COVID MBS items explainer and FAQs No.17, 2 April 2020


Dear Doctors and Health Care Workers

Here’s answers to today’s questions:

1.  Does the bulk bill incentive apply only to existing pensioners, concessions card holders and under 16s? 

Yes, it does, and only for GP and ‘other practitioner’ items, which are usually items in the range 52-57. The bulk bill incentives have been doubled in the recent changes and enacted in the Regulations which you can read here

 2.  Our GP practice is collapsing because we cannot remain viable by bulk billing and there is no one left to privately bill.

I am so sorry to hear this. We all hope you can remain viable pending the announcement of Stage 5, when we hope the Government’s attempt at forced bulk billing will be relaxed, at least for GPs.

3.  I am a specialist haematologist working in my own private rooms. I believe the new COVID-19 codes for specialists for telehealth or telephone (91824/ 91825 and 91834/ 91835 respectively) are only bulk-billed items. So:

a) Can I charge my usual private consultation fees for 110/ 116 (even if done by telehealth or phone) and if patient has signed a DB4 form, then they can expect to receive the MBS rebate straight into their bank account?

No. Firstly, you either bulk bill or charge full fees, even in non COVID times. It is illegal to bulk bill AND charge a gap. So, if you are charging your ‘usual private consultation fee’ the DB4 form is redundant. The patient should be paying your full fee upfront and then you can submit the claim to Medicare for the patient for their rebate or they can do it themselves.

We have been informed that patients of practitioners who have chosen to charge private fees for COVID items, have been successful receiving their Medicare rebates. This is up to you. Please read bulletin 1 to understand the legalities around this.

b) Or am I only allowed to charge the MBS rebate for such items with no gap?

Please review bulletin 1.

c) How do we indicate that a COVID-19 telehealth or telephone consultation has occurred?

The COVID items numbers themselves indicate it is a COVID service and depending on which item you choose it describes whether it was video or phone. So, no need to add notes or do anything further. The COVID item numbers are self explanatory.

4.  I usually travel to a rural area to conduct F2F consults charging private fees, pensioner rates or bulk billing depending on patient circumstances. I usually am able to charge 132 and 133 but there is no equivalent for these in telehealth. Two questions:

a) how do I now bill these as COVID or rural telehealth and how do I distinguish the two?

Have a look at yesterday’s bulletin here.

There is a bit of confusion around all the various types of available telehealth at the moment. It may be helpful to remember one key thing – the location of the patient is the deciding factor, NOT the location of you, the practitioner. So, for example:

i)  If the patient is in a usual telehealth eligible area, then use usual telehealth billing – so for you this may be item 132/133 + 112, but

ii)  If the patient is not in a usual telehealth area – so they live close by to you and would usually have come to see you in your practice, in person – then use COVID telehealth items which are single item number billings, eg: 91824

b) what is the best way to charge for a long and or new consultation in these circumstances? 

This is matter for your discretion. If you are using usual telehealth items, then bill as you always have. If you are using COVID, it is up to you whether you choose to accept the Government’s attempt to force bulk billing or charge private fees. See bulletin 1

5.  My question is actually a general one (not necessarily related to COVID) relating to transferability of referrals. It is widely accepted that a referral to one gastroenterologist is transferrable to another gastroenterologist of the patient’s choice. However, if the patient was referred, for example, to a colorectal surgeon for colonoscopy, could that referral be accepted by a gastroenterologist, given that the service being requested is also within that specialist’s scope of practice?

Ah, referral law! Wouldn’t it be nice if that was clear and straight forward, but alas it is not.

Even though the law uses the singular “referral to a specialist or consultant physician”, the content on Medicare’s website makes clear that the current departmental view is that referral to a named specialist is not necessary But, of course, the opposite is true when the referral relates to a public hospital outpatient department. Under the provisions of the National Health Reform Agreement a referral must name a specialist.

So, back to your question, it would depend on the specifics of each referral. If the referral states something like ‘please conduct screening colonoscopy’ then, Medicare’s current interpretation of the relevant legal provisions would suggest this referral would be transferrable as between gastroenterologists and colorectal surgeons, both of whom do colonoscopies. But, if the referral states something more generic like ‘irregular bowel habits’ then you’re in a grey area and probably should only transfer the referral within the same craft group.

