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Approved Pathology Authority (APA) acquisitions and mergers 012-26082621




This document outlines how to manage the process when the ownership of Approved Collection Centres (ACC) and Accredited Pathology Laboratories (APL) transfers to a different APA through an acquisition or merger. This also includes the assessment, processing and approval of the relevant applications.

On this page:

Assessing Approved Pathology Authority acquisition or merger advice form (HW036)

Confirm applications have been received in PaNDA - PESDST

Process ACC applications in PDS

Update APL details in PDS

Confirm the acquisition or merger will proceed as planned before approving applications - PESDST

Delegate approval of ACC cancellations - PESDST

Delegate approval process - new ACC applications - PESDST

APA terminations

Notify APAs that processing has been finalised - PESDST

Track receipt of assignment of leases - PESDST


Assessing Approved Pathology Authority acquisition or merger advice form (HW036)

Table 1

Expand table

Step

Action

1

Assess the HW036 form

Check the HW036 form is complete and:

  • it is the current version of the form
  • both pages of the form are included
  • all mandatory questions are completed
  • the form is physically signed and dated
  • the signatories are authorised contacts, directors, CEOs or principal office bearers of the APAs, as currently recorded in the Provider Directory System (PDS)
  • it was submitted through an approved channel

Escalate the application to the Pathology and Diagnostic Imaging Team if:

  • an error has been made but the correct information is clear
  • the assessing instructions do not provide clear guidance
  • it may be reasonable to make an exception to the application requirements

See Escalation process for Pathology, Diagnostic Imaging and Radiation Oncology (LSPN).

The Resources page contains a link to the HW036 form.

Note: name the HW036 form in PaNDA using the following convention: APA_ACQUISITIONMERGER_(Disposing APA number)_(Acquiring APA number).

Are these conditions met?

  • Yes, go to Step 2
  • No, note the details for inclusion in the refusal email and continue checking the application for any further incorrect or incomplete information. Go to Step 2.

2

Question 1 - Acquiring APA

This question is mandatory and the APA number and APA name must match the details recorded in PDS.

The acquiring APA must also have an approval that will be current on the date of the acquisition or merger.

This question has been completed incorrectly if the APA:

  • number and name do not match the record in PDS
  • name does not match the record in PDS
  • undertaking is not current, or will not be on the proposed acquisition or merger date

Is the question correctly completed?

  • Yes, go to Step 3
  • No, note the details for inclusion in the refusal email and continue checking the application for any further incorrect or incomplete information. Go to Step 3

3

Question 2 - Disposing APA

This question is mandatory and the APA number and APA name must match the details recorded in PDS.

The disposing APA must also have an approval that will be current on the date of the acquisition or merger.

This question has been completed incorrectly if the APA:

  • number and name do not match the record in PDS
  • name does not match the record in PDS
  • undertaking is not current, or will not be on the proposed acquisition or merger date

Is the question correctly completed?

  • Yes, go to Step 4
  • No, note the details for inclusion in the refusal email and continue checking the application for any further incorrect or incomplete information. Go to Step 4

4

Question 3 - Proposed date of acquisition or merger

This question is mandatory. The effective date should be at least 30 days from the date the application was received.

If the form was not received more than 30 days before the proposed effective date, advise the APAs that it may not be processed in time. Escalate the application to the Pathology and Diagnostic Imaging Team. See Escalation process for Pathology, Diagnostic Imaging and Radiation Oncology (LSPN).

Is the question correctly completed?

  • Yes, go to Step 5
  • No, note the details for inclusion in the refusal email and continue checking the application for any further incorrect or incomplete information. Go to Step 5

5

Question 4 - Date disposing APA will cease to exist

This question is mandatory if, as part of the acquisition or merger, one of the APAs will be terminating their undertaking under section 23DH of the Health Insurance Act 1973.

If one APA, or both APAs if a new APA will be formed, will be terminating their undertaking, this date cannot be earlier than 30 days from when the form is received.

