COVID MBS items explainer and FAQs No. 7, 24 March 2020


Dear Doctors and all Health Care Workers

First an update on the news flash announced in yesterday’s bulletin.

1.  The Health Minister announced an extension of vulnerability criteria for Health Professionals.

This mirrors the criteria for vulnerable patients and represents Stage 3 of a 4 Stage initiative. The press release indicates Stage 4 may be revealed by the end of this week. Here’s the link

So, we are currently in Stage 3 (see below) and it’s not quite as promising as you may have liked.


WC March 23

From today the Government will allow all vulnerable general practitioners and other vulnerable health professionals who are currently authorised to use telehealth item numbers, to use telehealth for all consultations with all their patients. This includes health care providers who are:

  • aged at least 70 years old
  • Indigenous and aged at least 50 years old
  • pregnant
  • a parent of a child under 12 months
  • immune compromised
  • have a chronic medical condition that results in increased risk from coronavirus infection.
Stage 4

Moving Towards

The Government is consulting with the AMA, RACGP ACRRM, RDAA to co‑design stage four of our telehealth whole of population response. The co-design will look to the best practise expansion of telehealth items for all patients, with or without COVID-19, to see any general practitioner, medical specialist, mental health or allied health professional during the COVID-19 health emergency.


Effective yesterday, 23 March 2020, the COVID Determinations were consolidated. You can access the current law here. Whilst this is helpful, it is not an easy piece of legislation to wrap your head around because it cross references a lot of other law, so do not read it in isolation. I’ll try make sense of it for you.

2.  So, the first answer (which is a new answer to the same question from last week) from the pregnant Psychiatrist who asked whether she could consult from home via telehealth, the new answer is – yes you can, because you now meet the criteria for a vulnerable health professional.

3.  I am a Dermatologist and my patients are getting worried about coming to see me and my colleagues for a consultation. My question has 2 parts:

a) Can a Dermatologist bill for a review consultation item number 105 over the phone.

Subject to the below, no. Because this item requires personal attendance.

The equivalent COVID item for 105 is 91833 (telephone, when video not available)

You can claim this item number ONLY IF you meet the vulnerability criteria or your patients do, eg, over 70, chronic condition, you are in mandated isolation or the patient is. You cannot bill this otherwise at the moment.

You do have the option of billing using a private fee with no MBS item, see Bulletin No.6.

If your patients are in a usual telehealth eligible area such as an aged care facility remember that you can avail usual telehealth – eg, bill item 105 + 99.

b) Can a Dermatologist bill for item number 104 for a Skype Consultation.

The equivalent COVID item for item 104 is 91822 (assuming use of video such as Skype)

No, for the same reasons as above. 

4.  I am a GP and I’m wondering if I can bill 2715, 2717 mental health care plan numbers via telehealth if my patient needs an updated referral to their psychologist? Or will they have to book in to see someone else in person to get this done?

We answered this question yesterday, but I just wanted to add that after the announcement last night, if you, the GP, meet the “Vulnerable Health Professional’ criteria in Point 1, whilst there are no COVID equivalents of 2715 and 2717, you can bill the equivalents of usual GP consult items, or the specific GP mental health attendances currently included in the COVID suite. Here they are:

Description MBS item COVID telehealth COVID telephone
Short attendance 3 91790 91795
Less than 20 minutes 23 91800 91809
Less than 40 minutes 36 91801 91810
Over 40 minutes 44 91802 91811
FPS 30-40 minutes 2729 91818 91842
FPS > 40 Minutes 2731 91819 91843


5.  I am a psychologist and would like to run groups using telehealth with 6-10 participants for clients who are isolated/vulnerable as a direct result of COVID. What item number should I use?

Right now, group sessions have not been included in the COVID suite of MBS services. Your only option would be to charge private fees without using an MBS item number, see Bulletin 6.

6.  If you can’t bill inpatients because they are “admitted” then has the Health Minister overturned this provision by stating that you can bill any service to the vulnerable, which I assume includes inpatient services?

No, not yet. COVID billing is restricted to outpatient services only. This has been moved in the consolidated Determination to Clause 7(1) which states.

