1. business and industrial

CURRENT CIRCULATION: 7997
DATE: 16 Dec 2012
ISSUE NO: 192
Welcome to Health & Life’s free email newsletter service. This service is to provide Health &
Life’s clients, contacts and those who attended our presentations with up to date information
on key financial and practice management issues that may affect your practice. Tell a friend
that we would be happy to add their email address to the distribution list. Please do not use
this as a substitute to seeking professional advice.
Writer in charge: Mr David Dahm BA.Acc, CTA, FCPA, FTIA, Ffin, FAAPM, FGLF.
How to Cope With the Tsunami of Change
Introduction – How do you run a practice?
I know this is a big edition and you may not have time to read it. Efficient and effective practices and
people do, find out why. This is a three step plan on how to manage change in your practice. Over the
next few weeks we will be broadcasting this edition in three parts. Alternatively you can download the
full story here.
Last month at a function, a perplexed doctor in his 50’s said to me “David we have got this large
block of land to expand our medical centre but we can’t get the project up”. After some
discussion he said “They didn’t teach us how to run a practice at med school”. Like everything in
life some structured training is required or there is the hard way!
In this bumper edition, I want to put fire to your feet. Over the last 21 years this is the best advice I
can provide to you about how to tackle some of the most difficult “elephant in the room” problems you
may or will experience. Are you open to change?
We will cover Big Ideas on how to run a practice for 2013 and beyond. Practices should use this
edition as a quick checklist as to whether your practice has a future or not.
A serious prediction for healthcare practices in the next few years
Over the next 2 to 3 years, many practices will either grow exponentially, merge, corporatise or cease
operating. Recent main stream media coverage revealed national research that “larger practices of 5
or more GPs increased at the expense of solo and small practices”.
As we head for a fiscal cliff the only thing certain is death and taxes, so my money is still on investing
into healthcare with the following exception: make sure the practice is managed well.
The Government has imposed some significant and unprecedented operational and infrastructural
changes on practices that will have a substantial impact on the type of skilled staff employed and
practices’ IT infrastructure.
Additional external factors such as the national low pay Nurses Union dispute, Medicare and
Australian Tax Office computer generated audits means a doctor’s affairs will be more open and
transparent and subject to instant scrutiny. Legislative change continues unabated. Practices are
going into information overload. This edition is a case in point. It is unavoidable.
In this edition we will cover the three simple but effective steps for how practices can take advantage
of this change.
The most successful organisations and people we know employ these steps with discipline, rigour
and enthusiasm.
Asking the right questions is far more important than getting the right answers. Ask the following:
1. What? What are the significant external and internal challenges and opportunities
affecting our practice?
2. How & When? How are we going to turn these ideas into action?
3. Who? Who do we delegate to and why? Trust but verify!
Table of Contents
1.
Asking the right questions is more important than receiving the right answers!
1.1. What? What are the significant external and internal challenges and opportunities
affecting our practice?
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•
•
•
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•
•
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The ePIP are you about to lose a lot of money?
E-health the new norm?
Taxation Audits on Doctors reveal big errors in providers’ pay
Take Out Personal Tax Audit Insurance
Doctors and healthcare workers are being prosecuted without evidence
The Australian Nursing Federation low pay claim - do you have a signed contract?
Succession Planning – what really works!
1.2. How & When? How are we going to turn these ideas into action?
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•
•
Governance – business ethics is just important as patient ethics
Systems – if it can’t be measured it can’t be managed – no more surprises
Training – you don’t know what you don’t know – be open and transparent
1.3. Who? Who do we delegate to and why? Trust but verify!
People – Firstly get the right people on the bus
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•
•
•
•
Owners & Management
Staff
Patients or Clients
External Advisers
Time Management – I am too busy for this!
2.
Seminars and No Obligation Meetings
3.
Where to from here?
How to Cope With the Tsunami of Change
1.1.
What? What are the significant external and internal challenges and opportunities
affecting our practice?
Give me six hours to chop down a tree and I will spend the first four sharpening the axe ~ Abraham
Lincoln
Identifying the most important challenges and opportunities is the key. It is critical to ask the right
questions rather than find the right answers. This filters out any bias. Some key challenges and
opportunities are below.
The ePIP are you about to lose a lot of money?
