College calls on Health Minister to intervene in compliance campaign

The college has asked Federal Minister for Health and Aged Care Mark Butler to intervene after hundreds of GPs received letters querying their use of MBS item number 10997.
 
In an open letter sent to the Minister on 3 March, RACGP President Dr Nicole Higgins outlined members’ ‘significant concerns’ about the approach, which has focused on GPs’ co-claiming of chronic disease items and practice nurse support services.
 
She warned of ‘a ripple effect’ beyond the GPs who received the letter, which she said would worsen the ‘already low morale’ in general practice.
 
‘I strongly urge you to reconsider the value and purpose of this compliance campaign,’ Dr Higgins wrote.
 
‘We realise that the letters have now been sent and it is not customary for the Department to rescind these, however the circumstances in this case warrant your intervention.’
 
There were 596 GPs reportedly targeted by the campaign.
 
In their letter, the Department of Health and Aged Care (DoH) requests that GPs review their services.
 
‘The Department considers that item 10997 would not routinely be claimed at the same time as a [chronic disease management] item,’ the compliance letter states.
 
‘This is an opportunity to check your services have been claimed correctly and to address any incorrect claims in a timely manner.’
 
‘The Department may take compliance action, such as an audit, if concerns are identified that a provider has not met the MBS requirements and has been paid benefits they were not entitled to receive.’
 
The campaign immediately met strong resistance from GPs, who pointed out that the letters were produced at a time when the Strengthening Medicare Taskforce is advocating for improved multidisciplinary healthcare.
 
That point is raised by Dr Higgins in the letter.
 
‘The campaign is occurring at a time when we are looking to strengthen multidisciplinary care in general practice, and the letters devalue the care provided by nurses as part of general practice teams,’ she wrote.
 
Another issue cited in the correspondence is a lack of clarity around the MBS items under scrutiny.
 
‘There is nothing in the relevant item descriptors, explanatory notes or AskMBS Advisory to suggest these items cannot be billed on the same day,’ the RACGP letter states.
 
‘GPs have followed these descriptors and are justifiably shocked to receive correspondence suggesting they are “breaking rules”.’
 
As well as ‘problematic’ language, Dr Higgins said the tone of the letter caused ‘significant distress’ and a ‘massive amount’ of work for general practices forced to check their records.
 
Dr Higgins pointed out this ‘takes healthcare providers away from their clinical duties’.
 
‘Especially at this time of increased demand for services and burnout of healthcare workers, our communities would expect the Department to be supporting, rather than undermining, the psychological safety of their highly valued GPs,’ she wrote.  
 
The campaign was previously raised directly with Minister Butler last month by former RACGP South Australia Chair Dr Daniel Byrne, who spoke about its impact on ABC Adelaide.
 
‘All I’m trying to do is provide good care for my patients [and] get them to see the nurse instead of me for this care. It costs Medicare $40 to see me and $12 to see the nurse,’ Dr Byrne said.
 
‘I’m really upset as you can tell.’
 
Dr Higgins also called on the DoH to look into options for automatically rejecting incorrect claims when they are submitted.
 
‘The RACGP has long advocated for Medicare compliance educative processes focusing on prevention of incorrect claiming, rather than punitive measures and blunt instruments which can distract providers from delivering appropriate and high-quality care to patients,’ the letter reads.
 
Dr Higgins said she hoped the review of Medicare Integrity and Compliance by Dr Pradeep Philip, who was due to submit a final report at the end of February, will help address the issues raised.
 
She also acknowledged the DoH’s ‘ongoing willingness’ to discuss compliance activities with the college.
 
‘We look forward to continuing to engage constructively with the Department to minimise the impact of compliance processes for GPs who are acting in the best interests of their patients,’ the President wrote.
 
‘We do not wish to see compliance activities erode trust between GPs and government when we are strengthening our relationship and actively contributing to reform in the healthcare sector.’
 
For further information on billing chronic disease management and practice nurse support services, the following educational materials are available for RACGP members:
 

• MBS Note AN.0.47 – Chronic disease management items
• Chronic disease management patient information
• Chronic disease GP Management Plans and Team Care Arrangements
• eLearning programs – GP Management Plans
• eLearning programs and infographics – Team Care Arrangements
• MBS Note MN.12.4 – Item 10997
• Practice nurse items
• Billing multiple MBS items
• AskMBS Advisory on general practice services (see page 5)

chronic disease management Department of Health and Aged Care MBS item 10997 Medicare compliance