Australia Snapshot This month’s reporting covers April, May and June, and there are some startling cases among them. In total there were 28 adverse PSR outcomes across three months, more than $8 million in repayments, disqualifications extending as far as three years, two matters referred to the Major Non-Compliance (Fraud) Division, and one referral to Ahpra. 23 section 92 agreements: 11 effective in April, none in May and 12 in June. Five final Committee determinations: four effective in April and one in May. Two Federal Court decisions, with Dr Foong's judicial review and reopening applications dismissed on 2 April 2026; an appeal was filed on 7 May 2026. And in Dr Reece's judicial review proceedings, the court held that the PSR does not have to produce documents revealing any aspect of a PSR Committee's decision-making, but does have to produce documents that are clerical or administrative in nature. One referral to Ahpra in May. Two referrals to the Major Non-Compliance (Fraud) Division—one in May and one in June. Outcomes include the following practitioners:

• A respiratory and sleep medicine physician
• Many general practitioners
• A nurse practitioner
• A rehabilitation medicine physician
• A general physician
• An endocrinologist
• A psychiatrist
• A GP & consultant physician

Major April–May cases The largest repayment was $2 million by a respiratory and sleep medicine physician. PSR identified issues involving consultant attendances, respiratory testing and sleep studies, including inadequate clinical input, ineligible patients, prohibited combinations and deficiencies in CPAP assessment and reporting. A GP repaid $615,000 and was disqualified from item 91805 for 12 months after concerns about long video consultations and urgent unsociable-hours services, including missing or inadequate records, minimum-time failures, failure to meet the usual-practitioner requirement and services not shown to have been conducted by video. The Committee outcomes include several particularly serious matters:

• A nurse practitioner repaid $500,000, was disqualified from all MBS items for 36 months and all PBS items for 12 months after Medicare was used to subsidise spa treatments. Patients were also charged additional fees despite the services being bulk billed.
• Dr Shaukat Javed repaid $512,000 and was disqualified from all MBS items for 24 months. The findings included illegible and non-contemporaneous records, inadequate clinical care, unnecessary repeat home visits and billing multiple family members as separate single-patient visits.
• An endocrinologist repaid $400,000 for consultant attendance and telehealth services, including initial attendances that were not initial attendances, services billed without personally attending the patient, text messages billed as telehealth and minimum-time failures.

Dominant themes across the three months

• Record integrity: absent, generic, illegible, retrospective or insufficient notes appeared repeatedly.
• Time means time: professional attendance and telehealth minimum durations were commonly not met.
• Personal attendance: several practitioners billed when they did not personally attend the patient. In any other discipline—that would be fraud.
• CDM failures: patients were ineligible, plans were generic, and required collaboration with other providers did not occur.
• Telehealth scrutiny: phone, video, text and urgent telehealth services were frequently mischaracterised.
• Bulk-billing breaches: both the April nurse practitioner case and June psychiatrist case involved additional patient fees for bulk-billed services. More on this below.
• High-volume RACF claiming: personal attendance, clinical input, contemporaneous records and duration remained recurring problems.
• Prescribing and pathology: PSR repeatedly identified inadequate assessment, failure to meet PBS restrictions and clinically unjustified testing.
• Escalation pathways: two matters were referred to the Major Non-Compliance (Fraud) Division during the period—one in May and one in June—demonstrating that some concerns extended beyond inappropriate practice into matters warranting fraud investigation.

Disqualification summary Disqualification periods ranged from no disqualification to targeted item restrictions between 3 and 36 months.   IMPORTANT: THE PSR HAS NEVER SAID THIS BEFORE Bulk billing and charging an additional fee for the same service - no matter what you call it - is illegal. It’s actually fraud, though the PSR would not use that word. Our courts have. Administration fees, booking fees, "gap" fees, or any other fee attached to bulk-billed services are illegal. We have not seen the PSR specifically highlight this issue before, making it a timely warning to all practitioners. We do not know whether either or both of the two matters referred to the Major Non-Compliance (Fraud) Division involved the nurse practitioner and/or the psychiatrist identified in these outcomes, but they may well have been. Which means they may be found criminally liable as well. Bulk billing means free of charge. Nothing could be clearer. DO NOT CHARGE ANY ADDITIONAL FEES WHEN YOU BULK BILL – EVER! Payment Integrity Around the World United States – Largest healthcare fraud takedown in DOJ history (June 2026) The U.S. Department of Justice announced its 2026 National Health Care Fraud Takedown, charging 455 defendants, including 90 licensed healthcare professionals, across 45 states. The alleged schemes involved more than US$6.5 billion in false claims to Medicare, Medicaid and private insurers and included medically unnecessary testing, kickbacks, telemedicine fraud, opioid schemes and services that were never provided. Authorities highlighted their increasing use of AI and advanced analytics to identify suspicious billing patterns. Integrity signal: Large-scale analytics are rapidly becoming the primary method for identifying organised healthcare fraud. Full report here: https://apnews.com/article/justice-department-healthcare-fraud-9f55301f1af18863a959944276b3c9b1 United States – Advanced Pathology Solutions enters Corporate Integrity Agreement (July 2026) The U.S. Department of Health and Human Services Office of Inspector General announced a new Corporate Integrity Agreement (CIA) with Advanced Pathology Solutions. CIAs are one of the strongest compliance tools used in the United States, requiring organisations to operate under years of independent monitoring, auditing and reporting following government enforcement action. Integrity signal: Modern enforcement increasingly combines financial penalties with long-term compliance monitoring rather than relying solely on repayments. Full report here: https://www.oig.hhs.gov/compliance/corporate-integrity-agreements/browse-cias/advanced-pathology-solutions/ United Kingdom – Medical device fraud convictions (July 2026) The UK's Medicines and Healthcare products Regulatory Agency (MHRA) secured fraud convictions following a decade-long investigation into the supply of hospital baby-feeding devices bearing false CE conformity markings. The defendants were found guilty of misleading healthcare providers about the safety and regulatory approval of medical devices supplied to hospitals. Integrity signal: Payment integrity extends beyond billing. Procurement fraud and the supply of non-compliant medical devices remain significant healthcare integrity risks. Full report here: https://www.gov.uk/government/news/mhra-secures-convictions-after-a-decade-long-investigation-into-falsely-marked-baby-feeding-devices Global Takeaways Documentation remains the foundation of payment integrity. Whether in Australia, the United States or the United Kingdom, inadequate or inaccurate records continue to underpin the majority of enforcement action. Data analytics is now driving enforcement. Regulators are increasingly using AI and advanced analytics to detect unusual billing patterns, identify high-risk providers and intervene earlier than ever before. High-volume billing attracts attention everywhere. Unusually high service volumes, prescribing patterns and outlier behaviour remain one of the strongest indicators for targeted review. Payment integrity extends well beyond billing. Recent international cases demonstrate that procurement fraud, medical device fraud, prescribing practices and internal governance failures are all part of the modern payment integrity landscape. Regulators are becoming more coordinated. Multi-agency investigations, international cooperation and referrals between administrative, regulatory and criminal agencies are increasingly common. Compliance is shifting from detection to prevention. Around the world, governments are investing in real-time monitoring, proactive risk identification and stronger compliance frameworks rather than relying solely on post-payment recovery.