Target Market Determination

Purpose of this Document

The purpose of this Target Market Determination (“TMD”) is to comply with the Design and Distribution Obligations incorporated under Chapter 7 of the Corporations Act 2001 (“the Act”) by the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019.
This document aims to provide information to anyone who wishes to become a member of Xtras Health Plan Savings Scheme (ARSN 627076411) for their extras only cover as an alternative to traditional extras health insurance cover. It also specifies how the product is distributed and the conditions that apply as well as the frequency of the Review of the TMD

Legal Disclaimer

This document is not a product disclosure statement that applies to Xtras Health Plan Savings Scheme (ARSN 627076411) and does not consider your personal circumstances, financial objectives, health needs and objectives or any other needs you may have. Please read the PDS that applies to the scheme to make informed decisions for yourself or seek independent advice

Description of Target Market

This section is required under section 994B(5)(b) of the Act

Product Suitability and Intended Target Market. (RG 274.68 (a))

Xtras Health Plan Savings Scheme is not an insurance product. It is a managed investment scheme licensed by ASIC. It is designed to be an alternative to traditional extras health insurance product available from Health Insurance companies
Xtras Health Plan Savings Scheme is an extras only alternative to traditional extras health insurance product.
The product is appropriate for those who currently have extras cover either as a standalone or combined with hospital cover or are seeking to have extras health cover.

Likely objectives for joining the Scheme

a. Control out-of-pocket expenses associated with extras health needs,
b. Accumulate unused funds rather than lose it compare to traditional extras health insurance cover,
c. Budget for future health needs,
d. Access capped fees with health providers registered with the platform,
e. Use funds for non extras health needs. E.g. Hospital Gap Payments.

What Xtras Health Plan Savings Scheme is not suitable for.

This product is not suitable for Hospital Cover, Overseas Student Cover or any type of health cover for Visa purpose either for visit, migration or work residency purpose.

Key Product Description and Attributes of Xtras Health Plan Savings Scheme. (RG274.68 (b))

The key attributes of Xtras Health Plan Savings Scheme are

Key Attributes

Explanation of the attribute

Accumulation of Unused funds

Any fund that was not used in the current financial year accumulates for future years

Capped Fees

Platform Fee and Scheme Fees are capped as stipulated in the PDS for the life term of the membership of the scheme or termination of the scheme

Dedicated Health Savings Account

Funds in the scheme can be used for any health needs provided the health service is received in Australia, by an appropriately licenced health practitioner and provided by an appropriately registered health business

Issue Health Gift

A health gift can be issued from your balance in your account in the scheme towards the health needs of someone you care about. The health gift can only be redeemed at a registered health provider with the platform


In case of financial hardship, you can suspend future contributions with access to your funds. Suspension fee applies


Up to 25% of your funds can be withdrawn annually for non-health purpose. Withdrawal fee applies

Non preferred provider

Health providers who are not registered with the platform where you use your funds. A fee applies


If you cancel your membership of the scheme, the balance of your account will be refunded as defined in the PDS

Fund security

Member funds are segregated and held by a custodian

For all the details on the scheme please read the PDS.

Product and Target Market Consistency

The Product, and its key attributes, is likely to be consistent with the likely objectives, financial situation and needs of members looking for an alternative to traditional extras health cover in the target market based on the following:

a. There is 53% of the Australian population who have extras cover,
b. Not all extras health services is used every year, resulting in loss of funds to holders of such extras health insurance cover,
c. Extras health needs increase over time,
d. Cost of extras health insurnace cover increases every year, whilst the rebates do not increase. 
e. Extras health insurance products have limits and caps that could result in increased out of pocket expenses.

Distribution Conditions and Restrictions

This section is required under s994B(5)(c).

How is the product distributed?

The only way to join the scheme is online via the website. There are no paper application forms or customer service centre or other representatives of the scheme.

Conditions that apply to join the Scheme.