The APA's undertaking would terminate 30 days from receipt of the request. Escalate the request to terminate the undertaking(s) to the Pathology and Diagnostic Imaging Team when received. See Escalation process for Pathology, Diagnostic Imaging and Radiation Oncology (LSPN).

This question does not need to be completed if neither APA is terminating their undertaking.

Is the question correctly completed?

  • Yes, go to Step 6
  • No, note the details for inclusion in the refusal email and continue checking the application for any further incorrect or incomplete information. Go to Step 6

6

Question 5 - Acquisition or Merger details

Is this a partial or a total acquisition or merger? - This question is mandatory.

This question has been incorrectly completed if:

  • neither box has been ticked to indicate whether it is a partial or total acquisition or merger, or
  • both boxes have been ticked

Details of all acquired ACCs and APLs must be completed.

Is the question correctly completed?

  • Yes, go to Step 7
  • No, note the details for inclusion in the refusal email and continue checking the application for any further incorrect or incomplete information. Go to Step 7

7

Check ACC and APL details in PDS

The acquisition or merger may be partial or total. Follow the relevant instructions below.

Partial acquisition or merger

Check PDS to ensure that for the disposing APA, all:

  • ACCs listed on the HW036 form have a current approval
  • APLs listed on the HW036 form have a current approval

For ACCs:

  • Select Pathology > Collection Centre > View
  • Key the APA and ACC numbers provided by the disposing APA
  • Select Search

For APLs:

  • Select Pathology > Laboratories > View
  • Key the APL numbers provided by the disposing APL
  • Select Search

Total acquisition or merger

Check PDS to ensure that for the disposing APA, all:

  • ACCs owned by the disposing APA are listed on the HW036 form
  • APLs owned by the disposing APA are listed on the HW036 form
  • ACCs listed on the HW036 form will have a current approval on the date of the acquisition or merger
  • APLs listed on the HW036 form will have a current approval on the date of the acquisition or merger

For ACCs:

  • Select Pathology > Collection Centre > View
  • In the Basic Search tab:
    • key the APA number of the disposing APA, and
    • select Search
  • Select Status to sort those ACCs which have a current approval period (Status will be APP or REL). Check the Approval End dates to make sure the ACCs have a current approval

For APLs:

  • Select Pathology > Laboratory > View
  • In the Detailed Search tab:
    • key the APA number of the disposing APA, and
    • select Search

Do ACC and APL details match those provided by the disposing APA, and do all ACCs and APLs have a current approval?

8

Section 7 - Declaration - Acquiring APA

This declaration is mandatory for both partial and total acquisitions or mergers.

An authorised applicant as listed on the PDS record of the acquiring APA must have:

  • provided their full name, position and contact number
  • physically signed and physically dated the form

Note: See Authorised applicants for APAs on the Background page in Assessing Approved Pathology Authority (APA) applications for a definition of 'authorised applicant'.

Is the question correctly completed?

9

Section 8 - Declaration - Disposing APA

This declaration is mandatory for both partial and total acquisitions or mergers.

An authorised applicant as listed on the PDS record of the disposing APA must have:

  • provided their full name, position and contact number
  • physically signed and physically dated the form

Note: See Authorised applicants for APAs on the Background page in Assessing Approved Pathology Authority (APA) applications for a definition of 'authorised applicant'.

Is the question correctly completed?

10

Assessment complete

Once the assessment is complete:

  • leave a comment in PaNDA advising that the application has been checked and the recommendation to approve or refuse, and
  • send the application to the Provider Engagement Service Delivery Support Team (PESDST) using the Send for Delegation function in PaNDA

PESDST will check the application and notify the Pathology and Diagnostic Imaging Team of the acquisition or merger request, advising whether it has been accepted or refused.

See Escalation process for Pathology, Diagnostic Imaging and Radiation Oncology (LSPN).

Go to Step 11.

11

Confirm outcome of application with APAs - PESDST

Once the assessment is complete and the Pathology and Diagnostic Imaging Team has been notified, PESDST will advise the APAs of the outcome of their application.

