Welcome to the first edition of the RACGP’s Regulation and Compliance news! 

These quarterly newsletters will provide important updates on Medicare compliance and broader regulatory issues. In each edition, we’ll cover topics like current and future compliance campaigns, emerging compliance concerns and activities, and advocacy updates. We’ll also highlight key resources to support you to bill correctly. 

Overseas claiming 

In May 2025, around 4600 specialist GPs received education letters related to billing Medicare from overseas. A further 1100 received early intervention letters with a schedule of claims to review. Around 300 (27%) of those who received a schedule did not respond to the concerns raised in the letter, and the Department of Health, Disability and Ageing (DoHDA) is now considering whether to escalate these practitioners to an audit. 

Clinicians can only bill Medicare Benefits Schedule (MBS) items when the provider and patient are both in Australia, including for telehealth. 

Bulk billing and raising additional charges 

Bulk billed patients cannot be charged any out-of-pocket fees, including registration or membership fees. Exceptions apply for the supply of a vaccine from your own stock. Read DoHDA’s fact sheet for more information. 

In October 2025, DoHDA will be writing to around 550 providers, including 100 GPs, to encourage them to review their current policies and procedures when bulk billing. 

Self and family servicing 

You cannot bill the MBS for services rendered to yourself or immediate family members – see MBS Note GN.13.33. 

In October 2025, DoHDA will be writing to around 800 providers on this matter. Around 500 GPs will receive an educative letter and approximately 300 will receive a letter and schedule of claims to review. 

Separate to MBS billing rules, the Medical Board of Australia advises practitioners should, wherever possible, avoid self-diagnosis, treatment or prescribing, as well as treatment of anyone with whom they have a close personal relationship. 

Registering patients for MyMedicare without their consent 

Page 3 of DoHDA’s fact sheet provides information on patients registering with a MyMedicare practice, including measures for obtaining and registering consent. 

Potential misuse of MBS multidisciplinary case conferencing items 

DoHDA has commenced a risk assessment activity around multidisciplinary case conferencing items. MBS Note AN.0.49 provides guidance to ensure you are meeting all item number requirements. 

Referrals for geriatrician assessment and management plans (MBS items 141–147) 

GP referrals for these plans are required to specify the need for a comprehensive assessment and management plan. General phrases such as ‘for your opinion and management’ are likely to be insufficient. Instead, specific identification of the clinical question is required. See MBS Note AN.0.26 for further details. 

Opportunistic single issue business models 

DoHDA continues to assess compliance risks associated with single issue business models, including taking compliance actions in relation to business models where patients are prescribed drugs, such as semaglutide, and do not meet the Pharmaceutical Benefits Scheme (PBS) restriction requirements. 

More broadly than DoHDA’s concerns, there have been concerns raised about other business models including advertising for medical certificates and prescribing of medicinal cannabis. 

Approved pathology collection centres (ACCs) 

DoHDA has concerns regarding sites not operating in accordance with legislative requirements (‘prohibited practices provisions’). This includes potentially inappropriate business dealings, such as rental agreements predicated on the volume of pathology tests requested, and requestors being induced to order services from particular pathology providers. Stronger action may be taken against sites that do not appear to be operating or billing as Medicare collection sites. GP lessors may also be contacted about sites that are not billing. Please note that a rent agreement for a site that is not operating or has a rent more than 20% above the market rate may breach the prohibited practices provisions. 

The use of artificial intelligence (AI) to support MBS billing and clinical record keeping 

Concerned about the increasing use of AI and the risk that it may reduce a practitioner’s input to clinical decision making or automate decisions, DoHDA advises practitioners to review Australia’s AI Ethics Principles when using AI tools. Remember to: 

• always check any AI generated notes for accuracy 
• ensure you follow the ‘complete medical service’ principle that underpins the MBS 
• speak to your medical defence organisation (MDO) if you need advice on using these tools and what you are covered for if any issues arise. 

For more news and the latest advocacy updates, visit the RACGP website. 

The next meeting of the GP Advisory Committee to the Professional Services Review (PSR), chaired by the RACGP, is scheduled for 29 September 2025. This group consists of peak bodies and the PSR. The hot button issue of AI use in general practice will be high on the agenda. 

Where a practitioner provides several services (excluding operations) on the one occasion, they can choose to bulk bill some or all those services and privately charge a fee for the others, in excess of the Medicare rebate. See MBS Note GN.7.17 and the Services Australia website for details. 

Visit the RACGP website to find resources to help you bill Medicare correctly. If you have any questions or concerns around regulation and compliance, 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 – RACGP Regulation and Compliance Working Group