Mail Management and Postal Remittances Policy

Applicable to: Western Australian Government Health System

Description: Mail remains the most used way of sending and receiving information and it is essential that mail is processed in a planned, disciplined and consistent manner. A key component of financial accountability is that all public funds are recorded and banked immediately they are received. Capturing mail at source also needs to be supported by a records management program. A systematic approach to the management of records is essential for health services and the community to protect and preserve records as evidence of actions.

Legal requirements: State Records Act 2000, Financial Administration and Audit Act 1994

Mail Management and Postal Remittances

Background

Mail remains the most used way of sending and receiving information and it is essential that mail is processed in a planned, disciplined and consistent manner. A key component of financial accountability is that all public funds are recorded and banked immediately they are received. Capturing mail at source also needs to be supported by a records management program. A systematic approach to the management of records is essential for health services and the community to protect and preserve records as evidence of actions.

The Operational Circular, OP 1863/04 Mail Management and Postal Remittances was released on 28 October 2004. This Operational Circular aimed to address the Qualification by the Auditor General on the 2003/04 Metropolitan Health Service (MHS) financial statements. This would require an alteration in health services work practice in regards to the handling, opening and processing of mail in a centralised manner.

However due to confidentiality and ethical concerns raised by a number of stakeholders and health industry groups, the Operational Circular was withdrawn. Since both the Auditor General's qualification, and the confidentiality concerns needed to be addressed, the Mail Opening Policy Review Group (MOPRG) was formed at the instruction of the Director General.

The MOPRG noted that the aim of an effective and efficient mail distribution policy and service is to ensure the cost effective and timely distribution and opening of mail in a manner that meets accounting and record keeping standards. However, such a policy and service should maintain confidentiality and ethical standards required of a health service, and not transgress wherever possible the privacy of patients, staff and site tenants.

Please refer to the full Mail Opening Policy Review Report located at http://intranet.health.wa.gov.au/records/mail.cfm, which provides a discussion of the policy issues and underlying rationale.

Relevant Legislation

State Records Commission Public Records Policy 5 - Mail Management deals with mail handling procedures and recommends that all incoming correspondence should be opened, registered, classified and attached to a file or a document management system before being sent to action officers.

The State Records Act 2000 and the State Records Principles and Standards 2002 require government organisations to have a Record Keeping Plan (RKP) that complies with the principles and standards established by the State Records Commission. Further information about the State Records Act and associated Department of Health policies can be found on the HOLII Records Services page: http://intranet.health.wa.gov.au/records/state_records_act.cfm.

Treasurer's Instruction 701 to the Financial Administration and Audit Act requires agencies to include in their accounting manuals appropriate policies and procedures for the recording and receipt of postal remittances.

Scope

Organisational Scope

The Record Keeping Plan (RKP) developed by the Department of Health (DoH) provides evidence to affirm a regime of compliance with the State Records Act. The RKP applies to all employees of the WA government health sector ultimately reporting to the Minister for Health. This includes the Department of Health entities, public hospitals, public community health services, public pathology laboratories, public health and mental health clinics and services, public nursing homes, DoH contracted services and any other WA Government health sector organisational entities.

Records Scope

It should be noted that the definition of a "government record" is a record created or received by - (a) a government organisation; or (b) a government organisation employee in the course of the employee's work for the organisation, but does not include an exempt record. Indeed hospitals and health services receive a considerable volume of both government and non-government mail. The aim is for all Government Mail (being mail created or received by a government organisation or a government organisation employee in the course of the employee's work for the organisation) to be opened and recorded at the appropriate point. However the private mail of patients, staff and site tenants should not be opened by other than the addressee.

Best practice recommends that there should be 2 nominated officers at the mail opening/distribution points/areas to meet RKP compliance, yet this will depend on staffing and budgetary requirements of the area health services. Compliance with the RKP, is required by 2008.

Any alteration in mail handling practice needs to be combined with a training program to educate nominated Mail Opening Officers about confidentiality and receipt of postal remittances. Mail opening should always include at least 1 nominated Mail Opening Officer, predominantly to ensure postal remittances are handled effectively but also to begin to meet compliance required by Health's RKP for the registration of incoming correspondence.

Policy Statement

Capturing mail at one delivery and distribution point may be the most efficient way of undertaking mail opening, however confidentiality issues determine that mail is better opened at a number of distribution points within each organisation.

