Most healthcare practices assume their privacy and consent processes are compliant until something tests them. 

That test may be a patient complaint, a data breach, an Australian Health Practitioner Regulation Agency (‘AHPRA’) advertising concern, a staff mistake, a website review, or a question from a prospective buyer during due diligence. By that stage, the issue is rarely just the wording of a policy. It is often a gap between what the clinic says it does and what actually happens day to day

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For many practice owners, opening a second clinic feels like the next logical step. The first location is operating well, patient demand is growing and expansion appears commercially sensible. In many cases, the second site is secured quickly once the right premises become available.

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Growth is usually viewed as a positive sign in a medical practice. An expanding practitioner base, additional locations, broader service offerings and increasing revenue may all reflect a practice that is evolving and growing. However, what many practice owners later discover is that growing a practice and strengthening it are not necessarily the same thing.

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Most medical practices today operate using some form of independent practitioner model. For many years, these arrangements have been seen as commercially efficient, flexible and relatively low risk.

However, practice owners are increasingly coming to us with the same question: “Are our agreements still compliant?” In many cases, the answer is no; not because the agreement structure was inappropriate, but because the devil lies in the detail of the specific terms and conditions of the agreement.

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You’re trained to identify clinical risks… but what about your practice risk?

Many practice owners assume their business is sound from a legal and commercial perspective. Agreements are in place, the structure has remained unchanged for years, and financial performance appears stable, and everything’s fine, right? What you might find, when examined more closely, a different picture can emerge.

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Medical practices commonly engage independent medical practitioners through service agreements, where doctors provide services to their patients and the practice supplies rooms, reception, billing infrastructure and administrative support. These structures are widely used across general practice and specialist settings.

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As the landscape of medical practice management continues to evolve, practice owners and managers must navigate the complexities of staffing - one of the highest areas of cost and legal risk. Among the most important decisions you’ll face is whether to engage doctors as employees or independent practitioners. While the flexibility of independent practitioners may seem attractive, misclassifying staff can lead to significant legal, financial, and reputational consequences.

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Across Australia, allied health clinics are expanding. Physiotherapists, psychologists, occupational therapists, speech pathologists, dietitians and podiatrists are increasingly being integrated into general practice settings, multi-disciplinary clinics and specialist health hubs. For many clinic owners, whether operating one or multiple clinics, this expansion is deliberate and a strategic choice.

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Across General Practice, allied health and multi-disciplinary clinics, we are seeing a steady rise in the same enquiry.
A practice owner decides to engage a physiotherapist, psychologist, dietitian or speech pathologist.  A consulting room is available, the practitioner will pay a fee and they will operate as an independent practitioner.  On the surface, the arrangement appears simple.
Following this meeting of the minds, the question we receive typically reads something like this;

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