Hope that helps. Sorry it’s not easier☹

6.  We are a public hospital network. In response to the COVID-19 emergency and to minimise the risk to patients and health practitioners, we need to temporarily move face to face outpatient consultations from their existing locations in major public hospitals, to other locations. Multiple moves may be rapidly required to be able to continue to provide a service. Can a specialist/consultant physician continue to use their provider number for the location from which the service would normally be provided. or should they apply for a new provider number for the new temporary location?

Have a look at bulletin 9, point 4 and let us know if this answers your question.

As a general point, best advice is to use their current public hospital provider numbers because they are linked to the relevant public hospital bank accounts. Will just make it quicker and easier for you. But if the doctors are using these provider numbers for inpatient billings as well you just need to be careful switching between software solutions to be sure you don’t take half your billing offline. Let us know if you want to chat about this. Happy to help.

7.  I am a private psychiatrist and have been using telehealth to bulk bill existing patients for the past two weeks. I met the vulnerable practitioner category (have a newborn at home) before this was made less important. I have a new patient booked in next week. Just to double check:

a) Have vulnerable criteria had been scrapped?

Yes, vulnerable criteria have been scrapped. We have now moved to ‘whole of population’ COVID telehealth.

 b) My only option is to charge a private fee outside of Medicare, because I haven’t seen the patient face to face before?

Yes, this is correct. There are no initial psychiatry attendances included in the COVID suite of items yet. The only other option (and the Government’s expectation) appears to be that you will continue to see your initial consults F2F and bill as usual.

c) If bulk billing is the only option, I’m assuming a longer time duration item no would be best?

It’s just important here to remember that you must always select an item number that accurately reflects what you did and don’t select a longer service because it pays more. Just select the item number that accurately reflects the time you spent (if it is a time based service) and the service you provided (after you have provided it) and you will be compliant.

 8. I am a Geriatrician. Can I just check that this plan will work?

a) I can telehealth and charge an out of pocket expense (my usual fee for a first geriatric assessment). Yes, you can.

b) But, on the invoice I do not write 141 (because it was not a face to face consult). Instead, on the invoice I write the fee (larger than a 110) and then the COVID item number for a first consultation (equivalent of 110). Yes, you can do this. But please review bulletin 1 about the legalities around forced bulk billing.

c) Then my front of house takes payment and then does electronic patient claim…… And the patient will get the Medicare rebate for the COVID item number (equivalent of 110) put into their bank account (Despite the government trying to make us bulk bill). We have been informed this has been successful.

Or does the patient have to claim the rebate themselves. We have no information as to whether this will be successful for the patient or not.

9.  Is there a 12 month period for using 149 as there is with 141/143 or can it be used for ongoing reviews for nursing home residents on telehealth?

Item 149 is the telehealth loading so it can never be billed alone. It can only be billed with related items 141/143 to which relevant frequency restrictions are applied.

10.  I am a Rehabilitation Physician who will be involved with an expanding Rehabilitation in the Home program. I would normally use items numbers 110 for initial attendance and 116 for review attendance. We are hoping to replace these with telehealth consultations. Can I clarify the referral requirements for me to use the corresponding telehealth item numbers – i.e. is a medical referral still required for me to bulk bill the consultation? 

Yes. All usual referral requirements apply. So, you cannot bill these services without a valid referral.

11.  I am a Psychiatrist.  Does the requirement still remain that either the patient or Psychiatrist must meet the COVID screening criteria prior to being able to use telehealth for patients local to my practice?  Has there been any consideration to date to open the opportunity for telehealth review of local patients by specialists so as to reduce the risk of exposure of either party and hence potentially preserve the viability of the established medical workforce a little longer?

No, the vulnerability requirements no longer apply. See above in point 7 (a).

There has been little attention for specialists at this point in time. The majority of COVID services apply to GPs, however, we understand Stage 5 will be specialist focussed.

Thank you everyone. Till tomorrow. Stay safe!

Margaret and the Synapse team.

COVID MBS items explainer and FAQs No 18, 3 April 20202…Read more

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