If the application is:

  • accepted, advise the APAs of the next steps in the process and what further application forms are required
  • refused, advise the APAs that the HW036 form cannot be accepted and the reasons

Confirm applications have been received in PaNDA - PESDST

Table 2

Expand table

Step

Action

1

Check applications have been received in PaNDA

All applications should be received at least one week before the acquisition or merger date.

Applications required after receipt of the HW036 form will vary depending on the type of acquisition or merger:

  • ACC cancellations from the disposing APA
  • New ACCs from the acquiring APA
  • Update APL contacts and mailing address (if required)
  • Termination of APA (if required)
  • New APA (if required)

The Provider Engagement Service Delivery Support Team (PESDST) manages the receipt and tracking of applications.

When ACC applications related to the acquisition or merger are identified in PaNDA, add the following to the Secondary Reference ID field:
ACQUISITIONMERGER_(Disposing APA number)_(Acquiring APA number).

Name the ACC applications using the normal naming convention in the External Reference ID field:

  • ACC_NEW_(Applying APA number)_(SUBURB)
  • ACC_CLOSURE_(APA number)_(ACC number)

Partial acquisition or merger

Check PaNDA to ensure that applications have been received from the:

  • disposing APA, requesting the cancellation of the existing ACCs as listed on the HW036 form
  • acquiring APA, requesting new ACCs for all ACC locations as listed on the HW036 form

Total acquisition or merger

Check PaNDA to make sure applications have been received from the:

  • disposing APA, requesting the cancellation of all their operating ACCs as listed in PDS
  • acquiring APA, requesting new ACCs for all ACC locations where the disposing APA has an operating ACC
  • a request has been received to terminate the undertaking of the disposing APA

Note: where both APAs are merging to form a new entity (APA), check PaNDA to ensure that:

  • requests have been received to terminate the undertakings of both existing APAs
  • an Application for approval, amendment or renewal of an approved pathology authority form (HW011) has been received to register a new APA

Have all relevant applications been received?

  • Yes, go to Step 3
  • No, PESDST will contact the APAs by email at least one week before the acquisition or merger date to advise of any applications not yet received, noting that any late submissions may result in a gap in eligibility (if required)

2

ACC application requirements

The acquiring APA must include the following with each application for a new ACC:

  • floor plan
  • copy of the lease for the premises in the name of the disposing APA:
    • evidence of acquisition (signed by both the disposing and acquiring APA), explaining why the acquiring APA's name is not on the lease and indicating that the documents will be transferred, or
    • evidence that the lease has been assigned to the new APA and signed by both the disposing and acquiring APA and the lessor
  • $2000 payment (if applicable)

A copy of the new lease in the name of the acquiring APA, or an assignment of lease, must be provided within 30 days after the new lease arrangement has been made (acquisition or merger date). If an assignment of lease is submitted instead of a new lease, both APAs and the lessor must sign it.

For more details about assessing ACC applications, see Assessing Approved Collection Centre (ACC) applications and renewals.

All applications should be submitted at least one week before the acquisition or merger date.

Applications should be checked to make sure they meet the requirements as early as possible before the acquisition or merger date to allow time for resubmission if required.

Note: no application forms are required for the transfer of any APLs listed on the form.


Process ACC applications in PDS

Table 3: describes how to process ACC applications in the Provider Directory System (PDS). These applications can be processed before the date of the acquisition or merger but must not approved until on or after the day of the acquisition or merger.

Expand table

Step

Action

1

Acquiring APA - Process new ACCs

Process new ACC applications

New ACC applications do not need pending until the day of the acquisition or merger and can be processed once received.

However, when created, the new ACCs must not be approved by a delegate until the day of the acquisition or merger, or later.

All new ACCs must be processed as per normal process, with the start date being the date of the acquisition or merger. If the delegate(s) is unable to approve all applications on the day of the acquisition or merger, they will backdate the new ACCs where required as part of the approval process. See Table 7.

Complete Lease tab details

When creating the new ACCs, make sure the check box on the Lease tab is ticked indicating that The APA is occupying the premises following an acquisition or merger.

When ticked, a box will populate for the Previous ACC number. Key the disposing APA number.

