General

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

1 August 20

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.

Can I bulk bill a Medicare service and charge for a related non-Medicare service simultaneously?

1 August 20

A gastroenterology practice asked whether a service provider providing two services to a patient on the same day, one for which there is an MBS item number, and the other for which there is not, can bulk bill the MBS service and simultaneously collect private payment for the non-MBS service. The question related to an outpatient context and both services were clinically relevant for the treatment of the patient, meaning neither would be considered cosmetic. NB: The scenario presented in this question is distinct from the common scenario of bulk billing a consultation and charging a private fee for a cosmetic botox injection, which is permitted, because Medicare specifically excludes rebates for cosmetic procedures, which are not clinically relevant. In this scenario, both services are clinically relevant. It is an important distinction and often a point of confusion.

Can a group of specialists operating under a single brand, but with their own separate practices, agree to charge the same fees?

1 August 20

A group of haematologists in private practice, who operate across various locations under a single brand with a central point of contact, asked if they could agree to all charge the same fees. Behind the brand, they each operate their own private practices with separate legal entities, separate ABNs and so on. They also asked if anything changed if they all agreed to bulk bill everyone.

When I am covering another physician’s inpatients and it’s the first time I see the patient, can I bill an initial consultation?

27 July 20

When one physician covers anothers’ inpatients who have already been admitted, but are new to the doctor covering for the weekend, Dr A wanted to know if it is acceptable to bill a 110? Dr A’s instincts were that all encounters should be billed as 116 since they are generally part of the same episode of care, (even if provided by a different physician) but she had received conflicting advice.

If a specialist sees a non-admitted patient in an approved private emergency department, can they bill to Medicare and is the patient entitled to a rebate?

10 July 20

Billing to Medicare for non-admitted patients in public hospital emergency departments is strictly prohibited, even if patients have private health insurance and are happy to use it. This is provided for in various provisions of both the Health Insurance Act 1973 and its intersection with the National Health Reform Agreement. However, in this scenario, Dr A was a haematologist who worked at a private hospital with an approved private emergency department (ED). Dr A wanted to know whether non-admitted patients in the ED could be billed to Medicare and whether the patient would be entitled to a Medicare rebate. Further, Dr A wanted to know at what point a patient is considered an inpatient after a decision to admit has been made, so that the patient’s private health insurer (PHI) could be billed. Was it: 1. When the patient is physically out of the ED and on the ward, or 2. When a decision has been made to admit the patient, but the patient is still in the ED, or 3. When the patient’s admission status has been changed in the hospital administration system indicating the patient is an inpatient.

Can we bill to Medicare for public inpatients in public hospitals?

10 July 20

An administrator in a public hospital had been advised that they could start billing to Medicare for inpatient services including case conferences.

Can another psychiatrist, who is known to the patient, be the second participating doctor in a case conference?

10 July 20

Question: For case conferences involving psychiatrists and allied health personnel (item 855 to 866) can the conference include the treating psychiatrist, another psychiatrist known to the patient, and then allied health or mental health nurses who treat the patient in an ambulatory setting, or does the patient’s GP need to be involved as the second doctor? If so, can that GP be included via teleconference/video conference?

Can I bill using my provider number when a locum is covering for me?

10 July 20

Doctor A was an oncologist who understood that when on leave with a locum covering, Doctor A could continue billing as usual, even though Doctor B was acting as a locum and was providing all services to Dr A’s patients. Doctor A would reimburse Dr B for the locum services under an agreement they had reached.

Can we co-claim a consultation every time we do a bone marrow biopsy?

3 July 20

A haematologist said that he and some colleagues were considering personally performing bone marrow aspirates and trephines (items 30084 and 30087) and explained that the MBS rebates for these procedures barely covered the cost of consumables, let alone the time taken, so they would have to charge gaps. However, he had heard that they could also claim an item 110 or 116 consultation item number at the same time as every aspirate procedure, because they review the patient’s appropriateness for the procedure, and obtain their consent.