Cheat sheets, ‘little frauds’, co-billing and other (non-)stories

5 minute read


The latest media attack shows ignorance of how general practice functions.


On 14 December, Nine newspapers published their latest offering in a series of articles designed ostensibly to expose fraudulent doctors.

According to Ben Cubby’s story, anecdotal comments from private doctors’ groups on social media supported the theory of deliberate fraudulent activity by doctors, promulgated by Dr Margaret Faux (PhD), who has rejoined the fray after going quiet since the initial stories of 22 October.

The story’s allegations based on the leaked posts and quotes from Dr Faux include that:

  • Billing multiple item numbers is fraudulent
  • Billing Medicare “for financial gain” is illegal
  • A post about obviously illegal billing titled “little frauds” was encouraging this activity

What are the facts, from someone who actually is a specialist GP, does bill Medicare and saw some of these posts and comments in the wild?

Billing multiple item numbers

Billing multiple item numbers at the same consult is legal. I suspect this is the main if not the only way many universal-bulk-billing practices have managed to stay afloat this far.

Instead of charging proper fees for their services, many practices survive by billing multiple item numbers (all at heavy discounts if accepting the patient rebate as full fee) or charging for one item and bulk billing the rest if appropriate to avoid a heavy fee to the patient at point of care.

Most of our patients do not present for one issue to be dealt with at a time; instead, they usually book a standard 15-minute consult and come prepared with a list of complaints and concerns for us to address, to make it worth their while, some of which attract separate and extra item numbers (and often cause us to run late).

A patient may present for a consult about contraception, which may be 15 minutes or longer, and decide on the day to go ahead with a long-acting reversible contraceptive such as an Implanon or a Mirena IUD, both of which usually require a negative pregnancy test prior to insertion. So that would be consult item number + insertion number + pregnancy item number. All are legal. Charging for only one means seriously undercharging, and putting another nail in the coffin of general practice viability.

Accusations like this will simply drive more of us to stop bulk billing anyone and charge full fees, or turn patients away with too many problems to ED, or limit them to a “one issue per appointment” policy.

Cheat sheets on Medicare item numbers

The article says doctors use cheat sheets to bill item numbers as if this were literally a kind of cheating.

I remember, as a first-term GP trainee, being introduced to the MBS, a thick and heavy book with indecipherable, legalistic language that made little to no sense to me. My supervisor then, and every supervisor since, gave me a laminated sheet with the most common codes and item numbers used in general practice, so that I could use the consultation time to address the patient’s concerns rather than worrying about what item numbers to bill.

Many government and associated organisations have their own variations of cheat sheets to enable easy access to the most commonly used item numbers for ease of use.

Financial gain

“If you bill Medicare for the sole purpose of financial gain it is illegal,” Dr Faux is quoted as saying.

I find this confusing. As clinics and practices, all GP clinics are small businesses. We are not charities nor are we non-profits. Profit while serving the community is a necessary part of the goal to stay viable – so what is Dr Faux talking about? What other purpose is there to bill Medicare if not as payment for services rendered by a business entity?

Little frauds

I read the post about “little frauds” and it was not an endorsement, as I have since clarified with the doctor who posted it.

Many of these groups are there for support, especially for junior trainees who are still finding their feet or feeling somewhat lost. It is entirely appropriate in our teaching role to point out both what easy and common mistakes we may fall into, such as this post about “little frauds”, as well as more obvious ones so that we may be more mindful of what NOT to do. The poster never said it was OK to commit these frauds nor encouraged anyone to do so.

Making a business out of maximising Medicare billings

I am not a member of the group run by the business that teaches doctors to maximise their billings. You may or may not approve of the ethics, but there is nothing illegal about what they are promoting. While I have not taken part in this training, it is notable – and was noted by Cubby – that the founder and others have been audited and passed the audit: no fraud or deceitful practices were found to have been committed. So what is the issue exactly?

Legalities and journalistic integrity aside, I suspect what will come of this story is more of the same: the fear of more audits and nudge letters will mean doctors will either abandon bulk billing even faster or continue to underbill, placing more practices at risk of eventual closure and adding to the GP shortage; and more junior doctors will be deterred from choosing general practice.

If this is what the media wants, then they are well on their way to achieving their goals.

Dr Imaan Joshi is – at heart – a Sydney GP; she tweets @imaanjoshi.  

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