Record comments

Leave a comment in PDS on each ACC record and in PaNDA Processing Notes that the ACC was created as part of an acquisition or merger:
'ACC created as part of an acquisition or merger'.

When processing each new ACC, leave the acquisition or merger PaNDA work item ID in comments.

For details about the assessment and processing of ACC applications, see:

2

Disposing APA - Close existing ACCs

Process ACC cancellations

Manual ACC cancellations do not need pending until the day of the acquisition or merger and can be processed once received.

However, the cancellation of the ACCs must not be approved by a delegate until the day of the acquisition or merger.

Note: as ACC cancellations cannot be backdated, they must be processed, checked by a delegate, and have an approval to cancel comment left on the ACC record in PDS before the acquisition or merger date.

Pend requirements

Although ACC cancellation requests where the cancellation date is more than 10 business days in the future are usually pended, ACC cancellations received as part of an acquisition or merger do not need to be pended and the applicant does not need to be notified that the application has been put on hold.

Close ACCs

The Closure Reason selected must be 'APA merger/acquisition'.

The closure date of all ACCs listed on the form must be the day before the acquisition or merger date provided on the HW036 form:

For example, if the acquisition or merger date is 2 March 2026, the ACC closure date will be 1 March 2026.

Record comments

Leave a comment in PDS on each ACC record that the ACC was cancelled as part of an acquisition or merger:
'ACC cancelled as part of an acquisition or merger'.

When processing each ACC cancellation, leave the acquisition or merger PaNDA work item ID in comments.

For details about the assessment and processing of ACC applications, see:


Update APL details in PDS

Table 4: describes how to update the APL details in the Provider Directory System (PDS). The updates to the APL links to the APAs can be made before the day of the acquisition or merger, but the updates to authorised contacts and mailing address can only be made until on or after the day of the acquisition or merger.

Expand table

Step

Action

1

End date APL links to disposing APA record

APL links to the disposing APA must be end-dated the day before the acquisition or merger and linked to the acquiring APA from the date of the acquisition or merger.

Access the disposing APA record

Go to:

  • Pathology
  • APA
  • View

In the Basic Search tab:

  • key the disposing APA number
  • select Search - the APA record will display
  • select Edit
  • go to the Applications tab
  • select Laboratories for the current approval period

For each of the APLs listed on the HW036 acquisition or merger form, change the Link End Date to the day before the acquisition or merger date provided on the form.

For example, if the acquisition or merger date on the form is 3 March 2026, key 2 March 2026 as the Link End Date.

Record comments

Leave a comment in PDS on each APL record that ownership of the APL changed as part of an acquisition merger:
'Ownership of APL changed from APA (disposing APA number) to APA (acquiring APA number) as part of an acquisition or merger'.

Once the links for all APLs listed on the form have been end-dated, select Save.

2

Acquiring APA - Link APLs to acquiring APA

Access the acquiring APA record

Go to:

  • Pathology
  • APA
  • View

In the Basic Search tab:

  • key the acquiring APA number
  • select Search - the APA record will display
  • select Edit
  • go to the Applications tab
  • select Laboratories for the current approval period
  • key the APL numbers and select Link APL
  • change the Link Start Date to the date of the acquisition or merger

Link APLs

Link all APLs to the acquiring APA with a start date of the acquisition or merger date.

Record comments

Leave a comment in PDS on each APL record that ownership of the APL changed as part of an acquisition or merger:
'Ownership of APL changed from APA (disposing APA number) to APA (acquiring APA number) as part of an acquisition or merger'.

Note: if an APL is due to expire before the date of the acquisition or merger, the disposing APA must renew the APL before the date of the acquisition or merger, and the renewal must be approved by a delegate. If not renewed by the date of the acquisition or merger, a new APL cannot be issued for the location for the acquiring APA.

For details about the assessment and processing of APL applications, see:

3

Amend APL authorised contacts and mailing addresses

Update the authorised contacts and mailing addresses of all acquired APLs to match those recorded on the acquiring APA record.

Only process these updates after both APAs confirm that the acquisition or merger is proceeding as planned and the acquisition or merger date is reached. Do not process the updates before the acquisition or merger date.

