National Health (IVF Program) Special Arrangement 2025

Key legal and pricing concepts are defined or operationalised in the instrument. Understanding them is essential to applying the instrument consistently.

• Special arrangement supply. The core concept is defined by operational criteria: supply must be to a person receiving IVF treatment from an accredited ART centre and must be made on the basis of a prescription by a medical practitioner practising for that centre (s 6, definition of special arrangement supply; s 5 simplified outline). This restricts availability under the arrangement to the ART‑treated cohort and to prescriptions issued by practitioners attached to those centres.
• Approved suppliers and approved hospital authorities. The instrument uses the Act’s defined classes of supplier: approved hospital authority, approved pharmacist, approved medical practitioner and approved supplier (s 6 definitions). These labels determine which dispensed price rules and payment entitlements apply (Parts 2 Divs 1 and 2).
• Dispensed price. The instrument defines “dispensed price” for special arrangement supplies separately depending on the supplier type. For approved hospital authorities for public hospitals the dispensed price equals the sum of the applicable approved ex‑manufacturer price (AEMP) or proportional ex‑manufacturer price (PEMP) for pack quantities, adjusted for broken quantities (s 9). For other approved suppliers the dispensed price adds, where applicable, a ready‑prepared mark‑up and a ready‑prepared dispensing fee (s 12). Rounding for dispensed prices is to the nearest cent (ss 9(3), 12(3)).
• Pack quantities and broken quantities. The instrument uses “pack quantity” (as defined in Part VII of the Act) and prescribes the method for valuing broken quantities: divide the broken quantity by the pack quantity, express as a percentage to two decimal places, and apply that percentage to the AEMP or PEMP (s 9(2); s 12(2) when mark‑ups apply). This fixes a proportional approach to partial packs.
• Ready‑prepared pharmaceutical benefits and mark‑ups. The instrument recognises a subset of IVF benefits as ready‑prepared pharmaceutical benefits (definition cross‑referenced to the National Health (Listing of Pharmaceutical Benefits) Instrument 2024). For such items, approved suppliers other than approved hospital authorities for public hospitals may add a mark‑up per pack quantity, computed according to the tiered table in s 13. The table ties the mark‑up to the AEMP/PEMP for the maximum quantity and specifies percentage or dollar‑amount mark‑ups depending on price bands.
• CTG Special Arrangement interaction. Supplies to CTG registered patients are subject to certain CTG Special Arrangement provisions, with modifications (Part 3, s 15). The instrument preserves CTG co‑payment reductions etc., but modifies references and excludes the CTG notes to subsections 11(2) and (3) for these supplies; claims for payment for special arrangement supplies are handled under s 16, not under CTG notes (s 15(2)‑(4)).
• Claims requirements. A claim for payment must include the RTAC Accredited Unit number of the accredited ART centre for which the prescribing medical practitioner was practising, and, for manual claims in respect of CTG registered patients, an indicator that the supply was to a CTG registered patient (s 16). Section 16 operates in addition to s 99AAA of the Act.

These concepts together set who is eligible to supply and be paid, how price is computed for full packs and broken quantities, where mark‑ups and dispensing fees are permitted, and how CTG interactions and claims administration must be handled.

This instrument affects a defined but multi‑party set of actors within the IVF delivery, pharmacy and health payments ecosystem.