The most significant industry change facing practices today is to the (Electronic) Practice
Incentive Payment (ePIP) grant system. For some practices the normal Practice Incentive
Payment represents up to 5% to10% of a practice’s turnover and nearly 60% of a practice’s
st
profit. You need to be ready by 1 February 2013 or you may start to find the practice
experiencing cash flow problems for not being compliant with the new Pip rules.
Over the coming years up to $25,000 p.a. per full time equivalent GP could be lost if the
practice does not comply with the new program. Can you afford to ignore this change?
As mentioned in our last edition, the program is designed to enable a national electronic health
records system that patients can access anywhere at any time. This has significant privacy and
medico-legal problems, many of which have not been completely resolved with medical
indemnity insurers. So don’t believe all the glossy brochures and reports, practice owners are
personally liable if things should go wrong.
The ePIP requires practices to start re-evaluating their software and hardware systems, IT
protocols and staff training. Furthermore, doctors are expected to clinically code entries
correctly into this new national system or future funding may be put at risk.
A lot of this has not been in the main stream media. Yes, it is pretty much an Australia card in
disguise, however for patients it is a voluntary opt-in arrangement.
How practices are legally set up and who is the responsible officer are not straightforward
issues when it comes to registering.
For legal and operational reasons, make an owner and not your practice manager the primary
responsible person in charge. Also make sure if you have a service entity that this is the
registered entity. Contact us at [email protected] if you are not sure.
Getting ready for new the ePIP is not a user friendly process and involves a lot of management
time, including that of owners and all providers.
The AMA ePIP checklist is useful starting point. Like practice accreditation if you are not ehealth compliant practices will miss out on Government grants, they will make it hard to cheery
pick. The Government has spent over $500m on this program to date.
The Australian Association of Practice Managers also has a very useful E-Myth series that can
help with any compliance issues.
E-Health the new norm?
It is interesting to note practices focussed on e-health a number of new on line booking
systems and Skype consults on line for scripts and minor issues appears to be the new way of
delivering or enhancing services. See https://gp2u.com.au/ which has recently been in the
mainstream media. Practices need to have a strategy or they will miss out on what can be
perceived the easy work. More importantly it has the potential to disrupt continuity of care with
your patients. Patients should be educated with the up and downside of this trend.
It can be beneficial if a service could be provided by local practitioners. It can offer more flexible
working arrangements for providers.
The role of social media should not be underestimated in this environment from explaining
common treatments to promoting what and how people use your practice services see GP2U
video tutorials.
For the record they are not clients nor do we have any arrangements with them other than
showing this as an example of how the future of healthcare may look. For many practices how
they will respond will depend if patients start to use the service. It is worth thinking about if a
more offensive strategy is a better defence.
Taxation Audits on Doctors reveal big errors in providers’ pay
Due to the Global Financial Crisis we are seeing more computer generated tax audits based on
data matching a doctor’s income to that reported in practices.
Of serious concern, many of the major and popular medical software companies do not
prevent past billing information from being edited or tampered with.
We have noted many practices have no audit controls and significant and frequent errors from
$100 to $4,000 per person/pay period are being made, where doctors and providers are paid
on a percentage of their income.
This is adding significantly to a practice’s accounting costs. Note: many practice accountants
do not check this area because they say it is outside their responsibility. They don’t have the
experience or tools to check this area. It is important to ask and get any advice in writing.
These errors are embarrassing. They can make the practice liable in a tax audit or pay dispute
and have a serious impact on recruitment and retention.
Health & Life have successfully developed (which we have had the ATO scrutinised) an
alternative solution. Please contact us if you would like further information.
Take Out Personal Tax Audit Insurance
We highly recommend taking out tax audit insurance for the practice and individual doctors.
Check with your medical indemnity insurer. We understand Avant offers this insurance
automatically. Please check the terms and avoid the problem this poor doctor had with his
insurer see GP $12,000 out of pocket after ATO probe.
Doctors and Healthcare workers are being prosecuted without evidence
Another interesting development flowing from ePIP is how the Government Professional
Services watch dog will use the patient electronic controlled records system to data-mine
doctors for inappropriate practice see PSR software will extract GP patient records. This means
you can easily attract an audit for seeing too many patients. This is regardless of your
situation - if you are busy solo GP in a rural town, right through to not documenting a patient’s
treatment correctly.
The new Professional Service Review laws have been extended to practice owners and
management. They can be implicated if they do not comply.