It should be noted that patient mail should not be opened but it should be acknowledged that of the volume of mail, patient mail is a very small proportion of the overall amount. However, given that the Auditor General's qualification centres on postal remittances relating to Special Purpose Accounts and the perceived need therefore to open all mail to determine if a remittance is contained within, is an important issue, which in part could be addressed through an education process at pre admission. Every endeavour would be made to identify patient mail, which should then not be opened.

Having undertaken revised mail addressing procedures and education for patients, it is then considered that the number of payments that might elude recording will be small. Other auditable processes for monies, such as Arrangement A and B reporting in relation to Medical Practitioner employment arrangements, for receipt of remittances, are in place.

The following principles underpin the development of the DoH WA policy for mail opening:

  • Privacy and confidentiality of mail must be maintained;
  • Mail containing government records must be opened and the records maintained in accordance with the RKP;
  • Patient mail is the property of the patient and should not be opened;
  • Private personal mail of staff is the property of the staff member and should not be opened;
  • Site tenant mail of site tenant is the property of the site tenant and should not be opened; and
  • All remittances must be logged at distribution points by the nominated Mail Opening Officer and delivered to a designated cashier daily as per Treasurer's Instruction 701 to the Financial Administration and Audit Act.

Mail Opening Program

Each Chief Executive shall ensure that the correct legal and administrative processes are strictly followed at these areas and incorporate the following principles:

  • All Government mail will be required to be opened in a secure and timely manner;
  • A central mail delivery point must be established for sorting and distribution of unopened mail.
  • A distributed model then allows for mail opening at a number of distribution points within the area health service. Area Health Services will determine, identify and document where the distribution points are within their health services, and rationalise the number of distribution points, whilst meeting confidentiality requirements;
  • Patient mail is the property of the patient and should not be opened, and within time constraints every endeavour should be made to separate patient mail from the health unit's mail and forward it unopened to the patient;
  • Site tenant mail of site tenant is the property of the site tenant and should not be opened;
  • Mail, which cannot be readily seen to be patient mail or site tenant's mail but which cannot be clearly seen to be mail to the health unit or a staff member should be subject to closer examination;
  • Health services should work towards ideal staffing arrangements and best practice to ensure the presence of 2 nominated officers, one of whom is trained to deal with postal remittances;
  • In relation to mail marked with privacy markings (ie. Personal, Private and Confidential, or other Privacy and/or Confidentiality markings), this mail should not be opened, except by the addressee or his or her delegate and one other person, where possible. This type of mail should ideally be logged and opened by 2 persons where one of whom wherever practicable would be the addressee or his/her nominee to ensure confidentiality. If the addressee or his/her nominee is not available within a reasonable period of time to attend mail opening then that mail may be opened by other persons;
  • It should be noted that mail not necessarily marked with confidentiality and privacy markings may actually contain confidential information, and staff within health services need to be aware of this. Examples of this may include mail for health service areas such as Chaplaincy, Social Worker, Human Resources (employee matters, job applications) etc.;
  • Whilst private personal mail of staff is the property of the staff member and should not be opened, staff should be encouraged to ensure that personal mail is not addressed to them at health services;
  • All remittances must be logged at distribution points by the nominated Mail Opening Officer and delivered to a designated cashier daily. Therefore an audit trail for remittances will be maintained from point of opening through to the take up of the revenue at a central point in the Area Health Service. This central point within each health service will be determined by each area health service. This includes the recording of any postal remittance (as per Treasurer's Instruction 701 to the Financial Administration and Audit Act);
  • Any mail that is opened by officers that are not the addressee will have the envelope re-secured appropriately in order that the contents are protected from loss other than where it is clear that the mail is official health service business;
  • Confidentiality training must be provided to staff that open mail;
  • Postal remittance training must be given to all staff who are nominated Mail Opening Officers - regardless of whether they receive cheques in the area or not;
  • Patient Mail, private personal mail of staff, and site tenant mail as far as practicable should not be opened. If inadvertently it is opened, it should be identified in regard to the point of opening, secured and delivered to the addressee;
  • All public funds must be recorded daily, which is a requirement of the FAAA.

Chief Executives are to ensure that appropriate arrangements are implemented in their respective area by no later than 30 June 2005 noting that RKP compliance is required by 2008.


Mr Terry Lennard
DIRECTOR
INFORMATION POLICY AND SUPPORT

Date of effect: 21 April 2005 to

Policy Framework

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