COVID MBS items Explainer and FAQs, No. 25, 9 April 2020


Dear Doctors and Health Care Workers

Thank you all once again for your kind words of support and humour this week. Three weeks in and we hope you’re all staying strong.

More great questions today but also something worrying, alas, so let’s start with that.

We want to support your billing compliance during this period and have unfortunately become aware of potential serious breaches of both Section 19(2) of the Health Insurance Act and the terms of the National Health Reform Agreement.

We touched on it in bulletin 22 but feel it is important to restate very clearly that anyone who tells you that you can bulk bill public patients in private hospitals is wrong.

Section 19(2) exemptions are currently only available under the ‘better access to primary care’ scheme, which is exclusive to remote Australia. You can read about it here.

This conduct may expose you to investigation when the dust settles, and we are 12-18 months post COVID, because it will be very easy for Medicare to audit – why were all these 75% inpatient rebates bulk billed in private hospitals? Admitted patients in private hospitals are almost never bulk billed.

And don’t forget, the Federal Government has just signed an agreement to fund private hospitals to the tune of $1.3 Billion. The Government is unlikely to add to that burden by allowing VMOs to draw more from the public purse through bulk billing.

There are various strategies being considered and implemented across the country to address this issue including:

  1. Cross accreditation of public clinicians to private hospitals, so they can continue to treat these patients under their salaried arrangements
  2. Cross accreditation in the other direction, where private clinicians are paid a sessional rate to treat public patients in private hospitals

So, if you are contracted to a private hospital that is admitting public patients, please speak with the hospital about how it plans to pay you to treat these patients, and do not be tempted to bill to the Commonwealth.

Here’s answers to today’s questions

1.  I was just wondering if there had been any guidance on obtaining referrals for ongoing patients. We are an oncology practice and continue to see patients (currently as many over phone on COVID items as possible) and some may need a new referral for ongoing management from their GP, however it seems silly (and an unnecessary burden on the GP) to risk going to the GP just for this at this time. Is there any allowance to extend existing referrals? 

No. There have been no changes to referral law, so all usual requirements apply.

You may actually be doing the GP a huge favour encouraging the patient to return for a new referral. Many GPs are struggling out there.

2.  I am a General Surgeon in private practice. To bill 91832 and 91833 for telephone consult, the patient has to be:

A patient at risk of COVID-19 virus means a person who:
(a)   is required to self-isolate or self-quarantine in accordance with guidance issued by the Australian Health Protection Principal Committee in relation to COVID-19; or
(b)  is at least 70 years old; or
(c)  if the person identifies as being of Aboriginal or Torres Strait Islander descent—is at least 50 years old; or
(d)  is pregnant; or
(e)  is the parent of a child aged under 12 months; or    
(f)  is being treated for a chronic health condition; or
(g)  is immune compromised; or
(h)   meets the current national triage protocol criteria for suspected COVID-19 infection.”

or > 15km from my office. Correct? 

and I cannot bill 91832 for a telephone consult in a fit, healthy patient with no COVID risk that is <15km from my office.

No. Incorrect.

  1. The > 15 km requirement relates to usual telehealth not COVID telehealth and the patient has to be in a telehealth eligible area. Plus you would then bill item 104 or 105 + 99
  2. You can bill items 91832 and 91833 for all patients, but the Government wants you to bulk bill those who meet the ‘risk of COVID’ criteria
  3. Yes, you can bill item 91832 for a fit healthy patient with no COVID risk who is 5 minutes from your office. And you can charge your usual fees for this patient.

3.  Can you bill a WorkCover item having done a telehealth consult with video. Able to do the required examination quite adequately.

Have a look at bulletin 3 and bulletin 15 where we answered questions about billing workers comp.

More and more of the workers comp insurers are adding content to their websites with guidance on how to bill. Here’s a link to SIRA

4.  I am so confused! I thought all restrictions and criteria were lifted for telehealth and all patients were eligible for a telehealth regardless of their age, etc. m so confused! I thought all restrictions and criteria were lifted for telehealth and all patients were eligible for a telehealth regardless of their age, etc.