We are concerned that the doctor/patient relationship is being unconstitutionally
interfered with and services are being unnecessarily withheld.
We have produced part one of a social media video called “I want to get in between your legs”.
The title is meant to be confronting as it is a public awareness campaign, it is meant to attract
attention. I am sure you will be just as upset by the content as we are.
It reveals how the Government unfairly prosecutes healthcare workers without evidence in
Australia. This seems to be more for budgetary than clinical reasons. This audit anxiety is
stifling medical/healthcare innovation that meets your patients’ needs and is reducing patients’
freedom to choose their provider.
This is a sneak preview of the full 15 minute video to be launched in late January which will
explain all. We would appreciate any feedback as we are planning a national campaign. I hope
you will share the full video with your patients so we can lobby the Government for fairer rules.
The Australian Nursing Federation low pay claim - do you have a signed contract?
We have widely reported this year the need for practices to have prepared Fair Work friendly
employment contracts. Employment agreements have to be signed by your staff in order to
avoid an underpayment of wages claim. This issue continues with over 1,000 practices in the
eastern states being forced to provide evidence against the Union’s allegations of
underpayment. This will spread nationwide if the Union’s action is successful.
We have worked pro-bono for our clients to successfully argue before the Fair Work Tribunal
that these are false allegations. The Union was on a fishing expedition successfully soliciting
copies of employment contracts. Many practice owners and staff (including those in corporate
practices) are being forced to give testimony before the Fair Work tribunal.
Succession Planning – what really works!
Every practice has a lifecycle. Are you throwing good money after bad if you can’t sell
your practice? What is it really worth? Doctors will pay to get into well run practices.
Practices must ask themselves what they will look like in 5 years time. Do we want to grow from
2 owners to 5, from 4 doctors to 6? Why would anyone want to join or buy our practice? What
income do we hope to earn for how much effort? Is there really any point in owning 100% of
nothing when you could own 50% of something? What is our business model?
If you can’t answer these questions, you probably have more ‘low hanging fruit’ opportunities
than problems. It is possibly also the main reason why you cannot recruit and retain your staff.
Nobody wants to join the Titanic anymore than they want to work in a practice that is not
keeping ahead of the times.
Health & Life can prepare an annual The Good, Bad and Ugly Report for clients. This helps
give a “MRI” view of your practice.
One of the most common mistakes that practices make is that they sell a percentage and not a
future to younger practitioners. Well structured practices offer owners from 90% to 110% of
billings and can be sold for this very reason.
Ownership should be sparingly offered to potential recruits that can work on and not just in the
practice. For example, a part-time GP owner is a good catch if they can recruit and train GP
Registrars. Practices need to ensure specific skills sets and expertise that complement the
existing Board.
Our clients use a Directors Pathway Program that vets potential owners to ensure they are the
right fit. What do you do?
1.2 How & When? How are we going to turn these ideas into action?
Efficiency is doing things right; effectiveness is doing the right things. ~ Peter Drucker
Leaders do the right thing, managers do the thing right!
Highly successful practice owner leaders know how to capture information and leverage from it
fast. This includes setting priorities and managing key tasks without the need to micro-manage
the outcomes. How do they do it?
Governance – business ethics is just important as patient ethics
Governance means ‘to do no harm’. It is now part of the new accreditation standards. It is a
thinking process that involves a structure as described below. It is there to promote openness
and transparency as well as sound and efficient decision making. The ability to delegate the
day-to-day issues without micro-management is a key benefit.
For example if you have 5 owner doctors charging $300 per hour, each meeting costs $1500
an hour. So you don’t want the practice manager to carry on about getting a $200 discount on a
photocopier machine. Good governance prevents this poor use of everyone’s time.
Where there is more than one owner, they have a Board and should elect a Chair. The role of
the Board is to hire and fire the CEO/Practice Manager and ensure policies and protocols and
the strategic direction of the practice is being complied with. We have a delegations policy for a
CEO/Manager that stops unnecessary meetings on the small stuff. An example would be
authorised spending limits and a limit when to get Board and/or Chair approval.
The Chair, on behalf of the Board, deals directly with the CEO/Practice Manager. No Board
Member or the Chair can publicly undermine the CEO/Practice Manager. The CEO/Practice
Manager is directly accountable to the Chair and Board to implement any Board decisions.
