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What are the most reviewed items under Medicare compliance?

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The Professional Services Review (PSR) has provided an overview of data which shows the MBS and PBS item numbers that were most commonly the subject of its reviews over the past two financial years.
 
Standard consultation items and chronic disease management services feature heavily in the list, while item 1215Y (paracetamol + codeine) is the only PBS entry in the top 10.
 
Overall, the top 10 reviewed items between 1 July 2021 and 30 June 2023 were: 

1. Item 23
2. Item 723
3. Item 36
4. Item 721
5. Item 732
6. Item 91809
7. Item 5020
8. Item 2713
9. Item 1215Y (PBS)
10. Item 5040

The list was provided earlier this month at a meeting of the General Practice Advisory Committee to the PSR, a group consisting of representatives from medical peak bodies that meets with the PSR Director and staff twice a year.
 
RACGP President Dr Nicole Higgins chaired the August meeting and said it was ‘a valuable opportunity’ to hear about recent PSR activity and share feedback from members on issues with the compliance process.
 
‘GPs shouldn’t be afraid of the PSR,’ she told newsGP.
 
‘Very few health professionals are referred to the PSR – only 59 GPs were referred in 2022–23. Most of that was around the inappropriate use of item numbers and referred by the Department of Health and Aged Care’s Medicare Compliance Unit.’ 
 
Across both financial years, a total of 131 GPs were referred to the PSR: 72 in 2021–22; and 59 in 2022–23.
 
Inadequate record keeping was cited as a common concern, for example insufficient notes to allow another practitioner to take over the patient’s care if needed.
 
Issues with the chronic disease management items included not personalising templates for the patient, plans not having changed at all over several years, and no evidence of having consulted with other providers when billing item 723 (Team Care Arrangements). 
 
So, how can GPs avoid non-compliance?
 
Dr Higgins said basics such as good note taking and understanding of the item descriptors is ‘essential’.
 
‘I acknowledge that sometimes it is difficult when we are under the pump and people are waiting … [but] keeping good notes is part of being a GP,’ she said.
 
‘The PSR uses peer review to look at individual circumstances, so if a rural doctor is up before the PSR, it will be rural GPs who will be there to support and also provide context around the unique issues that may have contributed to the notification.’
 
The PSR advised that while reviewers do not require extensive notes, they do need to understand what took place during a consultation and what the time was spent on. Notable concerns around prescribing relate to which antibiotics were prescribed and why, and that often there is no detail in the clinical notes to explain this. 
 
The review body also noted there is no specific type of practice or location that stands out in terms of which GPs are referred.
 
Despite the relatively few practitioners who attract the ire of the PSR each year, GPs often report being fearful of the regulator and its investigations. To help ease some of these concerns, Dr Higgins said the college has been working with ‘tireless’ PSR Director Dr Antonio Di Dio to ensure ‘an educative approach versus punitive’.
 
‘We will continue to meet regularly with the PSR and develop resources for members,’ Dr Higgins said.
 
GPs can find out more from the guide to the PSR process and the RACGP’s webpage containing links to MBS educational resources, including information on record keeping.
 
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MBS items Medicare compliance Professional Services Review PSR

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