A: The Australian Government has extended the temporary MBS telehealth
introduced on 13 March 2020 in response to the COVID-19 pandemic to 31 March
2021 on the
recommendation of the Australian Health Protection Principal Committee, but with
changes which take effect from 1 October 2020:
• GPs and Other Medical Practitioners (OMPs) providing COVID-19 telehealth
services are no
longer required to bulk-bill their patients.
• Temporary MBS COVID-19 bulk-billing incentive items 10981 (for GPs) and 10982
• The temporary doubling of fees for MBS bulk billing incentive items 10990,
64990, 64991, 74990 and 74991 also cease.
• Bulk-billed GP and OMP services provided using the MBS telehealth items are
MBS incentive payments when provided to Commonwealth concession card holders and
under 16 years of age.
It remains a legislative requirement under the Health Insurance (Section 3C
Medical Services - COVID-19 Telehealth and Telephone Attendances)
that GPs and other medical practitioners working in general practice only
telehealth or telephone service where they have an existing relationship with
in order to bill the consultation to Medicare under this Determination. Private
arrangements can still be made for telehealth consultations with appropriate
financial consent. These changes do not apply to specialists and other
Telehealth items that were available prior to COVID-19 also remain unaffected by
changes and can continue to be billed where appropriate.
An existing relationship with a patient is defined as:
• The medical practitioner who performs the service has provided a “personal
face-to-face service to the patient in the last 12 months. The Determination
specify where the personal attendance has to occur, so in our view this may be
either in the
medical practice, aged care facility or at a home visit; or
• The medical practitioner who performs the service is located at a medical
the patient has had a face-to-face service arranged by that practice in the last
This can be a service performed by another doctor located at the practice, or a
performed by another health professional located at the practice (such as a
or Aboriginal and Torres Strait Islander health worker); or
• The medical practitioner who performs the service is a participant in the
Deputising Service (AMDS) program, and the Approved Medical Deputising Service
(AMDS provider) that engages the medical practitioner has a formal agreement
with a medical
practice that has provided at least one face-to-face service to the patient in
the last 12
The requirement to have had a face-to face consultation in the last 12 months
does not apply
• children under the age of 12 months
• people experiencing homelessness (see below)
• people located in a COVID-19 impacted area (see below)
• people receiving an urgent after-hours service (in unsociable hours)
• people who receive the service from a medical practitioner located at an
Medical Service or an Aboriginal Community Controlled Health Service.
A person is considered homeless if their current living arrangement:
(a) is in a dwelling that is inadequate; or
(b) has no tenure, or if their initial tenure is short and not
(c) does not allow them to have control of, and access to space for
Telehealth consultations can still be conducted and billed to Medicare with a
person who is
in a “COVID-19 impacted area”. This means a patient who, at the time of
telehealth service, has had their “… movement restricted within the State or
by a State or Territory public health requirement applying to the patient’s
location”. The Determination doesn’t specify what constitutes a “public
requirement”. We have clarified with the Department of Health that the exemption
areas subject to specific restrictions such as Melbourne and Mitchell Shire, but
“Patients that test positive for COVID-19 and/or are subject to quarantine or
restrictions on the basis State and Territory health authorities”.
This will potentially cover a range of patients who have had their movement
state or territory public health orders or public health guidelines on
Examples of this, based on the NSW and Victorian laws, are:
• People who live in Melbourne and the Mitchell Shire subject to restrictions on their movement.
• People diagnosed with COVID-19 who are subject to self-isolation orders such
as the Public Health (COVID-19 Self-Isolation) Order (No 2) 2020
the Public Health Act 2010 (NSW) which directs that a person diagnosed
must self-isolate in their residence or other suitable location until medically
comply with the COVID-19 self-isolation guidelines.
• People returning from overseas who are subject to quarantine orders such as
Health (COVID-19 Quarantine) Order 2020 (NSW).
• People travelling across borders within Australia who are also subject to
orders. Public Health (COVID-19 Border Control) Order 2020 (NSW)
for example, people from Victoria to self-isolate under certain circumstances
arrive in NSW.
It is also likely to cover patients who have been required (by government or
guidelines) to self-isolate pending test results or because they are suspected
close contacts of confirmed cases.
However, patients living in areas that are not restricted by government lockdown
who are not suspected of having COVID-19, will not be able to access telehealth
simply because of their fears of contracting COVID-19 in the community if they
do not also
fulfil the criteria of having had a personal attendance with the particular GP
or that was
arranged by the particular GP’s practice in the past 12 months.
If these issues are unclear, you may wish to document that you have given
consideration as to
whether a patient has had their movement restricted within a state or territory
patient’s medical record.
Some common scenarios* include:
Q: I saw patient X at practice A 10 months ago. Can I provide a telehealth
(THC) for him from practice B?
A: Yes, as patient X has had a personal attendance with you in the past 12
Q: Patient X attended practice A 10 months ago and saw another GP, but I
wasn’t working at
practice A at that time. Can I now provide patient X with a THC?
A: Yes, as patient X has had a personal attendance with a GP at practice A
last 12 months.
Q: I have had regular THCs with patient X over the past four months since the
started, developing a good clinical relationship, but I have not yet seen
the patient in
person and the patient has never attended my practice in person in the past.
continue to provide THCs?
A: No, patient X needs to see you in person before you can continue to
bill Medicare for any THCs. Alternatively, patient X will need to arrange a THC
doctor at their former practice if they attended there in person within the last
Q: I saw patient X in her home/nursing home in March but otherwise we have had
THCs due to
her vulnerability to COVID-19. Can I continue with the THCs?
A: Yes, you have had a personal attendance with patient X in the past 12
Q: Patient X is a new patient. She is unwell and doesn’t want to come into the
fear of contracting COVID-19 as her husband is immunocompromised. She
doesn’t live in a
‘hotspot’. I am unable to do a home visit. Can I see her via a THC given her
A: These reasons do not fall within the exemptions listed in the
patient will need to come and see you face-to-face or attend the hospital or
contact her old
practice to see if they will do a THC if she can’t get in to see you. You have
the option of
doing a THC and privately billing the patient with informed financial consent.
*These scenarios are based on the assumption that the consultations are not
covered by the
telehealth items applicable to GPs prior to COVID-19.
Insurance (Section 3C General Medical Services – COVID-19 Telehealth and
Attendances) Amendment (Patient’s Usual Medical Practitioner) Determination
• MBS changes:
• factsheet on telehealth items
• factsheet for GPs
• RACGP website
• View the Department of Health’s COVID-19 Telehealth Items