All parties must abstain from conflicts of interest. This means walking out of the room and
abstaining from voting on a decision where there is a perceived conflict e.g. whether to employ
a family member or friend.
Governance training should be for all owners and the CEO/Practice Manager. It should be
mandatory from the practice perspective and not just learnt in the classroom. This helps solve
and contextualise real time issues.
We offer a governance training service to our clients to help resolve those elephants in the
room in a humane way.
Systems – if it can’t be measured it can’t be managed – no more surprises
Great systems help you to delegate, so you can work on more complex issues that others
cannot. They protect you from making mistakes or when key staff leave or go on holidays. They
help you from having to repeat yourself and free you up for more profitable activities. This is the
most efficient, effective and profitable area to work on. You can do it because the thought
process is easy to understand and inexpensive to implement.
There is no point in making the same mistake unless you have learnt from it. Well documented
systems are proof of this point.
This leads to greater job satisfaction and less job distraction. People know where they stand on
how and when to do a task consistently and competently.
A key annual question the Board should ask if a key owner or CEO/Practice Manager was
hit by a bus what would happen? Is there a backup so we can continue to operate?
Systems are the key to delegating high level and complex work to staff less experienced or
trained. It enhances and up-skills your good staff which is great for recruitment and retention.
There are companies that do offer cost effective templated and customised healthcare practice
manuals. This saves you reinventing the wheel. Contact us for further information.
Monitoring tasks and regular reporting is the key. There is no point in receiving reports 12
months old. It leaves no opportunity for corrective action (see our example of a regular
reporting cycle our established clients use).
The key is to enforce any governance systems that have been implemented. Correct errors
and deviations immediately. Modify systems when necessary. They should be signed off by the
Chair.
Training – you don’t know what you don’t know – be open and transparent
You can’t have successful training without effective and well documented systems and
procedures. It is as simple as that. There is no magic. 100% of your operational issues are
resolved in a depersonalised way by establishing and training your staff on clear procedures.
1.3 Who? Who do we delegate to and why?
People – Firstly get the right people on the bus.
The wrong people can be a dangerous distraction when you need to keep you eyes on the
road. Always attract like minded people if you want to remain focussed on what you need to do.
Owners & Management
“Trust but verify”! ~ George Bush Snr
My advice is to sack the owners! Why? A great practice is one where the owners don’t have
the responsibility to meet the overheads and micromanage the environment. Eat well and sleep
well. Earn while you sleep. It should be a choice not a responsibility to come to work.
They should have at least one day a week off to think. Use this as a key measure.
Owners and managers need to lead, coach, enable and inspire. They must clearly state what
they want. What is the end point? Are we getting there? To maintain trust they must be open
and transparent and use a governance framework. This will allow them to empower and
delegate responsibilities efficiently and effectively. Owners should delegate one of their own
(the “Chair”) to monitor their strategic plans, budgets, systems and training are actually
working. They in turn delegate this role to the CEO/Practice Manager who implements and
reports back weekly. This is called working on the practice and not in it. The Chair and
CEO/Practice Managers do this by walking the floor. Observe if all their staff have a smile on
their face. Try test checking employment agreements to see if they are really being prepared
and signed off. Make sure it is done, don’t actually do the task. Another example is receiving
timely monthly financial reports. The Chair needs to feed back to management if there is a
problem.
Owners need to be the navigator in the taxi cab and not the driver. The CEO/Practice Manager
is the driver. It is about giving the right directions and making sure you are not about to go over
a cliff. Advisers should act like a Global Positioning Satellite (GPS). Most importantly owners
need to know when it is time to retire. Passing the baton by selling out or down to the next
generation at a fair price is critical. Mentoring the next generation of owners will ensure their is
a smooth and dignified transition. A fair price will be paid for your practice.
About Staff
Your staff can be the best or the worst risk management tool outside the consulting
room. A great practice culture is critical for success. Is it time to kill Bambi and start
celebrating your success?
A good CEO/practice manager plays a crucial role. They are in charge of money and morale.
They are the hub in the wheel. I also call them the air traffic controller. Make sure they get the
support they need.
The CEO/Practice Manager is probably the most isolated person in a practice. If they are
not keeping the owners happy, then it is the staff. It is a real juggling act. It does not have to be.