• Patients receiving IVF treatment from accredited ART centres. Only those patients qualify for IVF pharmaceutical benefits under this special arrangement. The instrument’s eligibility is explicitly limited to persons receiving treatment from an accredited ART centre and with a prescription from a medical practitioner practising for that centre (s 6 definition; s 5 simplified outline). Patients receiving medication outside an accredited ART centre are not within the special arrangement’s supply definition.
• Accredited ART centres and their medical practitioners. An ART centre’s accreditation is material because the RTAC Accredited Unit number must be used in claims (s 16). A prescription must be issued by a medical practitioner practising for an accredited ART centre for a supply to qualify as a special arrangement supply (s 6 definition). The instrument therefore channels prescribing authority for these benefits to practitioners attached to accredited ART centres.
• Approved hospital authorities (public and private). Hospital authorities approved under Part VII of the Act that govern public or private hospitals may make special arrangement supplies in or from their hospitals (s 7). The instrument sets separate dispensed price and payment rules for approved hospital authorities for public hospitals (Part 2 Div 1, ss 8−9) and private hospitals (s 11).
• Approved pharmacists and approved medical practitioners operating outside public hospital authorities. These suppliers are entitled to payment under s 10 for special arrangement supplies they make, subject to s 99AAA of the Act and conditions determined under s 98C. For suppliers other than approved hospital authorities for public hospitals, s 12 and s 13 determine dispensed price computation including permissible mark‑ups for ready‑prepared items and a ready‑prepared dispensing fee.
• The Commonwealth and administering agencies. The Commonwealth’s payment exposure is defined in ss 8, 10 and 11 as the amount by which the dispensed price exceeds the amount suppliers are entitled to charge under s 87 of the Act. The instrument also modifies how CTG Special Arrangement rules apply to CTG registered patients (s 15), thereby affecting Commonwealth co‑payments and payment flow for that cohort.
• Pharmaceutical suppliers and manufacturers. The Schedule 1 list specifies the drugs, forms, manners of administration and brands that are IVF pharmaceutical benefits under the instrument (Schedule 1). Manufacturers and suppliers of those brands will be affected by volume changes induced by eligibility rules and pricing treatment.
• Claims processors and remuneration administrators. Claims must include RTAC Accredited Unit numbers (s 16) and CTG indicators for manual claims. The instrument’s structure requires administrative systems to validate RTAC numbers, apply different dispensed price rules by supplier type, calculate broken quantities and apply mark‑ups per s 13’s table.
• The coordinated CTG program stakeholders. CTG registered patients and providers engaged with Closing the Gap arrangements are expressly included but subject to modified CTG treatment for these supplies (Part 3, s 15).

Who does not qualify under the arrangement is also important. The instrument excludes supplies unless both elements of the special arrangement supply definition are met: the recipient must be receiving IVF treatment from an accredited ART centre and the prescription must come from a medical practitioner practising for that centre (s 6). This exclusion is material to private individuals obtaining IVF medicines elsewhere, non‑ART prescribers, and suppliers not approved under Part VII.

The instrument allocates discrete duties to suppliers and administrative obligations to claimants, and it creates a specified payment right against the Commonwealth.

Duties

• Supply limitations and prescription duty. Suppliers may only make special arrangement supplies where the supply is to a person receiving IVF treatment from an accredited ART centre and on a prescription by a medical practitioner practising for that centre (s 6). Approved hospital authorities are specifically permitted to make special arrangement supplies to patients receiving treatment from that hospital (s 7(1)). This imposes a duty on suppliers to verify the provenance of the prescription and the treatment status of the patient.
• Claims documentation. Approved suppliers must include the RTAC Accredited Unit number for the accredited ART centre of the prescribing practitioner in any claim for payment, and include a CTG indicator where a claim is for a CTG registered patient and is made using the manual claims system (s 16(1)). Claims processing systems and staff must capture and supply those data elements.
• Pricing computation. Suppliers must compute dispensed price in accordance with the rules that apply to their supplier type: approved hospital authorities for public hospitals use the formula in s 9; other approved suppliers use the formula in s 12, including mark‑ups where applicable. Broken quantities are to be computed proportionately to two decimal places (ss 9(2), 12(2)). Rounding is to the nearest cent (ss 9(3), 12(3)).
• Application of CTG provisions where relevant. Suppliers making supplies to CTG registered patients must be aware that certain CTG Special Arrangement provisions (subsections 11(1), (2), (3), (3E) and (4) and CTG s 13) apply with modifications (s 15(2)), and that references to CTG supplier/supply in the CTG Special Arrangement are taken to refer to the approved supplier and the special arrangement supply respectively (s 15(3)).

Rights

• Payment entitlement against the Commonwealth. Approved suppliers are entitled to be paid by the Commonwealth the amount, if any, by which the dispensed price for the supply exceeds the amount the supplier was entitled to charge under s 87 of the Act (ss 8(1), 10(2), 11(1)). For approved pharmacists and approved medical practitioners s 10 specifies entitlement subject to s 99AAA and applicable s 98C conditions (s 10(1)(b), (2)). The instrument’s notes reinforce that s 87 caps supplier charges to patients, and the Commonwealth fills the gap between that patient charge limit and the dispensed price (ss 8 note, 10 note, 11 note).
• For approved hospital authorities for public hospitals, s 9 prevents the addition of mark‑ups to the cost of a pharmaceutical benefit for which payment is claimed by those authorities (s 9 note). The entitlement in s 8 is therefore limited to the dispensed price computed without mark‑ups.
• Where a medical practitioner directs a single supply instead of repeated supplies, the dispensed price includes only one dispensing fee (s 14), which constrains the supplier’s right to multiple dispensing fees in that specific scenario.