To ensure that the products are sold in accordance with the TMD: see s994B(5)(c) and 994B(8)(a)], the issuer of the product has taken the following factors into consideration
1. Wide market for the product
2. The ability to restrict the use of the product being distributed by other means other than those adopted by the issuer. Namely the joining the scheme only via the website.

Eligibility Requirements (RG 274.68 (c))

Xtras Health Plan Savings Scheme is designed with specific consideration and is only available for those who meet the eligibility requirements.
a. Must be verified under KYC requirements
b. Be an Australian Resident
c. Be an Australian Citizen
d. Be able to use online platform to interact and transact
e. Must have a mobile phone linked to the member’s account.

Financial Consideration of the Consumers in the Target Market

The minimum contribution to be a member of the scheme is $5 per day or $152 per month or $1825 per year. Other financial considerations for the consumer is as  below.
Platform Fee Annual recurring $199.00
Contribution Fee 1% of Contributions
Management Fee 0.5% of Monthly account balance.

Reviewing of TMD

The issuer of the scheme will review this TMD as per the following listed below.

Review Triggers

This part is required under section 994B(5)(d) of the Act.
If events or circumstances occur that would reasonably suggest that the TMD is no longer appropriate, the Issuer will review the TMD. This may include:
• an event or circumstance that would materially affect the manner in which this TMD has been determined. This could be changes to existing regulatory environment or the way extras health services are provided in Australia due to to changes in health regulation. Other factors that may influence the changes to the TMD may include significant event such as stock market crash, changes to banking regulations or substantial changes to Government schemes that impact the operations of the scheme and its target market as determined.
• a material changes to the design or distribution of the Product
• a significant dealing in the Product that is not consistent with the product’s TMD
• the nature and extent of any feedback received from members of the scheme such as members asking for inclusion of additional services currently not provided by the scheme or rise in member complaints
• experiencing significant regulatory issues with industry bodies or government entities eg ASIC AFCA investigations

Mandatory Review Periods

This part is required under section 994B(5)(e) and (f) of the Act.

Initial Review: This TMD will be reviewed within 12 months of the TMD approved date.

Periodic Reviews: This TMD will be reviewed at least every 5 years from the initial review date.

Distributors: Reporting & Required Information

This part is required under s994B(5)(g) & (h).
All complaints covered by this TMD will be reported to the product issuer on the same day it is received.
Significant Dealings
Any changes to the current method of distribution or significant changes in the product not consistent with this TMD within 10 business days.
Other information
Any referrer, who refers new members to the scheme will be required to provide information relevant to the scheme or referred to the PDS of the scheme.
Appropriateness of the TMD
This section is required under s994B(5)(c) and s994B(8)(a) &(b).
The Issuer has reviewed the Product and its key attributes by considering its purpose, past outcomes and likely future outcomes, and has reasonably concluded that the Product is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market as described above, when offered to the consumer in accordance with the distribution conditions listed above. The comparatively wide target market of the Issuer has been a factor in assessing why the distribution conditions and restrictions will make it likely that consumers who purchase the product are in the class of consumers for which it has been designed.

TMD - Issuer Details 

Xtras Health Plan Ltd
Issuer ABN
Issuer ARSN
Xtras Health Plan Saving Scheme
TMD Approval Date
TMD Version
TMD Status

Australian Owned and Operated
Designed ground up by consumers and health professionals for a better extras cover.

XHP members enable their health and finances

Xtras Health Plan Savings Scheme (Xtras) is not an insurance policy, and you should consider your personal circumstances before deciding whether to open an account. Funds deposited to an account will not be eligible for a private health insurance rebate. Xtras may be considered as a replacement for or to act supplementary to private health insurance depending on your personal circumstances. Xtras Health Plan Ltd does not warrant that Xtras is suitable for your personal circumstances, and you should consider your health and financial needs before deciding whether to open an account. There is a risk that you may have insufficient funds in your account to meet the costs of health treatment depending on the treatment required and the amount deposited to your account.
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