Ideally always have more than two staff backing up roles. Remember to annually ask the
question “if that person gets hit by a bus what are we going to do”?
Staff may have good technical know-how and an ability to apply this theory to the task at hand,
however they must want to. This is the most critical quality you need to find in your staff. It only
takes one staff member to pull down the rest.
I know patients who say they will not go back because of the defensive or grumpy receptionist
at the front desk. I do understand the reluctance to kill Bambi, the person who is not open
to change.
You know Bambi; the loyal staff member who is loved and respected by everyone at work. At
the end of the day, from patients to staff they are just are hungry for a result. We live in an
impatient, instant gratification society. I don’t agree with it, but it is what it is.
Bambi could be damaging your brand which makes recruitment and retention of staff and
patients more difficult than it needs to be. This can be a huge medico legal risk. Doing nothing
is the worst thing you can do. Nobody is bigger than the practice. Six monthly staff reviews
are critical. The most effective thing to do is to correct people on the spot when it happens.
Any later and it is too late. People don’t respond well to a six monthly shopping list of
complaints about themselves.
Key staff members and owners must inspire, coach and enable people. Morale is the key
to ensuring you have a successful and efficient outcome on any task delegated. Try using staff
surveys to monitor morale and workloads weekly.
Are your poor performing staff not working out? First blame the system, then the training
before the person. Only then give them 3 opportunities to improve their performance. If there is
no improvement, ask them if they are unhappy working with the practice. People should not
work in jobs they are not happy in. Don’t allow them to lose face and encourage alternate
employment. Please seek specific external advice from us if you are not sure.
Get the right people on the bus. Remember to hire slowly and fire quickly. Everybody loses if
the person is the wrong fit - especially the patient.
Recruiting the right people from the beginning is the key. We have an unorthodox way we
recruit our staff see our job ad flexibility and culture statement. It takes a little longer to recruit
but it actually works and saves a lot of time. It attracts people with attention to detail and
persistence; they want a career not a job. Google does something similar but in a different way.
The message is make it hard to get in.
Reward and Recognise
Most importantly don’t forget reward and recognise. It does not always take money. We have
an annual practice trophy for the team player of the year based on a peer reviewed team player
of the month to be announced at our Christmas lunch.
About Patients or Clients
Getting the right fit extends to attracting the right type of patients you want to help. We are only
after aspirational and ethical clients who sincerely want our help. People have to meet you half
way for anything to work. Work to the contrary and you open yourself to criticism and a possible
law suit.
So make your intentions clear. It is unethical to see patients you really do not want to help
(unless it is an emergency) because at all times the practitioner must act in the patient’s best
interest. Doing otherwise will only put more stress on your workforce and make your staff burn
out. It is better to have a happy doctor than none at all. It is important that they enjoy their work;
indifference can lead to serious medico-legal issues down the path. Look at innovative ways of
developing your workforce to meet this need by sub-specialising. For example, train nurses to
do more women’s health screening issues.
For one-off projects, establish a task force with set terms of reference and a time frame handed
down from the Board. Potential owners and or future management team members could chair
these meetings. This provides an excellent training ground for key role players looking to step
up.
External Advisers
The buck stops with owners! You can’t delegate this. You can delegate tasks but not
responsibility. The buck always stops with the owner. So delegate well.
Owners don’t have the luxury of blaming advisers, staff or anyone else but themselves
when things go wrong. Ignorance of the law is no excuse and being an ‘honest fool’ is not a
legal defence. If you don’t sight written and signed documents e.g. Fair-Work Compliant
employment contracts that are material to your practice, assume it never happened. Ask
yourself what are the real consequences (e.g. a $33,000 fine from Fair Work Australia and the
staff finding out there is a problem in the lunch room).
Not all advisers are the same and they have limitations. Remember all advisers have
limitations in experience, skills and overall capability. Often a problem not addressed may be
answered as “you never asked me” or “I assumed you would have told us”. There is a lot of
“free BBQ advice” out there you can get burnt by. It is important you compare apples with
apples when it comes to advisers. All important advice should be confirmed in writing.
Phone advice fades with memory and removes accountability and any legal defence.
Wherever possible, seek the advice of specialists. With a specialist there is a greater likelihood
that all issues are covered, not just the tax issue by your Accountant, the legal issue by your
Lawyer and the commercial issue by your Business Advisor. Real value comes from the
comprehensiveness of a service that can holistically embrace all your specific needs.
