13 October 2021

No telehealth without patient enrolment

MBS Reform TheHill

From 2023 GPs may only be able to offer MBS-subsidised telehealth consults to patients who nominate them as their usual practitioner under the government’s voluntary patient registration scheme.

Today, Minister for Health and Aged Care Greg Hunt, invited the public to submit feedback on this proposal, as well as a number of other recommendations which feature in the draft Primary Health Care 10 Year Plan.

The public will have until 29 November to provide written feedback on the draft plan.  

The long awaited plan for the next decade of primary care acknowledges that telehealth, voluntary patient registration and new funding models would be key to future success.

Mr Hunt said the plan drew on two years of consultations with individuals and peak medical organisations.

“It represents a high-level response to the draft recommendations of the Primary Health Reform Steering Group, which has been working since October 2019 on future directions for primary health care reform,” he said in a statement.

In July, the steering group, which included representatives of the RACGP, AMA and ACRRM delivered its report to government which called out the “significant weaknesses” in the current funding structures supporting general practice.

A number of the steering group’s suggestions have carried into the draft report published this week, with authors agreeing that funding models could become blended in the future.  

But buried on page 12 of the report is a plan that would see MBS telehealth for general practice become contingent on the patient being registered with the practice from 1 July 2023.

Subject to government’s decisions following the public consultation, voluntary patient registration (VPR) could begin as early as July next year.

In practice, the change would extend the “existing relationship rule” GPs currently experience with telehealth arrangements to a number of other attendance items.

“The ‘usual doctor’ requirements for MBS health assessments, chronic disease management plans and medication reviews would also be linked to voluntary patient registration for registered patients from that date,” the authors wrote.

The face-to-face attendance requirements also appear to be more stringent under the proposed reform.

This is despite the Department of Health facing a severe backlash for a compliance activity earlier this year which targeted more than 400 GPs for telehealth consults they may have provided which did not meet the criteria for an “existing and continuous relationship”.

Currently, for patients to access MBS subsidised telehealth with a GP, they must have had at least one face-to-face attendance in the previous 12 months with the treating doctor or practice (with exemptions for Commonwealth covid hotspots and state restrictions).

But in what reads like more red tape for GPs, there appear to be two steps practices would have to take to provide Medicare funded telehealth under the VPR system:

  1. Adhering to the criteria compatible with patient registration before being able to provide certain services, and
  2. Ensuring a patient’s registration is maintained at the time of providing that service.

Under the draft Primary Health Care 10 Year Plan, to be eligible for registration, patients in metro and regional centres would have to attend at least three face-to-face visits in two years, while those in remote areas would only have to attend one.

“Children under 18 would not need to meet the qualifying criteria if their parent was already registered, and vice versa, to assist families to register,” the authors wrote.

“People would only need to visit the practice face to face once every two years to maintain registration with that practice. People could change the practice with which they are registered at any time after the qualifying number of visits or withdraw their registration at any time.”

On the subject of funding reform, the report said primary care services remained highly dependent on a fee-for-service model.

One suggestion floated was for the sector to move to more blended payments – a mix of fee-for-service and block payments which would be made on the basis of quality outcomes on a patient-by-patient basis.

The draft report said this model would “balance the incentives in the system”, but provided no additional detail on how this might change existing business models for primary care.

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4 Comments on "No telehealth without patient enrolment"

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Margaret Faux
8 days 8 hours ago
Any patient registration requirement that ties patients to a particular practice where they have no realistic option other than to pay whatever fees are charged, may offend the civil conscription caveat in section 51(xxiiiA) of the constitution, by being a form of practical compulsion. The constitutional provision applies equally for the benefit of doctors and patients – I think everyone forgets that. Patients have a right to access medical services from the provider they chose, because they pay for the system and the Medicare benefit is their ‘property’. I suppose one option would be for the government to force GP… Read more »
Adrian Sheen
8 days 9 hours ago

Since the PIP payment is in part dependent on who is a patient’s “usual doctor”, the Government already has the data needed to link patient-with-doctor.
The Department of Telephonic Compliance is about to be launched.

Igor Jakubowicz
Igor Jakubowicz
8 days 9 hours ago

This will make it more difficult for patients to access specialised services such as addiction or pain management, or medicinal cannabis. I provide these, even by telehealth, while the patient, who may reside at some distance, can continue to see their usual GP for routine matters.

Jane Crowe
Jane Crowe
7 days 9 hours ago

I work in a metropolitan general practice , but like you, am also a GP with special interests seeing cancer patients in a cancer centre one day a week. Not sure how the cancer patients will be able to access a telehealth rebate under these rules.