Are annual enrolment or membership fees legal in a bulk billing setting?

Context

Annual enrolment or membership fees have become a controversial feature of bulk billing GP practices in recent years. One example was the now defunct National Health Co-op in the ACT, which publicly charged a $100 per year membership fee and a $30 sign up fee in return for bulk billed services. It was even awarded State based grants to support this business model. However, there is debate around the legalities of these arrangements with the Federal Government expressing the view that such arrangements breach the bulk billing law.

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