Conditions and caveats

• Suppliers other than public hospital authorities are subject to s 99AAA and the conditions under s 98C of the Act; those conditions can further qualify entitlement to payment (s 10(1)(b)). The instrument does not list those conditions, so suppliers must consult the Act and the current determinations.
• For CTG registered patients, the instrument makes explicit modifications to how CTG Special Arrangement provisions apply (s 15), and it removes CTG notes to certain CTG subsections from applying to these special arrangement supplies (s 15(4)). The instrument displaces the CTG notes’ application to claims for payment and centrally routes those claims through s 16.

Overall, the instrument sets the suppliers’ duty to restrict supply to the defined population, to compute price according to statutory rules, to include required identifiers on claims, and accords them the right to a Commonwealth payment that equals the gap between the statutory dispensed price and the patient charge ceiling under s 87.

The instrument itself does not create new criminal offences or specify distinct civil penalty provisions. Enforcement and penalty mechanisms remain those established by the National Health Act 1953 and its Part VII apparatus, read subject to this instrument (s 5 note).

Direct references in the instrument to enforcement‑relevant provisions are limited but material.

• Subject to other Act conditions. Section 10(1)(b) makes entitlement under s 10 “subject to section 99AAA of the Act and the conditions determined under section 98C of the Act that are applicable at the time of the supply.” Section 10 therefore signals that the entitlement to Commonwealth payment for approved pharmacists and approved medical practitioners is governed by s 99AAA (the Act’s special payment and claims framework) and any administrative conditions imposed under s 98C. Those statutory provisions contain the Act’s compliance, claim, and payment conditions.
• Part VII of the Act applies subject to this instrument (s 5 note). That preserves the Act’s enforcement framework,administrative conditions, potential recovery of payments, and the Act’s civil penalties and offences,while operating them in the instrument’s special arrangement context.

Operational enforcement levers implied by the instrument (grounded in its text rather than extraneous inference) include:

• Claims validation and administrative refusal. The instrument conditions payment on compliance with claim requirements in s 16 (RTAC Accredited Unit number and CTG indicator for manual claims). Failure to include required data would be a ground for non‑payment by the Commonwealth under the Act’s claims framework (s 16(1) read with s 99AAA).
• Payment conditions and revocation of approval. The instrument requires that approved pharmacists and medical practitioners’ entitlements are subject to any conditions determined under s 98C. Those conditions are capable of specifying compliance obligations and sanctions, as they are part of the Act’s regulatory scheme (s 10(1)(b)). The instrument does not itself set those conditions or the mechanism for revocation.
• Reconciliation and overpayment recovery. While the instrument does not state recovery powers, payment entitlements are framed in a way that feeds into the Act’s payment mechanism (ss 8, 10, 11 refer to subsection 99(4) of the Act). The Act contains administrative mechanisms for reconciliation and recovery where payments are inappropriate; the instrument’s operation within Part VII preserves that legal architecture (s 5 note).

Risks and implementation friction relevant to enforcement

• Administrative non‑compliance risk: the instrument imposes specific claim identifiers (s 16), broken‑quantity computations to two decimal places (ss 9(2), 12(2)), rounding regimes (ss 9(3), 12(3)) and a complex mark‑up table for ready‑prepared items (s 13). These raise the risk of incorrect claims and consequent payment denial or later recovery actions under the Act.
• Discretion and conditions elsewhere: because s 10(1)(b) refers to s 99AAA and s 98C conditions, suppliers must monitor those separate provisions for conditions that can affect entitlements and enforceability.

In short, the instrument provides the substantive framework for payment and claimability but relies on the pre‑existing enforcement and penalty regimes of the National Health Act and its administrative determinations to police compliance and sanction failures.

The instrument explicitly cross‑references and modifies the operation of various instruments and statutory provisions. These interactions determine precedence, scope and administrative sequencing.

