RACGP warns against ‘Robodebt style’ automated decision-making

The RACGP has raised concerns about the potential for GPs to be impacted by ‘Robodebt style automated decision-making’ in incentive payment administrative processes, as it responds to potential changes to health laws.
 
The Health Legislation Amendment (Incentive Payments and Other Measures) Bill 2026 aims to establish a framework for health incentive payment programs and modernise the programs.
 
While the college supports the overall intent of the legislation, its submission says it cannot endorse it unless key changes are implemented, including addressing concerns around automated decision-making.
 
RACGP President Dr Michael Wright said that at a minimum, the legislation must be amended to require ‘robust and meaningful’ human oversight and review mechanisms embedded in the compliance process to ensure decisions are accurate, fair and transparent.
 
Having previously warned about the use of AI to manage Medicare compliance activities, the college raises concerns regarding the proposed use of automated decision-making for incentive payment programs.
 
It says ‘inaccurate AI-driven decisions’ could disproportionately burden general practices, particularly where compliance is assessed without adequate consideration of factors such as practice and patient demographics, potentially resulting in incorrect decisions and lengthy review or appeals processes.
 
‘Decisions relating to eligibility, compliance and participation often involve complex clinical and operational circumstances that require professional judgement and cannot be adequately reduced to a set of automated rules,’ the submission states.
 
‘Eligibility determinations may involve nuanced clinical and practice-level considerations that automated processes are unlikely to fully capture, increasing the risk of inaccurate or unfair outcomes.’
 
Decisions that have financial or professional consequences for GPs or practices should be made by appropriately qualified human decision-makers, with access to clinical advice where necessary, the college says.
 
And while it welcomes the Bill’s proposed transparency requirements for automated administrative decision-making, concerns remain around the ‘increasing reliance’ on automated systems to assess eligibility and carry out administration for government programs, including health incentive payments.
 
To address this issue, the college is calling for any changes to incentive payment program rules to have ‘early and meaningful’ consultation with peak bodies, including the RACGP, to ensure they are fit for purpose and respond to evolving health system priorities.
 
An expert advisory group should also be established with key stakeholders when the legislation is implemented.
 
Also noted in the submission is a lack of ‘lock in measures’ for incentive payments, with the college urging the Bill be amended to reflect that these keep pace with inflation and the cost of providing high-quality patient care, and ensure that measures do not result in financial losses for patients accessing care through general practice.
 
‘Practice incentive programs are critical to the viability of general practice and ensuring patients can access the care they need,’ Dr Wright states in the submission.
 
‘Any changes to these programs should be carefully considered to minimise any adverse impacts on patients and their health outcomes.’
 
The RACGP welcomes commitment from the Government that practices will ‘transition seamlessly’ to the new legislative framework without the need to reapply or undertake additional administrative processes.
 
However, it says a lack of robust safeguards around compliance powers to prevent ‘red tape’ administrative barriers will take time away from patient care – particularly for smaller and rural practices that may find additional requirements disproportionately onerous. 
 
A ‘proportionate approach’ to compliance is the college’s recommendation, with implementation of the legislation ensuring healthcare providers are given the opportunity to adapt their billing practices prior to being subject to compliance activities.
 
The RACGP is also asking Health, Disability and Ageing Minister Mark Butler to report back to Parliament on its proposed actions within 6–12 months of the legislation’s commencement.
 
A Senate Committee is currently investigating the legislation, with its final report due on 14 August.
 
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Health Insurance Act health legislation Medicare compliance practice incentive payments practice incentive program