Access the acquiring APA record

Go to:

  • Pathology
  • APA
  • View

In the Basic Search tab:

  • key the APA number
  • select Search - the APA record will display
  • note the following:
    • first contact details
    • second contact details
    • postal address

Update the APL record

Go to:

  • Pathology
  • Laboratories
  • View

In the Basic Search tab:

  • key the APL number
  • select Search - the APL record will display
  • select Edit
  • amend the following to match those recorded on the acquiring APA's record:
    • first contact details
    • second contact details
    • postal address
  • select Save

If the acquiring APA wishes to record different contact details, an Application for approval, amendment or renewal of premises as an accredited pathology laboratory form (HW010) is required.

Record comments

Leave a comment in PDS on each APL record that ownership of the APL changed as part of an acquisition or merger:
'Ownership of APL changed from APA (disposing APA number) to APA (acquiring APA number) as part of an acquisition or merger'.


Confirm the acquisition or merger will proceed as planned before approving applications - PESDST

Table 5: for Provider Engagement Service Delivery Support Team (PESDST) only.

Expand table

Step

Action

1

Confirm acquisition or merger with APAs

Before the proposed acquisition or merger date, contact both APAs to confirm the acquisition or merger is proceeding as planned, by:

  • email 2 business days before the acquisition or merger date, and
  • phone on the acquisition or merger date, if email confirmation has not been received

PESDST should obtain confirmation 2 business days before the acquisition or merger date that the acquisition or merger is proceeding as planned. This may vary depending on the circumstances.

Once both APAs confirm the acquisition or merger is proceeding as planned, the relevant applications can be approved.

Note: if confirmation is not received from both APAs, the acquisition or merger cannot proceed and a new HW036 form must be submitted giving another 30 days' notice.

Go to Step 2.

2

Record Comment in PDS

Depending on whether confirmation has been received from both APAs, record the outcome on:

  • both APA records in the Provider Directory System (PDS), and
  • the acquisition or merger work item in PaNDA (HW036 form)

Note: advise the Pathology and Diagnostic Imaging Team of the APAs' responses.

Has confirmation been received?

  • Yes, record the following:
    'Confirmation received from APA (number) and APA (number) that acquisition or merger dated DD Month YYYY is proceeding as planned'
  • No, record the following:
    'Confirmation not received from APA (number) and APA (number) that acquisition or merger dated DD Month YYYY is proceeding as planned. Acquisition or merger cannot proceed'

Delegate approval of ACC cancellations - PESDST

Table 6: explains the delegate approval process for ACC cancellations, on or after the date of the acquisition or merger. Provider Engagement Service Delivery Support Team (PESDST) only.

Expand table

Step

Action

1

Confirm acquisition or merger is proceeding

Applications should be checked for completeness before the day of the acquisition or merger, allowing enough time for the APAs to resubmit applications if required.

As ACC cancellations cannot be backdated, the assessment and decision to approve the cancellations must take place before the day of the acquisition or merger.

An approval to cancel comment must be left on the ACC records before the acquisition or merger date and the cancellations then approved in the Provider Directory System (PDS) on or after the acquisition or merger date.

2

Review closure details and record approval

Check that the:

  • correct closure reason has been selected (APA merger/acquisition)
  • requested closure date is the day before the acquisition or merger date

If required, amend the:

  • closure reason to APA merger/acquisition
  • closure date to the day before the acquisition or merger

Record approval comments

Leave the cancellation approval comment in PDS, noting that the cancellation will be actioned on or after the day of the acquisition or merger:
'APS5 delegate approval for cancellation granted under 23DNH of the Health Insurance Act 1973 after confirming all requirements have been met. Cancellation date effective as <day before day of acquisition or merger>. Cancellation to be actioned on or after <day of acquisition or merger>'.

See the following for more details about:

  • the approval of HPOS ACC cancellation requests, see Table 6 in Processing Approved Collection Centre (ACC) applications
  • manual ACC cancellation requests, see Table 7 in Processing Approved Collection Centre (ACC) applications

Note: as ACC cancellations cannot be backdated, it is important that the decision to approve the ACC cancellations is made before the day of the acquisition or merger.


