This edition covers recent Medicare Benefits Schedule (MBS) billing trends and compliance risks, updates to the RACGP website, and the latest education to support your understanding of Medicare.

Chronic condition management
Analysis of claiming following the 1 July 2025 changes to the MBS chronic condition management framework will commence this month. This will allow the Department of Health, Disability and Ageing (DoHDA) to have a full 12 months of data to determine if claiming has shifted following the introduction of GP Chronic Condition Management Plans.

Telehealth
Current focus areas include the eligible telehealth practitioner requirement and working with Ahpra and the Therapeutic Goods Administration to develop a treatment strategy to address concerns related to on-demand telehealth platforms.

Item 91891 remains the most commonly billed GP telehealth item. DoHDA’s current analysis indicates potential non-compliance with the eligible telehealth practitioner requirement may be occurring at a higher rate for video consultation items than phone items. Future analysis will also consider additional exemption pathways, including MyMedicare registration, with the department commencing this work shortly.

Multidisciplinary case conferences (MBS items 735–758)
Analysis undertaken by the DoHDA for services performed between 1 April 2025 and 30 March 2026 shows 89,200 case conferencing items billed by GPs, and $11.6 million in benefits paid. While there do not appear to be systemic issues with GP claiming, compliance concerns include:

• claiming at significantly higher volumes in comparison to peers (may be explained by practice location and patient demographics)
• upcoding – billing a higher paying time-based case conferencing item without meeting requirements
• co-claiming with items such as professional attendances and practice nurse services (item 10997)
• long daily servicing (>5 hours)
• unmatched services – where a patient receives an organise service and no participate item was claimed on the same date of service by another provider, and vice versa.

DoHDA acknowledged the heterogeneity of general practice will influence billing trends in this space, with some practices having non-GP specialists and allied health professionals onsite, while others must engage with these providers remotely. The department is continuing analysis and engagement across relevant specialist items, therefore, decisions relating to any potential compliance action have not yet been made.

Aged care
Current compliance risks in residential aged care include high servicing (particularly after-hours), safety and quality issues tied to telehealth business models, billing item 91891 to communicate with aged care staff without the patient present, high rates of opioid prescribing, and approaching claiming thresholds under the 80/20 rule.

Prescriber Bag ordering
DoHDA has developed an editorial for prescribers in relation to Prescriber Bag ordering for dissemination.

Over recent months, concerns have been identified regarding compliance with the requirements of the National Health Act 1953 and associated Pharmaceutical Benefits Scheme arrangements. The editorial reinforces the intended purpose of Prescriber Bag arrangements, outlines appropriate ordering practices, and highlights the professional responsibilities associated with ordering medicines through Prescriber Bag arrangements.

For more news and the latest advocacy updates, including details of Ahpra’s registration renewal campaign, visit the RACGP website.

For information on regulation and compliance topics, the RACGP’s revamped webpage centralises resources, CPD, news and submissions. This page will be regularly reviewed and updated, so we suggest adding to your bookmarks for easy access.

We’ve also set up a webpage on changes to the Medicare assignment of benefit process. RACGP advocacy on this issue is continuing over the 12-month transition period, with the College engaging with DoHDA on options to reduce the administrative burden on practices and patients.

As part of the RACGP’s Medicare CPD project with DoHDA, we will be hosting a targeted member meeting on Tuesday 6 October on MBS care and management plans. Attendance will be capped at 40 members, so get in quick to secure your place. This is the first of four targeted meetings we’ll be running, and the session will be recorded for those who miss out.

Ahpra is running a webinar on mandatory notifications on Wednesday 23 September from 2.45 pm – 3.45 pm AEST. Register now to secure your place.

In addition to relevant MBS services, equivalent services funded by the Department of Veterans’ Affairs (DVA) are included in the prescribed pattern of services rules (80/20 and 30/20). This includes DVA services billed under MBS item numbers, such as standard consultations and telehealth attendances.

Visit the RACGP website for resources to help you bill Medicare correctly. If you have questions or concerns around regulation and compliance, or feedback on this newsletter, contact us at healthreform@racgp.org.au.

If you know someone who would like to receive this newsletter, please forward on and encourage them to subscribe on the RACGP website.

Kind regards,
Dr Tony Bayliss
Chair of RACGP Regulation and Compliance Working Group