term, even when undertaking GP training in private primary care clinics. SA Health through the regional LHNs will be responsible for the salary, leave entitlements, tax, superannuation, workers compensation, premiums, allowances, and benefits. This also means they’ll retain their employment entitlements which accrue over time, including sick leave and parental leave.

For the periods that the trainee spends in general practice, there will be a defined SEM Clinical Placement Agreement (CPA) between the General Practice and the regional LHN, which sits underneath the Memorandum of Understanding Agreement (MoU) between the Commonwealth and State. These governing documents describe the financial, employment, O&WHS, and other arrangements around the trainee while on placement and under the supervision of the General Practice.

As part of the Commonwealth SEM trial, the General Practice trainee is allowed to bill Medicare under the section 19(2) exemption Direction issued by the Commonwealth whilst working in the GP Practice. Part of this revenue is retained by the General Practice to ensure all overheads are covered for hosting the trainee, and a portion is provided to the regional LHN to offset the trainee’s salary.

No. Participation in the SEM trial is opt-in for GP Practices and potential SEM RG/GP trainees.

Voluntary participation is a critical element of SEM trials, for both registrars and primary care practices.

The focus of the new SEM trial will be on regional, rural, and remote locations, supporting the growth of rural generalism and addressing primary health care challenges.

The trial will provide geographical coverage of the following South Australian regional LHNs:

• Barossa Hills Fleurieu Local Health Network
• Eyre and Far North Local Health Network
• Flinders and Upper North Local Health Network
• Limestone Coast Local Health Network
• Yorke and Northern Local Health Network

This new SEM trial is intended to demonstrate the benefits of a SEM trainee distribution program, linked to the Rural Generalist Program South Australia (RGPSA) and more broadly for example activities being undertaken by Consortium for General Practice Workforce Planning and Prioritisation (WPP).

The Riverland Mallee Coorong Local Health Network has it’s own SEM trial that commenced in 2022 through the Riverland Academy of Clinical Excellence.

We want to locally grow Rural Generalists who provide primary care as rural GPs with advanced skills that are needed by the communities they serve.

The main objective of the SEM trial is to address the inequity in trainee salaries and entitlements for GP registrars and their hospital-based peers. It’s intended the SEM trial will contribute to building a more sustainable primary health care workforce into the future, with only 13% of medical students in Australia currently seeking a career in general practice.

The SEM trial will particularly support the expansion of medical training pathways and is expected to assist SA in attracting rural medical trainees to regional based training programs through the delivery of the following objectives:

• Building a skilled workforce
• Expand medical training pathways in regional and rural South Australia
• Increase the number of doctors entering rural medical training and practice
• New and sustainable models for rural health care
• Develop sustainable models of rural medical care
• Increase support to rural general practitioners
• Developing a collaborative and co-ordinated health system
• Share the responsibility for rural health across the state
• Collaborate to support the sustainability of the rural workforce.

Implementation of the SEM trial will address the following workforce challenges:

• Enable trainees to be employed by SA Health as their single employer for the duration of their GP training, providing employment and wage continuity. RG/GP trainees need to leave public sector employment during their required training periods in private general practice, resulting in loss of entitlements and limited access to extended leave including sick and parental leave.
• Registrars will have certainty about their work region/location, income and working conditions for the duration of their training and enable them to build community connections.
• Training under SEM in a region will progress flow through of the training pipeline by improved retention of trainee GPs as they progress through post graduate rotations, GP training terms, advanced skills training and on to Fellowship.

Anticipated benefits from the SEM trial to patients and rural communities, include:

Workforce

• GP/RG attraction and retention, increasing the number of GP/RGs working rurally and in their respective training regions
• Long term engagement between trainees and rural employers
• SEM trainees and subsequently graduates work across both hospitals and primary care
• GP/RG trainees become an integral part of the regional health service

Regional Health Service Delivery

• Trainees better able to establish longer term community connections and continuity of care with their patients
• Access to emergency care improved by increasing regional workforce
• Reduced waiting times for outpatient or procedural services
• Increase communication between primary and hospital care, potentially reducing hospitalisations and improving effectiveness of care
• Potential cost savings due to decreased hospital utilisation, and in the medium to longer term through the reduction in locum requirements
• Increase distribution of workforce
• Long term health status of rural communities is improved.

