COVID MBS items Special Confusion Issue, No. 27, 15 April 2020


Dear Doctors and Health Care Workers

We are going to dedicate tonight’s bulletin to confusion. It is obvious from the questions that came in today there is a lot of confusion out there, which is not surprising with the laws changing every five minutes. Here’s some examples:

  1. I think you are wrong. COVID item numbers must be bulk billed. 
  1. I am a private paediatrician. The MBS online website does not stipulate that I must bulk bill everyone < 16, so why do some people think I must and do I? Why can’t I use the new telehealth numbers for metro patients and a gap with patient informed consent? 
  1. I am a physician haematologist in private practice. I usually charge a full fee and my billing company processes the Medicare rebate for the patient which is deposited directly into their account. I am now doing many of my follow up consults as either a telephone call or telehealth. All my patients satisfy the “vulnerability” criteria for COVID, but they live in metropolitan areas. Can I legally still charge my usual full fee, and expect that they will have the COVID code rebate paid into their bank account as usual? My confusion lies in the “mandatory bulk billing” which the government wants us to use for COVID codes. Bulk billing all patients in my practice is not sustainable for my practice.

Firstly, COVID item numbers do not have to be exclusively bulk billed.

Secondly, the Government did, then didn’t, then did (but only partially) want you to bulk bill COVID items.

Thirdly, it is worth pointing out that we are dealing with law here, not rumour and gossip. Medicare is a legal system. It is funded by taxpayers and laws apply, and whilst it is true that new laws are being made at such a frenetic pace right now, it is hard to keep up, that doesn’t change the fact that the law in place at the date of service is what applies and nothing else.

So, let’s be really clear that the law in place today (which commenced on 6th April 2020) provides that you DO NOT HAVE TO BULK BILL ALL COVID ITEM NUMBERS, THE GOVERNMENT IS ONLY TRYING TO FORCE YOU TO BULK BILL FOR VULNERABLE PATIENTS, CONCESSION CARD HOLDERS AND UNDER 16s.

Here is a cut and paste from MBS online which you can access here reinforcing this very clear and legislated message (my underlining) and the actual underpinning law is here at this link:

“From 6 April 2020:
Bulk-billing: Health providers can apply their usual billing practices to telehealth consultations. It is a legislative requirement that the service must be bulk-billed where the service is provided to a concessional or vulnerable patient or a child under 16 at the time the service is provided. For all other patients, the service may be bulk-billed.

So, in answer to the 3 questions above:

  1. Our information is and was correct
  2. The Government does want you to bulk bill everyone under 16
  3. The Government does want you to bulk bill all your vulnerable patients. However, please review bulletin 22 in relation to billing without a Medicare item number.

Before we go, here’s a more straight forward question:

2.  Regarding item number 91824,91825,91834,91835. Is the physician required to provide the service from the premise of the practice? or can this be done remotely?

You do not need to be in your practice and can provide this service from home, remotely or from anywhere. Try to use your provider number linked to the place where you would usually have consulted these patients or get a new one from PRODA.

Thanks everyone

Till tomorrow.

Margaret and the Synapse team.

COVID MBS items explainer and FAQs No. 28, 16 April 2020…Read more


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