Questions over timing as 201 GPs sent ‘please explain’ letter on anaesthetics billing

An estimated one third of the nation’s GP anaesthetists have been sent a new compliance letter, despite clear calls from the RACGP to delay and modify the letters to avoid causing anxiety and fear during the COVID pandemic and ahead of the planned vaccine rollout.
 
The Department of Health (DoH) letter was sent late last week to 201 GPs – expected to be almost all GP anaesthetists – requiring them to justify their claiming of anaesthetic Medicare items without an eligible connected procedure, and to repay any erroneous claims. It is estimated Australia had around 600 GP anaesthetists as of 2018.

The new compliance letter is aimed at providers claiming Medicare Benefits Schedule (MBS) items 20100–21990 (other than item 21965), 22060–24136, 25200 and 25205 without an eligible therapeutic or diagnostic procedure for the same patient episode.
 
GPs receiving the letter will be asked to review their claiming of the items and repay incorrect payments or explain the claiming.
 
RACGP Rural Chair Dr Michael Clements expressed disappointment at the fact the compliance activity was going ahead despite repeated college protests since the letter was first flagged in July 2020. In response, the DoH delayed but did not scrap the campaign.
 
‘We know these letters generate fear, anxiety and stress in everyone who receives them, even when there’s no case to answer,’ Dr Clements told newsGP.
 
‘Each letter will generate hours of work for anyone who receives it. They’re now forced to deal with that and investigate it in the midst of preparing for the biggest rollout of any new medication in the country’s history. 
 
‘The fact it’s going out to a third of our GP anaesthetists, claiming they’ve been billing incorrectly – that speaks to an error in the Department’s thinking and suggests it’s a systemic problem.
 
‘It’s more likely that this compliance activity has cast the net very widely and captured a whole lot of people who have been practising perfectly appropriately.’
 
Dr Clements criticised the wide-scale targeting as well as ramping up the compliance activity just as GPs prepare for their role in what will be one of the largest public health undertakings in Australian history.  
 
The compliance letter does note that there may be ‘occasional circumstances where these claims are appropriate’ and asks GPs to review their claiming to ensure it meets MBS requirements.
 
But Dr Clements said he and other RACGP representatives had outlined a number of reasonable examples where it would be appropriate to claim anaesthetic MBS items without being directly linked to a procedure.
 
‘There are many good explanations for why this pattern exists. We gave the Department these reasonable explanations for this billing,’ he said.
 
Examples given included pre-anaesthetic checks and dental procedures, which could lead to a disconnect between billing anaesthetic items and other procedures.
 
GP anaesthetists are primarily rural doctors who have undertaken additional training to be able to perform anaesthetic procedures.
 
‘Their services provide immense capability for rural healthcare in rural towns. It’s perfectly appropriate for GP anaesthetists to use Medicare,’ Dr Clements said.
 
‘We are disappointed by these nudge letters and we will advocate for our members wherever and whenever.’
 
The compliance letter is the latest in a string of targeted letters described by the DoH’s Benefits Integrity and Digital Health Division as ‘light touch interventions.’
 
The DoH has ramped up its targeted compliance efforts in recent years, with some letters – such as the 2018 large-scale letter targeting opioid prescribing – meeting strong pushback from the profession.
 
The Professional Services Review’s annual reports also show that DoH compliance requests have steadily increased over the past five years, reaching 127 in 2019–20. By contrast, in the past four years the number of cases resulting in ‘no further action’ has dramatically reduced.
 
The 2020 compliance letter targeting mental and physical health co-claiming also triggered a strong backlash.
 
At the time, Dr Michael Wright, Chair of the RACGP Expert Committee – Funding and Health Reform (REC–FHSR) told newsGP he had concerns regarding the emerging technique of compliance-by-algorithm, where outliers are sent warning letters without taking patient cohort or individual circumstances into account.
 
By contrast, the effective ‘nudge’ letter targeting antibiotic prescription rates was received more positively by GPs and experts.
 
The RACGP is calling for feedback on the new compliance push. Responses can be sent to rural@racgp.org.au
 
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