Section 19(2) of the Health Insurance Act, 1973 precludes state-employed medical practitioners from utilising Medicare Benefits for non-admitted, non-referred professional services unless an exemption applies.

The South Australian Department of Health has a Memorandum of Understanding with the Commonwealth Government that will enable trainees on the Single Employer Model trial to utilise a section 19(2) exemption. This means RG/GP registrars participating in the SA SEM trial where the regional LHN acts as the single employer for the duration of training, allows the GP/RG trainee to bill Medicare for their work in private agreed and eligible GP Practices for the duration of their training.

All eligible GP Practices across the 5 regional LHNs, who have indicated their interest in participating in the SEM trial will be publicly listed in a s19(2) Direction issued by the Commonwealth and made available to potential SEM trainees.

The s19(2) exemption only allows state-employed GP/RG trainees participating in the SEM trial and in an eligible training pathway (GPT, ACRRM, RACGP, RVTS, RGTS) at PGY3 level and above to claim MBS items for services while undertaking general practice rotations.

The s19(2) exemption is granted to the specific participating GP Practice where the trainee will undertake their training. The Commonwealth will grant the s19(2) exemptions to the sites nominated in the approved proposal, and subsequent to the MoU established between the regional LHN, the SA Government’s Department of Health and Wellbeing and the Australian Government’s Department of Health and Aged Care.

The s19(2) exemption is not granted to the individual trainee.

No, the Commonwealth has confirmed the s19(2) exemptions that Aboriginal Community Controlled Health Organisations (ACCHOs) already have can be used for the Single Employer Model trials and those locations do not need to be separately listed on the SEM s19(2) exemption Direction approved by the Commonwealth.

GP practices interested in participating in the SEM trial will be required to have the capacity and infrastructure to accommodate a GP/Rural Generalist trainee and be able to provide appropriate supervision both in the practice and the local hospital.

GP Practices will need to meet the following Commonwealth requirements to participate in the SEM trial and be eligible for a section 19(2) exemption:

• Located in a Modified Monash Model 2-7 location

Be accredited for training with ACRRM and/or RACGP

• Need to have supervisor accreditation by training colleges, ACCRM or RACGP
• Provide a willing supervisor with capacity to provide appropriate and approved supervision for training pathway requirements
• Provide a good training and education experience that meets the College curriculum
• Participation in the SEM trial by the GP Practice is on an entirely voluntary basis
• GP Practice is not disadvantaged by participation or non-participation in the trial, financially or otherwise

The training colleges (ACRRM and RACGP) are responsible for accreditation requirements. Primary care providers that aren’t accredited will need to work with the relevant college with regards to the process for meeting accreditation requirements.

In addition, GP Practices need to meet and carry out any requirements as outlined in the Clinical Placement Agreement (CPA) which will be in place between the regional LHN and GP Practice as host of the SEM trainee.

A list of primary care clinics participating in the SEM trial and granted a s19(2) exemption will be made available on the RGPSA – Single Employer Model (SEM) website page once these have been confirmed.

Interested GP Practices can contact the RGPSA or the Medical Education Units in their respective regional LHN.

Registrars interested in participating in the SA SEM trial need to be formally enrolled in either of the two recognised general practice qualifications, Fellowship of the Australian College of Rural and Remote Medicine (FACRRM) and the Fellowship of the Royal Australian College of General Practitioners (FRACGP or FRACGP-RG). Both fellowships lead to vocational recognition and registration under the Specialist (General Practice) category with the Medical Board of Australia.

The trainee must be enrolled in one of the following relevant programs:

• Australian College of Rural and Remote Medicine (ACRRM) Independent Pathway
• ACRRM Rural Generalist Training Scheme
• ACRRM Australian General Practice Training Program
• ACRRM Independent Pathway
• Royal Australian College of General Practitioners (RACGP) Australian General Practice Training Program
• RACGP Fellowship Support Program
• Remote Vocational Training Scheme.

SEM placement opportunities will be advertised at participating regional LHN locations throughout the year. The employing regional LHN, in consultation with the GP training colleges, GP practices will manage your rotations to make sure you meet your training requirements. You will complete GP training in ACRRM and RACGP accredited practices participating in the SA SEM trial.

You may have the opportunity to rotate to other rural local health districts to undertake advanced skills training.