Primary statutory basis and precedence

• Made under the National Health Act 1953. The instrument is expressly made under ss 99 and 100 of the Act (s 3). Section 5’s note states that Part VII of the Act, and regulations or other instruments made for the purposes of that Part, have effect subject to this instrument (s 5 note). That creates a statutory priority: where Part VII or subordinate instruments would operate differently, this instrument governs for the subject matter of IVF pharmaceutical benefits as defined.
• Repeal of predecessor. Schedule 2 repeals the National Health (IVF Program) Special Arrangement 2015 in whole; transitional saving in s 17 preserves acts done under the 2015 instrument where they could be done under the 2025 instrument (s 17).

Interaction with other Commonwealth pricing determinations

• Overrides or operates despite certain Determinations. The instrument states that s 8 (rates of payment for approved hospital authorities for public hospitals) applies despite the National Health (Commonwealth Price,Pharmaceutical Benefits Supplied By Public Hospitals) Determination 2017 (PB 25 of 2017) (s 8(2)). Likewise, s 11 (rates for private hospitals) applies despite the National Health (Commonwealth Price - Pharmaceutical benefits supplied by private hospitals) Determination 2020 (PB 99 of 2020) (s 11(2)). These express a specific incompatibility resolution: the special arrangement’s pricing rules take effect notwithstanding those Determinations for these supplies.
• Listing instrument and maximum quantity. Section 13(2) refers to the National Health (Listing of Pharmaceutical Benefits) Instrument 2024 as determining the maximum quantity for ready‑prepared items, which informs the mark‑up calculation. Users therefore must consult that Listing instrument for maximum quantity determinations invoked by s 13.

Interaction with CTG Special Arrangement

• The CTG (Closing the Gap - PBS Co‑payment Program) Special Arrangement 2016 (CTG Special Arrangement) applies to special arrangement supplies to CTG registered patients, but with explicit modifications (Part 3, s 15). Subsections 11(1), (2), (3), (3E) and (4) and s 13 of the CTG Special Arrangement (co‑payment reduction etc., payment by Commonwealth) apply with modifications (s 15(2)). The instrument maps CTG references to the special arrangement supply and to the approved supplier (s 15(3)), but excludes CTG notes to subsections 11(2) and (3) in relation to special arrangement supplies (s 15(4)). The instrument also substitutes its claims rule (s 16) in place of CTG notes concerning claims. Effectively, CTG co‑payment relief and payment rules apply, but CTG claims rules are modified where they conflict with this instrument’s claims approach.
• Claims procedure intersection. Section 16 modifies claims requirements in addition to s 99AAA of the Act. The CTG notes addressed in s 15(4) would normally deal with CTG claims; the instrument displaces them for special arrangement supplies and routes claims through s 16 instead.

Definitions and cross‑legislation linkages

• Health Insurance Act 1973 definitions apply where relevant. Section 6 notes that certain expressions defined in the Act take the meaning they would have under the Health Insurance Act 1973 (for example, “medical practitioner” and “private hospital”). That ensures consistency with broader health law terminology.
• Part VII and subordinate instruments. Because the instrument operates under Part VII and has been designed to sit within that scheme, other determinations, regulations and conditions made under the Act (for example, s 98C conditions and s 99AAA arrangements) continue to have effect subject to this instrument’s particular rules.

Administrative and operational intersections

• Claims and payments systems. The instrument imposes additional claim data requirements (s 16) that will interact with existing departmental claims platforms, including the manual claims system referred to in s 99AAA. IT, reconciliation and data‑matching processes must absorb RTAC Accredited Unit numbers and CTG indicators where required.

Overall, the instrument displaces certain pricing Determinations for the specific subject matter, imports definitions from other health statutes, overlays CTG arrangements with modifications, and slots into the Part VII payment/claims architecture while preserving the Act’s enforcement and conditions.

The instrument records its own making and the deletion of an earlier instrument, but it contains no sequential amendment log within the body of the text.

