COVID MBS items Explainer and FAQs, No. 23, 8 April 2020


Dear Doctors and Health Care Workers

Here’s answers to yesterdays questions. There’ll be another update later tonight.

1.  I am a Cardiologist and have a patient for whom I previously billed item 132, then 2 x 133 over the next five months. I have just reviewed the patient again (it’s now 13 months post the initial 132) and I plan to bill using COVID telehealth. Should I bill:

a) item 92422 (132 equivalent), even though it’s a review and not a new initial, or can I repeat this after 12 months?

b) item 92423 (133 equivalent), but I think I can’t because I didn’t bill a 132 in the last 12 months? 

c) item 91825 (116 equivalent), seems wrong given complexity of patient and I did a lengthy review?

Good question and we expect others will find themselves in the same position.

Considerations are a) the referral and b) the single course of treatment principle. Here’s the relevant components of the regulation that defines a single course of treatment with underlining:

“1.1.5  Meaning of single course of treatment

             (1)  Use this clause for items 104 to 131, 133

             (2)  A single course of treatment for a patient:

                      (b)  does not include:

                              (i)  referral of the patient to the specialist or consultant physician; or

                             (ii)  an attendance (the later attendance) on the patient by the specialist or consultant physician, after the end of the period of validity of the last referral to have application under section 102 of the Health Insurance Regulations 2018 if:

                                        (A)  the referring practitioner considers the later attendance necessary for the patient’s condition to be reviewed; and

                                        (B)  the patient was most recently attended by the specialist or consultant physician more than 9 months before the later attendance.”

Best advice as to how to apply this and the relevant referral issues to your scenario is:

  1. First, look at the referral. If it’s been 13 months since the 132 then a GP referral would have expired, unless it was indefinite.
  2. If it has expired, did you obtain a new referral before your recent consult? If no, then you can’t claim anything other than the unreferred items in the range 52-57. If yes, then you have a new referral and may be able to commence a new course of treatment under that referral, because it has been more than 9 months since you first consulted the patient. But note, a new referral does not automatically start a new course of treatment. The GP must deem a new review necessary, which would be evidenced on the referral itself.
  3. So, if the GP referral was/is indefinite, then you are in a grey area because the referral never expires, so the safest course of action would be to claim item 91825. You can’t claim item 92423 because the claim will be rejected without the pre-requisite 92422 as you have rightly pointed out.
  4. But, if the GP referral was new and the GP requested a complete review, then under the 9-month rule you can commence a new course of treatment and would bill either 91824 (110) or 92422 (132) depending on how long you spent and co-morbidities etc.

Hope that answers your question.

2 (a) I am an Endocrinologist and have been trying to do telehealth and bulk bill pts with COVID item numbers for the past two weeks. If I have done a phone consult for new patients and bulk billed them item numbers 91834 (same as item 110) but feel they need to come in so I can physically examine them. Would I bulk bill that second consultation as item 116 (ie review appt) as it is face to face or should I bulk bill them as item 110?

So, firstly, well done. Sounds like you are managing OK with the rapid transition to telehealth.

The single course of treatment provisions remain in force (see question 1) so you should bill item 116 when you follow up these patients in your rooms. Remember you can apply your usual billing practices for face to face consults and don’t have to bulk bill.

(b) Similar type of question, if we do a phone consult for a new patient and bulk bill item 91834 and because it is a complex patient (eg diabetes with renal disease), I have asked them to come in for a F2F consult and booked a 45 min appt, can I charge them with item number 132 at that appt time?

Yes, you can claim item 132 for the F2F follow up. There is nothing specific in the regs restricting the claiming of those two items on different days for the same patient if you meet all of the criteria.

3.  In the current environment, where you are asked to provide a specialist consult to an elderly rural patient >15km away or a new patient, and they cannot FaceTime, is it ok to do this per phone and still bill non COVID rural telehealth item 112 and 132, 133?

No. If you are billing usual telehealth items then you must continue to meet all of the relevant criteria for the billing of those items. They are video only, not telephone.

4.  Specialist physician here. If the patient has been seen within the calendar year, but has an existing and unexpired referral, do they need a new referral to be billed for a phone consult say COVID 110 (918434)? It is difficult to first get a GP referral physically or on phone in COVID times?

Hello specialist physician! No, you do not need a new referral to claim the COVID services. The existing, unexpired referral you have is fine.

5.  Can you do telehealth with DVA patients?


6.  I am a rehabilitation physician who will be moving to telehealth for outpatients, likely predominantly bulk billing. Could you please update regarding the current legal requirements when bulk billing under telehealth? In particular, what needs to be done to satisfy requirements for allocation of the Medicare benefit and the patient’s consent. Also, does this need to be done for each consultation?

In response to the first part of your question, have a read of bulletin 14 where we covered the issue extensively.

In response to the second part of your question, this is important for everyone

Yes, you must obtain bulk bill consent for every service for every patient. Medicare is a fee for service scheme and therefore you need to obtain consent to bulk bill for each and every service.

IMPORTANT: You cannot and must not try to obtain an overarching, ongoing consent. For example, I have seen practices ask patients to sign forms when they first attend the practice saying something like “You consent to us obtaining your Medicare rebate anytime, forever.” This is illegal, don’t do it.

7.  I am a private community Geriatrician that used to do F2F nursing home consults. I have a scenario where I am unsure how to approach the billing.

6/4/20 GP referred an urgent behavioural problem of a resident in a retirement village like facility, who is in isolation following discharge from a local hospital 10 days prior. I obtained as much history and examination findings as I could from the GP who had actually visited the resident. This call took about 30 mins. 

7/4/20 I spoke with the nurse in charge for 15 min on the phone and gave her my number and asked her to call me back later after checking a few things for me. An hour later, the nurse called and was able to provide most of the clinical information I needed, the observations and family history etc. This call took about 40 mins. A video recording of the patients’ behaviour was sent to me via skype. I then rang the next of kin for another discussion and to obtain extra information. The resident is not cooperating with staff and is not able to give consent.  

I have formulated my concerns and a treatment plan in a report that I am ready to send to the referring GP. Cumulatively, can I bill this item number to sum it up the work performed over 2 days?

Look, this is a difficult and unfortunate situation, because of the substantial amount of work you have done. However, from what I can gather you have not personally attended the patient F2F, or via video, or via telephone, though please correct me if I have misunderstood. So, you can’t claim any of the attendance items, neither COVID nor non-COVID, and there are no family conference type items that fit what you have described.

So, your only option appears to be to issue a private invoice with no Medicare item number on it, to the NOK for the time you have spent.

When you do go in to see the patient you can then claim your usual Geriatrician items starting from an initial consultation.

8.  What item numbers should Nurse Practitioners claim for Corona Virus consultations? Are there different items for indigenous patients? And what about pathology requests? 

NPs can claim items 91192, 91193, 91178, 91189, 91179, 91190, 91180, 91191. These items are generic timed-based attendance services applicable for all your patients, whether it is a patient at risk of COVID or an indigenous patient or anyone else.

In regards pathology, please have a look at our special edition NP bulletin at this link and let me know if that answers your question.

More later tonight.

Margaret and the Synapse team.

COVID MBS items explainer and FAQs No. 24, 8 April 2020…Read more








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