Yes. Participation in the SEM trial will be available to trainees at PGY3 level and above who are starting or have already commenced their GP/RG training.

Yes, participation in the SEM trial will be available to trainees who are starting or have already completed some components of their GP/RG training. Participants will be offered at a minimum a 3-year contract (as per the SA Health Salaried Medical Officers Enterprise Agreement 2022 and the South Australian Medical Officers Award) and a maximum of 4-years depending on the stage at which they join the SEM trial. A shorter duration can be negotiated on request by the Registrar.

The state-employed GP/Rural Generalist trainees will be required to be in an eligible training pathway at PGY3 level and above to claim MBS items for services under the section 19(2) exemption Direction issued by the Commonwealth while undertaking general practice rotations.

Currently lateral entry is permitted, this is subject to change and may not be a future feature of the program as it becomes established.

SEM placement opportunities will be advertised at participating regional LHN locations throughout the year. The employing regional LHN, in consultation with the GP training colleges and GP practices  will manage your rotations to make sure you meet your training requirements. You will complete GP training in ACRRM and RACGP accredited practices participating in the SA SEM Trial.

You may have the opportunity to rotate to other rural local health districts to undertake advanced skills training.

Yes, participation in the SEM is optional and trainees can leave at any time (on agreement with the GP practice if part way through a rotation).

As the registrar’s salary and wages are paid for by the regional LHN as the employer of the registrar, an agreed percentage share of the revenue generated through Medicare billing (i.e. total receipts regardless of gap fees) will be allocated between the GP Practice and the regional LHN as outlined in the Clinical Placement Agreement (CPA) between the two parties to cover the costs of the GP Practice in hosting the registrar and as a cost recovery for the regional LHN towards the registrar’s salary and wages.

GP Practice will continue to receive and retain Practice Incentives Program (PIP) and Workforce Incentive Program (WIP) payments if eligible.

The Medical Practice will retain 100% of all teaching and supervision payments facilitated through Services Australia and linked to identifiers such as location specific Medicare Provider Numbers.

All working conditions; including classification, hours of duty, on call, additional shifts, leave and entitlements are as per the SA Health Salaried Medical Officers Enterprise Agreement 2022 which is underpinned by the South Australian Medical Officers Award.

There are two options for maintaining additional skills while working in the community:

One option is to work part-time in your area of additional skill and part-time in community general practice and this can be incorporated into a Single Employer Model Contract, for example, 60 hours of community general practice and 20 hours of emergency medicine.

A second option is to work in community general practice and undertake casual shifts in your additional skill.
Please note you cannot be provided a contract that is more than 1 FTE or 80 rostered hours per fortnight. For people seeking to undertake casual shifts to maintain additional skills on top of full-time general practice, the additional hours worked would be recorded on your timesheet and paid as overtime. Monitoring of these hours would be required to ensure safe work hours and sufficient rest periods are maintained.

LWOP would be by negotiation with the GP Practice and the regional LHN as employer. For additional information please refer to the SA Health Salaried Medical Officers Enterprise Agreement 2022 which is underpinned by the South Australian Medical Officers Award.

GP training and accreditation is run by the Training Colleges, ACRRM and RACGP; there will be no changes in the training and education of general practice selection, and trainee progression remains with the GP supervisors and Colleges; there will be no additional requirements.

Registrars that don’t progress will be managed the same way as they are currently.

Indemnity insurance is covered in the Clinical Practice Agreement (CPA) under Clauses 25 & 26 of the agreement. General Practices participating in the SEM trial need to hold their own relevant insurance. There is no cost or requirement for the GP Practice to hold additional indemnity insurance for the SEM trainee which is covered by the South Australian Government Captive Insurance Corporation (SAICORP). GP Practices are expected to hold responsibility for their components of services, such as holding appropriate indemnity insurance for GP supervisors who are supervising clinical practice.

Registrars participating in the SEM trial will be instructed to apply for indemnity and legal assistance in accordance with Employment Directions, as is the current practice for all trainee medical officers.

The employing regional LHN, in association with the trainees’ GP colleges (ACRRM and RACGP for advanced skills training), will manage trainee rotations including trainee administration, payment of salary and management of leave.