Key points visible in the instrument are:

• New instrument and commencement. The instrument is made and dated 22 September 2025 (prefatory material) and commences in full on 1 October 2025 (s 2). The commencement table lists “The whole of this instrument” with a commencement date of 1 October 2025 (s 2(1) table).
• Repeal of the 2015 instrument. Schedule 2 expressly repeals the National Health (IVF Program) Special Arrangement 2015 in its entirety (Schedule 2, item 1). There are no other repeal items listed.
• Saving provision for transition. Section 17 contains a saving/transitional provision: things done under the 2015 instrument for a particular purpose have effect under this instrument if the thing could be done for that purpose under this instrument (s 17(1)). It expressly includes supplies of pharmaceutical benefits and claims for payment as things that can be taken to have been done under the new instrument (s 17(2)).
• Referential amendments. Section 4 states that each instrument specified in Schedule 2 is amended or repealed as set out in the applicable items in that Schedule; Schedule 2 contains only the repeal (s 4 and Schedule 2). There are no other amending items or consequential amendments listed in the body of the instrument.

What the instrument does not show

• The instrument contains no history of prior amendments to itself because it is presented in the form of a new instrument replacing the 2015 arrangement. There is no schedule of incremental changes or previous amendment dates in the text beyond the repeal of the 2015 instrument.
• No subordinate determinations, regulations or conditions under ss 98C or s 99AAA are reproduced or amended in the text. Section 10 references the continuing relevance of those conditions but does not set them out.

For a practitioner, the immediate takeaways are the instrument’s single commencement date (1 October 2025), its full repeal of the 2015 instrument, and the transitional provision preserving acts done under the old instrument where they can be reconciled under the new one (s 17). Any subsequent amendments will appear as separate instruments or as amendments to this special arrangement; none are recorded here.

The instrument itself contains no references to case law, judgments, or litigation history. It does not identify any litigation brought in relation to its predecessors, nor does it cite court decisions. The Schedule 1 note references ministerial declarations made under subsection 85(2) of the Act for the listed drugs, and subsections 85(3), (5) and (6) for form, manner and brand determinations, but no judicial interpretation or litigation context is provided in the text.

Practical implications of the absence of litigation in the instrument

• No judicial clarifications are contained within the instrument; any legal disputes, for example over the interpretation of “practising for such a centre” or the computation of broken quantities, would need to be resolved under the Act and by courts or tribunals if contested. The instrument does not contain dispute resolution clauses or alternate administrative appeal processes beyond the Act’s framework (s 5 note refers to Part VII’s continued effect subject to the instrument).
• Where ambiguity exists in the instrument’s drafting (for example, operational issues around the RTAC Accredited Unit number format or the interaction of CTG notes that are excluded under s 15(4)), resolution would depend on administrative guidance from the Department and, ultimately, judicial review or appeals under the Act’s dispute mechanisms if contested.

Because the instrument does not record litigation, users should not assume points of law have been settled by courts and should prepare for potential administrative clarifications or legal challenges where competing readings of claims, pricing calculations or eligibility arise.

This instrument contains several drafting and operational features that can be sources of practical error or unexpected outcomes if not carefully managed.

Eligibility strictly tied to accredited ART centre and practitioner

• Double eligibility requirement. A supply qualifies as a special arrangement supply only where both conditions are met: the recipient must be receiving IVF treatment from an accredited ART centre and the prescription must be by a medical practitioner practising for that centre (s 6). A prescription from a practitioner not “practising for” the accredited ART centre, or a supply to a patient not receiving treatment from the centre, will fall outside the arrangement. Practitioners and suppliers must verify both elements before claiming payment.

RTAC Accredited Unit number and claims data

• Claims must include the RTAC Accredited Unit number (s 16(1)(a)). Failure to include the correct RTAC number risks delay, rejection, or repayment recovery under the Act’s claims processes. The instrument’s specific data requirement imposes a new identifier that may not be present in existing pharmacy or hospital billing flows.
• CTG indicator for manual claims. For CTG registered patients, an indicator must be included when the manual claims system (s 99AAA) is used (s 16(1)(b)). Manual submission users must ensure this indicator is populated; absence can affect CTG co‑payment treatment.

Supplier type determines pricing treatment

• Different dispensed price rules by supplier class. Approved hospital authorities for public hospitals compute dispensed price per s 9 and may not add mark‑ups (s 9 note). Approved suppliers other than public hospital authorities use s 12 and may add a mark‑up for ready‑prepared items (s 12(1)(a)(ii), s 13). Confusion over supplier classification can lead to incorrect pricing and overclaiming.
• Mark‑up table complexity. Section 13’s mark‑up for ready‑prepared items is tiered and depends on the AEMP/PEMP for the maximum quantity, with percentage or fixed dollar mark‑ups applied differently when the pack quantity is less than the maximum. Implementing this precisely requires mapping pack quantities to maximum quantities (s 13(2) relies on Listing instrument 2024) and applying proportional reductions for smaller pack sizes (s 13(1)(b)(i)). Errors in applying these rules will yield mispriced claims.