“ 7.         Application of items – general

(1)     An item in Schedule 1 or Schedule 2 does not apply to a service mentioned in the item if the patient is an admitted patient.”

The definition of an admitted patients has not changed.

7.  The usual code for an antenatal appointment is 16500. As pregnant women fit the criteria for vulnerable patients, what code can be used for a telehealth antenatal appointment?

Yes correct, pregnant women do meet the vulnerability criteria.

The equivalent COVID items for 16500 are 91853 (video) and 91858 (phone)

8.  I presume the updated message from government is that GPs and Specialists can use existing MBS telehealth codes with the new criteria for vulnerable groups. E.g. geriatricians can now bill a video consultation for a vulnerable >70 year old who lives close to the practice as a 141 + 149? I presume this is still video conference though and not also telephone?

No, not yet. At the moment all usual rules apply in relation to the billing of 141 + 149, so the patient has to be in a telehealth eligible area such as an aged care facility.

This may change when we move to Stage 4 at the end of the week.

9.  Given the Government is aiming for social distancing and reducing non-essential services – how can we provide telehealth for patients who think their needs are essential without increasing risk to ourselves? I am offering telehealth to my patients with a private fee, but they are not taking it up because they will not receive their Medicare rebate. Why can’t I bill a 104 (or a GP bill a 23 or 36)? It takes the same clinical time, needs additional infrastructure and there is in fact a saving to the Government because the telehealth loading (in my case, item 99) is not applied. Is this being entertained in order for us to provide ongoing care to our patients?

My understanding is that this is being entertained by the Government and a broader telehealth solution package will be announced at the end of the week.

The fundamental problem is the attempt to force bulk billing. It does not fit with the current legal infrastructure and whilst it was no doubt well intentioned (to protect patients from OOPs) all it has done is deny patients their rebate and therefore access to care.

But let’s see what the end of the week brings.

10.  If you read the item descriptions of 104 and 36 etc. “Professional attendance at consulting rooms.” I am in my consulting rooms, paying all my staff and teleconferencing with patients to maintain a less full waiting room. Yet these telehealth patients are still not eligible for a Medicare rebate. Either I charge them less and don’t cover costs, close the doors and don’t provide healthcare, see them in the rooms and expose the pregnant women or charge a 104? Is this legitimate given the current circumstances?

No, you cannot do this unfortunately. The legal definition of ‘professional attendance” requires face to face attendance, in the same room, together, at the same time, not using video. The relevant interpretation of the law by the Department is found in the MBS which says:

“AN.0.1 Personal Attendance by Practitioner

The personal attendance of the medical practitioner upon the patient is necessary, before a “consultation” may be regarded as a professional attendance.”

The MBS is not the law. It is best described as a departmental interpretation of how the Government wants the Medicare scheme to be administered. Best advice, however, is to apply its interpretation.

11.  I am aware of the new MBS telehealth item numbers for COVID and associated rules of use, which appear to be being progressively updated. One of the criteria states that the person is more susceptible to the COVID-19 virus because they are “already under treatment for chronic health conditions.” What does this mean? So, can I use the new COVID telehealth item numbers for pretty much all my patients, because I am a Psychiatrist and by definition most psychiatric illnesses are chronic?

Great question!

So, this one requires your clinical input, which is not my area of expertise. But, from a legal standpoint, none of the new COVID services have been the subject of legal interpretation because they are too new. No courts have touched these services and nor has Medicare tried to provide definitions, parameters or hard and fast rules. So, we are all in a bit of a legal void.

Best advice is to approach it based on definitions of ‘chronic’ that a body of your peers would accept. I think chronic conditions have to be present for more than 3 months but will defer to your clinical expertise on this.

So, for example, an acute psychotic episode is probably not chronic, but then again, an acute psychotic episode is more likely to present at a hospital anyway, where the COVID services don’t apply. In your usual practice, if you are treating chronic conditions like Bi-Polar, Schizophrenia, Depression etc, then, unless your colleagues form a different view, I would think these were chronic and would meet the COVID criteria.

Thanks everyone. We are so enjoying being able to support you as you manage your medical practices during this difficult period. Please keep the questions coming.

Margaret and the Synapse team.

 COVID MBS items explainer and FAQs No. 8, 25 March 2020… Read more

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