Delegate approval process - new ACC applications - PESDST

Table 7: Delegate approval of new ACCs - on or after the date of the acquisition or merger - Provider Engagement Service Delivery Support Team (PESDST) only.

Expand table

Step

Action

1

Assess new ACC applications

Applications should be checked for completeness before the day of the acquisition or merger, allowing enough time for the APAs to resubmit applications if required.

Once both APAs confirm that the acquisition or merger is proceeding as planned, the new ACCs can be approved on the day of the acquisition or merger or shortly after (if required).

Backdating may be required if the new ACCs cannot be approved on the day of the acquisition or merger.

Does the ACC require backdating?

2

Escalate backdating request

Escalate the request to backdate the ACC approval from the acquisition or merger date to the Pathology and Diagnostic Imaging Team. See Escalation process for Pathology, Diagnostic Imaging and Radiation Oncology (LSPN).

Pend the application in PaNDA and add a comment explaining the reason for the escalation.

Once the Pathology and Diagnostic Imaging Team provide approval to backdate the ACC, in PaNDA:

  • attach the approval email to the file, and
  • add a comment

Go to Step 3.

3

Approve new ACCs

Approve the new ACCs with a start date of the acquisition or merger. For more details, see Table 7 in Processing Approved Collection Centre (ACC) applications.


APA terminations

Table 8: describes the process for terminating an APA because of an acquisition or merger.

Expand table

Step

Action

1

Process APA terminations

In the case of a total acquisition or merger, one or both APAs will terminate their undertaking.

For:

The end date of the undertaking should be:

  • the day before the acquisition or merger date if the request to terminate was received more than 30 days before the acquisition or merger
  • 30 days from receipt of the request, if received less than 30 days from the acquisition or merger date

When end dating the undertaking of the APA, select MERGE as the End Reason.

Note: the closure of disposing APAs must not be approved until on or after the acquisition or merger date.

2

Record comment

After terminating the APA undertaking, record a comment in the Provider Directory System (PDS) on the APA record, that the APA is terminating due to an acquisition or merger with the acquiring APA (Number).


Notify APAs that processing has been finalised - PESDST

Table 9: Provider Engagement Service Delivery Support Team (PESDST) only.

Expand table

Step

Action

1

Send confirmation email to both APAs

Once all applications have been processed and approved:

  • notify both APAs that the acquisition or merger process has been finalised
  • request assignment of lease documents within 30 days

2

Upload final documents to PaNDA

Upload a copy of the:

  • acquisition or merger form and confirmation email to the acquisition or merger work item in PaNDA
  • acquisition or merger form to all ACC work items in PaNDA

Track receipt of assignment of leases - PESDST

Table 10: explains how to track receipt of assignment of leases (30 days after the acquisition or merger) - Provider Engagement Service Delivery Support Team (PESDST) only.

Expand table

Step

Action

1

Track assignment of lease documents

Check that new leases or assignment of lease documents have been received for all new ACCs created as part of the acquisition or merger.

PESDST should complete this check 30 days after the acquisition or merger date.

Pend the HW036 form with a future release date 30 days after the acquisition or merger date.

Go to Step 2.

2

Check ACC lease documents

When the HW036 form returns to Open status, check all ACCs listed on the application form.

Access the ACC record

  • Select Pathology > Collection Centre > View
  • Key the:
    • APA Number
    • ACC Number
  • Select Search - the ACC record will display
  • Select Edit
  • Go to the Lease tab
  • Check documents marked Lease Document/Proof of Ownership in the Description field

Record missing documents

Record ACCs which do not have an assignment of lease uploaded to the ACC record.

Have all assignment of lease documents been received?

  • Yes, procedure ends here
  • No, record the ACC numbers for inclusion on the reminder email template, go to Step 3

3

Send reminder email

Complete and send a reminder email to the contact for the acquiring APA.

Send a copy of the reminder email to the Pathology and Diagnostic Imaging Team advising which ACCs assignment of lease documents have not been received.