I know! All restrictions were lifted on 31st March and then a week later on the 6th April the vulnerability criteria were partially reinstated ☹ And worse, it’s going to be changed again soon.

5 a) If my vulnerable patient lives at home, more than 15km from my location, but in Pakenham, would that be considered as non-metro area?


b) Can I then charge 141/149, for appropriate geriatric consultations?

Yes, if your patients are in telehealth eligible areas including being residents of aged care facilities (including an aged care facility in Pakenham)

c) Would it change if I am at home too, still 15km away?


d) Where can I get an updated list of non-metro regions for Telehealth?

Here is the link

e) I was told if patient and doctor are 15km away, then it should not matter re non-metro regions, is that correct?

No. It is incorrect. Here is a useful link

6.  Are we obliged now to provide all ‘vulnerable’ patients telehealth consults? If they insist on coming in for a face to face consultation, are we liable if for some unfortunate reason they ended up getting COVID from a contact at the hospital or practice?

No, you are not obliged to provide all vulnerable patients with telehealth consults. In terms of liability, this is a more complex issue. Best advice is to discuss this with your MDO.

7.  Can you please just clarify for anaesthetists what we can claim, including telephone consultations versus telehealth (video) consultations?

Unfortunately, anaesthetic services are not included in the COVID telehealth MBS suite because the current COVID services are exclusively for outpatients. Most anaesthetic work is inpatients.

This is obviously very challenging for anaesthetists right now because most surgery has been cancelled.

8.  I am offering all my patients video/FaceTime consultations but am finding that 90% especially in the older age group (but even younger families) cannot do this. Either they don’t have the facilities nor the knowledge to make it work.

a) I understand that because our patients cannot videolink/FaceTime we are then not able to bill 132/133 even though we offer to provide this service. Is this correct?

Yes and no. You can’t bill 132/133 via telehealth ever, even in non-COVID times, unless the patient is in a usual telehealth eligible area.

If the patient can’t manage video, maybe just try a phone call and use item 92431/92432. These are the item 132/133 equivalents for phone as opposed to video

9.  What about surgeons, what item numbers can we use? Normally I use 104 – new referral. And 105 for follow up.

See bulletin 22

10.  I went to eclipse the Medicare batches but got an error: Non-MBS item in Medicare bulk billing request: 91823.  How do I claim please?

Now this is interesting.

We are not having this problem and are finding the COVID item numbers are processing smoothly.

I assume you are bulk billing, so check with your software vendor first to make sure they are keeping up to date with the rapid changes. You should not get this message if the software is up to date because item 91823 was added a few weeks ago. Also call Medicare e-service on 1800 700 199.

Let us know if calls to your software vendor and Medicare don’t resolve your issue.

11.  I’m an NP working in a multi-purpose public health service in regional Victoria. Currently I cover all urgent care presentations and acute admissions. I get weekend cover from GP’s who bulk bill the urgent care presentations. A number of the GP’s and specialist physicians in the rural environment are at risk. They are >60 with chronic conditions or >70. We are looking to protect and engage these clinicians through a telehealth service to provide ongoing cover and support. My questions are: 

Do clinicians need to meet certain criteria in order to provide telehealth and MBS billing?

So, the first thing is, great idea! Secondly, I am assuming your facility is subject to a section 19(2) exemption because you have said the GPs attend the facility on the weekends and bulk bill.

There are no specific criteria for the clinicians, other than having a valid registration

Are the billing frameworks different for emergency/urgent care presentations?  

So, there’s a whole range of COVID items for GPs including the emergency after hours item 599, which is 92210 and 92216. Plus, if any of your GPs are OMPs there are also non-VR item equivalents.

But, as you are a public health service, the threshold issue of whether your doctors can bill at all is important, requiring a consideration of relevant provisions of the National Health Reform Agreement. If you’re happy to send through more details, I’ll take a closer look. 

Thanks everyone

Have a safe and restful long weekend. Thank god the Easter Bunny has been deemed an essential service. I’m going for 250gms of chocolate per day!

Till next week.

Margaret and the Synapse team.

COVID MBS items explainer and FAQs No. 26, 14 April 2020…Read more


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