Broken quantities and rounding precision

• Two decimal percentage for broken quantities. Broken quantities are converted to a percentage to two decimal places before applying to AEMP/PEMP (ss 9(2)(a), 12(2)(a)). Systems that use different rounding conventions may return incorrect amounts.
• Nearest cent rounding on final dispensed price. Rounding 0.5 cents upwards is required (ss 9(3), 12(3)). Small rounding differences aggregated across many claims can cause reconciliation mismatches.

Dispensing fee rules and repeated supplies

• Single dispensing fee for single supply replacing repeats. Section 14 limits the inclusion of dispensing fees to one where a practitioner prescribes a one‑off supply instead of repeated supply instructions. Suppliers who charge multiple dispensing fees in such situations risk payment adjustments.

CTG Special Arrangement exceptions

• CTG application is modified. While the CTG Special Arrangement’s co‑payment reductions and some payment rules apply to CTG registered patients (s 15(2)), CTG notes to subsections 11(2) and (3) do not apply for these special arrangement supplies (s 15(4)). Those notes deal with CTG supplier claims; the instrument redirects such claims handling to s 16. Implementers must not assume CTG claims protocols apply unchanged.

Dependence on other instruments and conditions

• s 10 subject to s 99AAA and s 98C conditions. Approved pharmacists and approved medical practitioners’ entitlement to payment is subject to existing Act conditions (s 10(1)(b)). The instrument does not list those conditions, so suppliers must check the Act and any determinations for eligibility restrictions or administrative conditions that could limit payments.
• Link to Listing instrument and Determinations. The maximum quantity and readiness of items rely on the Listing instrument 2024 (s 13(2) note). The instrument also explicitly operates notwithstanding PB 25 of 2017 and PB 99 of 2020 in the ways noted (ss 8(2), 11(2)), so implementers must be aware of these precedence statements.

Transitional carry‑over risks

• Past actions preserved only if they could be done under this instrument. Section 17 saves things done under the 2015 instrument only where the thing “could be done for that particular purpose under this instrument.” That could create ambiguity in transitional claims or supplies that differ in procedural detail between the two instruments.

Record‑keeping and administrative burden

• The discrete requirements for pack quantity computations, RTAC numbers, CTG indicators and mark‑up calculations impose an administrative and IT burden on hospitals, pharmacies and practitioners’ offices. Absent precise system updates, errors and delays are likely.

In short, the “gotchas” are concentrated in data‑capture obligations, supplier classification, tailored price computation rules (especially for broken quantities and ready‑prepared mark‑ups), CTG interaction nuances, and the need to monitor separate Act‑based conditions that the instrument references but does not reproduce.

Compliance requires operational, clinical and administrative alignment across ART centres, prescribers, pharmacies, hospitals and claims processors. The instrument sets precise computational and documentation rules; meeting them reduces payment risk.

Eligibility and prescribing practices

• Ensure prescriptions meet the special arrangement definition. Confirm that the patient is receiving IVF treatment from an accredited ART centre and that the prescribing medical practitioner is practising for that centre (s 6). That verification step must occur before the supply is characterised as a special arrangement supply.
• Capture RTAC Accredited Unit numbers. Prescribers and ART centres should ensure the RTAC Accredited Unit number is recorded on prescriptions, referral notes and in the patient record so that it can be carried into claims (s 16(1)(a)).