Use industry specialists – it is expensive acting on incomplete advice. Common sense
should always prevail. There are many Accountants who are a Jack-of-All-Trades. For 21 years
we have been mastering the healthcare industry because it is so complex and heavily regulated
that it needs to operate with an integrated thought process. If your adviser is not aware of all
the specific Health Care Regulations, their advice is incomplete.
Yes, we are registered tax agents and have benchmarked practices. We also deal with national
nursing union disputes, tailored Practice Agreements, practice valuations, and national
Pathology and Allied Health Leases (see what we do).
You can spend a lot of time receiving untimely disjointed and one-dimensional opinions. It is
important to tread with caution if this is the case. Make sure your advisers can back up their
advice with research and proof, not just hearsay.
Good advisers are independent, dispassionate, open, transparent and ethical. They avoid
conflicts of interest. They declare when they have one that may affect a material decision (for
example; the practice Accountant should not also do personal work of any owners where there
is more than one owner). It sets a discordant tone and is actually a conflict of interest. It is the
breeding ground for discontentment and expensive disputes amongst owners down the track.
Good advisers will make you money and reduce your risks from day one. This why we can
afford to offer a no obligation review of your practice affairs. Please email us at
[email protected] for more information.
If we can’t help we will tell you straight away, at no cost to you. At least you will receive some
thought provoking feedback.
There is no point in paying for advice if you are not going to follow it. This can only end in
disappointment. A good adviser will tell you this.
Time management – I am too busy for this!
This is the number one excuse we all make. The reality is, if I had a million dollars in my office
to give away next Monday, people would make it a priority. Reality Shot - your practice is
worth more than a million dollars. It is your single most important asset. It puts food on the
table for your staff, plus a few extra luxuries for the owners family, but most importantly it
provides for your greatest debt in life: retirement.
Don’t gamble with the most important thing that can give you a lifetime of financial security.
Unfortunately the stock market, real estate and the fixed term investments can never give a
greater tax effective return, control, independence, self determination and kudos than owning
your own practice can.
2.
2013 Seminars and No Obligation Meetings
If you would like your Medical Local to host a seminar, forward them this email with our seminar
details and copy us at [email protected]. We will contact them directly about presenting
in your local area.
We thank you in advance for your interest and support. You would be surprised how it only
takes one person to make things happen!
Catching up with David Dahm and the Team
We can talk about succession planning, business structures, effective tax planning, employee
vs contractor agreements, benchmarking and many more topics.
We are using this time to catch up with existing clients. If you are not an existing client, this may
be a good opportunity to tell us what is on your mind.
Ask yourself the following questions:
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•
•
•
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What new challenges am I facing?
What new opportunities do I anticipate?
What kind of support or expertise would be most helpful to me now?
What changes do I anticipate over the next year or so?
What more can Health & Life do for you, if anything?
We are now planning trips and one to one to meetings for next year. Please let us know if you
are interested and we will be happy to schedule you in! Please note that this is on a first come
first serve basis.
In the meantime, please feel free to contact us to arrange a no obligation teleconference to
get you started on any significant issues. Email us at [email protected].
3. Where to from here?
1.
2.
3.
Consult your professional adviser in relation to any advice suggested;
If you require any back issues of our news alerts please email us; and
If you are not sure about any issues raised in this broadcast, contact David Dahm on
1800 077 222 for an initial no obligation consult or email us at [email protected].
Health & Life provides comprehensive Practice consulting, accounting, taxation and
financial planning advice for group Practices and individuals. Email us for information
about our Employment Template kits for providers and support staff and our Doctors pay
Calculator.
Which topics would you like to hear about?
If there is a particular topic that you would like covered in one of our future News Alerts, please
email [email protected] and let us know what it is. We will then endeavour to cover
your requested topic.
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David Dahm BA (Acc.), FCPA,FITA, CTA, FFin, FAAPM, FGLF,Registered Tax Agent, Former AGPAL Surveyor - 10 years
of service
CEO & Founder
Health and Life Pty Ltd
National Tax Accountants and Practice Management Consultants
Phone: 08 8415 5400 or 1800 077 222
|
Fax: 08 8231 6767 or 1800 077 555
Level 5, 108 King William Street, Adelaide, SA 5000
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GPO Box 11042, Adelaide, SA 5001
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