When the RG/GP SEM trainee is undertaking a GP rotation, the nominated GP Practice is responsible for providing appropriate supervision by an accredited supervisor for the ACRRM or RACGP training program, or both, and consistent with ACRRM and RACGP requirements.

The GP trainees’ duties will be the same as those of other GP trainees.

Yes. Medicare Provider Numbers (MPN) are location specific and an application for a separate MPN will have to be submitted at each GP Practice.

No, your Medicare billings will be split between the regional LHN (your employer) and your GP Practice. If you choose to be a participant of SEM, you will receive a salary and other entitlements such as annual and sick leave; the % of your billings that will be paid to the regional LHN will be used towards your salary.

Trainees will undertake training in participating eligible GP practices, hospitals, Multi-Purpose Services (MPS) and AMS within the employing regional LHN in Modified Monash 2 to 7 locations.

There may be opportunities for trainees to undertake rotations to positions in other regional LHNs.

Yes, you can access salary packaging as you are a SA Health employee working in a regional LHN.

Yes, the SEM Pilot is statewide, so moving to another Practice would be possible. providing that the primary care provider you are undertaking placements at are a participating eligible and approved SEM GP Practice and are listed on the current s19(2) Direction.

Please note, Aboriginal Community Controlled Health Organisations that have their own s19(2) Directions and exemptions do not need to be listed on the SEM s19(2) Direction separately. Doctors participating in SEM can also be employed under the SEM pilot at these Practices if they agree to participate.

RG/GP registrars may be required to undertake placements at multiple primary care providers to complete their training requirements. The registrar can exit the SEM trial training program if they wish to be placed in a practice that is not accepting SEM trainees. This will result in their employment with SA Health/regional LHN ceasing and they will have their entitlements paid out upon required notice being provided.

Yes, some entitlements may transfer. Speak with your employer to obtain assistance and advice for your personal circumstances.

Yes. When trainees participating in the SEM Trial undertake a GP practice rotation, they will be supervised by a GP at the practice who is an accredited supervisor for the ACRRM and/or RACGP training program.

GP supervisors will receive supervision payments under the National Consistent Payments Framework for AGPT registrars as is the same for other AGPT registrars. The Department of Health and Aged Care has advised that both Colleges have been notified that exemptions will be provided under the NCP Framework for those practices and supervisors who: are involved in the SEM trials and are providing GP training to AGPT registrars, as part of the College supported GP training program.

If a trainee is not AGPT, for example, ACRRM independent pathway, supervisors will not receive payments for practice supervision.

Yes, they are included in the recruitment target/cap.

Doctors recruited to the SA SEM Trial are registered trainees with either ACRRM or RACGP working towards Fellowship of the College. The trainee must comply with the relevant colleges training requirements.

Depending on the trainee’s level of training and which College they are training with, the allocation of time dedicated to these hours will vary.

For more information, please visit the training college websites: ACRRM and RACGP

Participation in the SEM may be for the duration of the RG/GP registrars entire training time and encompasses rotations within both the hospital and primary care provider to meet GP college training requirements.

Both the regional LHN and the GP Practice where the trainee is doing their placement are responsible for the RG/GP registrar meeting the relevant GP college training rotations and requirements as per the current existing arrangements.

Both rural and metropolitan GP trainees generally need to leave public sector employment during their required training periods in private general practice. This results in them losing their entitlements and in particular, limited access to extended leave including parental leave.

Under SEM, Rural Generalist and GP trainees will have the same employer (the regional LHN) for the duration of their training. This means they’ll retain their employment entitlements which accrue over time, including sick leave and parental leave.

A single employer model is recognised as a potentially useful tool in attracting future rural GP and Rural Generalist trainees. It’s intended outcome is to give trainees certainty about location, income and working conditions such as work hours, on-call obligations, and leave entitlements including long service and maternity leave.

The model doesn’t replace current employment models for Rural Generalist and GP trainees; it’s in addition to existing options.

A SEM should be optional for GPs in training and will be set up as an opt in. Rural registrars will have a choice.

These expanded SEM trials benefit communities by creating secure training opportunities for GP/RG registrars, who will be able to complete their training under one employer across a range of local settings, and more easily accrue employment benefits

We believe this is a vitally important step forward to attract and incentivise medical graduates into general practice, particularly in the context of the recent commitment at the Federal Health Minister’s meeting for the development of General Practice Attraction Strategy.