Supplier classification and pricing setup

• Classify suppliers correctly. Configure billing systems to apply s 9 pricing rules when the supplier is an approved hospital authority for a public hospital, s 11 for private hospital authorities, and s 12 for other approved suppliers (ss 9, 11, 12). Misclassification will lead to incorrect dispensed price calculations.
• Implement the broken quantity calculation precisely. For any supply that is less than a pack quantity, compute the percentage (broken quantity divided by pack quantity) to two decimal places and apply that percentage to the AEMP or PEMP as required (ss 9(2), 12(2)). Make sure the calculation engine rounds the final dispensed price to the nearest cent (ss 9(3), 12(3)).
• Apply ready‑prepared mark‑ups per s 13. For ready‑prepared pharmaceutical benefits supplied by approved suppliers other than public hospital authorities, implement the mark‑up table logic in s 13: (i) identify the AEMP/PEMP for the maximum quantity (using the Listing instrument 2024 per s 13(2)), (ii) determine the mark‑up band, (iii) if the pack quantity is less than the maximum quantity, reduce a monetary mark‑up proportionately or apply the percentage to the pack quantity as specified (s 13(1)(b)). Round mark‑ups for pack quantities to the nearest cent as required in s 12(1)(a)(ii).
• Account for the ready‑prepared dispensing fee. For approved suppliers other than public hospital authorities, add the ready‑prepared dispensing fee where applicable (s 12(1) paragraphs (a)(iii), (b)(ii), (c)(iv)).

Dispensing fee and repeat supply management

• If a practitioner directs a single supply instead of repeated supplies, include only one dispensing fee in the dispensed price (s 14). Train pharmacists and hospital dispensaries to interpret and code such prescription directions correctly and to document the rationale for one‑off supply instructions.

CTG registered patients

• Apply CTG co‑payment and payment provisions with modifications. For CTG registered patients, apply the CTG Special Arrangement provisions identified in s 15(2) with the modifications prescribed. Do not rely on the CTG notes to subsections 11(2) and (3) where the instrument excludes them (s 15(4)). Where claims are made manually, include the CTG indicator per s 16(1)(b).
• Where uncertainty exists about whether a particular CTG note applies, defer to s 15: treat references to CTG supply and supplier as references to the special arrangement supply and the approved supplier (s 15(3)) and route claims per s 16.

Claims preparation and submissions

• Populate required claim fields. Ensure claims systems include fields for RTAC Accredited Unit number and CTG indicator (for manual claims where applicable) and that staff verify these entries before claim submission (s 16(1)). Missing fields are a clear compliance risk.
• Reconcile s 87 patient‑charge caps. Suppliers must be aware that the Commonwealth pays only the amount by which the dispensed price exceeds amounts suppliers are entitled to charge under s 87 of the Act (ss 8(1), 10(2), 11(1)). Claiming must therefore reconcile actual patient charges, the s 87 applicable cap and the dispensed price to compute the Commonwealth payment correctly.

Operational controls and record‑keeping

• Institute audit trails. Keep detailed records showing the patient was receiving IVF treatment at an accredited ART centre, the prescribing practitioner was practising for that centre, the RTAC number used on the claim, the pack quantity and broken quantity calculations, the AEMP/PEMP values used, mark‑up computations, and any CTG indicators. These records will be needed in the event of departmental queries or payment reconciliations under the Act.
• Update IT and reconciliation systems. Ensure pharmacy, hospital and claims systems implement the numerical rules: two‑decimal percentage for broken quantities, mark‑up computations per s 13, and nearest‑cent rounding. Confirm that systems differentiate supplier type (public hospital authority, private hospital authority, other approved supplier) and apply the appropriate dispensed price algorithm.
• Monitor s 99AAA and s 98C conditions. Because entitlement for pharmacists and approved medical practitioners is subject to s 99AAA and conditions under s 98C (s 10(1)(b)), ensure compliance with those conditions. Track and implement any administrative determinations or conditions issued under those provisions.

Transitional matters

• Apply s 17 to prior supplies and claims where relevant. For supplies and claims undertaken under the 2015 instrument, determine whether the thing could have been done under the 2025 instrument; if so, treat the prior act as effective under the new instrument per s 17(1)‑(2). Document the basis for treating previous actions as valid under the new instrument.

Engage with administration for clarifications

• Seek departmental guidance. Where operational ambiguity exists (for example, RTAC number format, how CTG indicators are signalled in automated vs manual claims), request clarifying guidance from the administering Department. The instrument establishes legal rules but administrative practice will determine day‑to‑day claim acceptance and processing.

By adopting these steps,eligibility checks, accurate RTAC capture, correct supplier classification, careful numerical implementation of broken quantities and mark‑ups, single‑fee application where relevant, thorough record‑keeping, and alignment with s 99AAA/s 98C conditions,suppliers and ART centres can operationalise the special arrangement in a manner consistent with the instrument’s text.