Telehealth rules tighten for nurse practitioners

Telehealth appointments are set for a shake-up, with the Department of Health and Aged Care (DoHAC) introducing an ‘established clinical relationship’ requirement for nurse practitioners (NPs) from November.
 
It follows advocacy from the RACGP, which has highlighted risks to continuity of care and a lack of consistency in telehealth rules.
 
The change will bring the rules for NPs to provide MBS-funded telehealth appointments into line with GPs.
 
The Australian College of Nurse Practitioners (ACNP) recently advised its members that ‘the “established clinical relationship” requirement will apply to Nurse Practitioner Telehealth MBS items’.
 
A spokesperson for the DoHAC has since confirmed those changes to newsGP.
 
‘From 1 November 2025, the established clinical relationship criteria will be introduced to MBS NP telehealth items to align with current GP telehealth requirements,’ they said.
 
‘This change will mean patients wanting to claim an MBS telehealth consultation will need to have had one face-to-face consultation with their NP, or another practitioner at the same practice, within 12 months preceding the telehealth service.’
 
In the wake of the changes, the RACGP thanked the DoHAC, saying the move is a common-sense application of consistent rules for accessing care from a provider that knows the patient.
 
The DoHAC spokesperson said exemptions will apply to children aged under 12 months; people who are homeless; patients at an Aboriginal Medical Service or an Aboriginal Community Controlled Health Service; those isolating due to COVID-19 or a public health order; patients affected by a natural disaster; and blood borne virus and sexual or reproductive health consultations.
 
Current MBS telehealth regulations require GPs to have a pre-existing clinical relationship, including a face-to-face consult within the past 12 months, with exemptions for selected services and patient groups.
 
Until now, that rule had not been introduced for NPs, despite a recent scope-of-practice expansion giving them greater autonomy to prescribe and provide Medicare services.
 
The RACGP had warned that disparity could fuel the rapid growth of telehealth-only nurse services and potentially undermine high-quality care.
 
Earlier this month, it wrote to the Federal Health and Aged Care Minister Mark Butler, Opposition Leader Peter Dutton and Opposition Health and Aged Care spokesperson Anne Ruston to highlight the issue and encourage ‘levelling the playing field’.
 
For RACGP President Dr Michael Wright, the changes to telehealth rules are a positive move.
 
‘The college has been asking for this loophole to be closed and for there to be consistency so that telehealth services are only provided to patients with an existing clinical relationship, except in some extenuating circumstances,’ he told newsGP.  
 
‘It is great to see that this consistency will roll out – the sooner the better, so that patients will be encouraged to see their regular provider for their ongoing care, including access to telehealth services.’
 
The change is also in line with recommendations put forward by the MBS Review Advisory Committee (MRAC).
 
In its Telehealth Post-Implementation Review published last June, it said eligibility requirements are not applied consistently.
 
‘The MRAC considered it appropriate to apply the existing relationship rule to nurse practitioner telehealth items as it applies to similar consultations provided by GPs,’ the review states.
 
Among its 10 recommendations was a suggestion to ‘introduce eligibility requirements and exemptions to nurse practitioner MBS items and midwifery MBS telehealth items, including selected services which have no established clinical relationship requirement’.
 
In its response to newsGP, the DoHAC said the MRAC recommendation ‘recognises that higher quality care is achieved through telehealth when it is provided in the context of a continuous clinical relationship’.
 
Introduced in July 2020 shortly after the widescale adopting of telehealth prompted by the COVID-19 pandemic, the established clinical relationship rule was welcomed by the RACGP as a way to ensure high-quality healthcare is carried out by those with knowledge of a patient’s medical history.
 
The rule was also designed to limit cost blowouts and the potential for ‘predatory’ marketing by telehealth providers.
 
Associate Professor Rashmi Sharma, who chairs the RACGP Expert Committee – Funding and Health System Reform, said NPs made a ‘huge contribution’ to the Australian health system but the eligibility rules were out of step.
 
‘The current absence of this requirement afforded to NPs promotes inconsistent regulatory oversight,’ she told newsGP.
 
‘It opened the door to the establishment of NP telehealth services that are able to access the MBS without the pre-existing clinical relationship requirement.’
 
Last November, the Nurse Practitioner Collaborative Arrangement ended, expanding the scope of practice for NPs.
 
The changes gave NPs greater autonomy to prescribe medicines and provide Medicare services without approval from a GP, which was previously required.
 
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