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Q: What are the new minimum requirements for a valid referral?

To be considered valid, a referral must now include:

• Either the address of the practice or the provider number of the referring practitioner
• A statement about referral validity, if relevant

Referrals are now valid for 18 months from the date of the first service provided, unless a different period is specified on the referral.

Q: Has the 5-visit cap changed under the new rules?

No. The total number of Medicare-funded allied health services remains capped at 5 per calendar year (10 for Aboriginal and Torres Strait Islander patients).

What has changed is that referrals are now valid for up to 18 months, meaning patients may space out their sessions or see different providers during that time.

You can verify remaining MBS-funded services using the HPOS online checker or ask the patient to check their Medicare Online account.

Q: Do referrals need to list how many sessions are being allocated?

No. Under the revised rules, GPs are not required to specify the number of services per provider or per profession.

However, GPs can still include the number of services if they wish, and it's recommended that you ask the patient or GP to clarify this where possible, particularly if coordinating care with other allied health providers.

Q: How will I know when to send my first and final reports?

Reporting requirements remain unchanged:

• You must send a report after the first service
• You must send a report after the final service under the referral
• If there is clinical relevance, you may report mid-referral

If it's unclear whether the patient has completed all sessions, send a "final" report based on clinical judgement. If the patient returns unexpectedly, another final report can be submitted without consequence.

Q: Can patients use the same referral at multiple practices?

Yes. Referrals no longer need to list a specific provider or clinic. Patients can choose their provider, and services can be spread across different clinics if they wish.

This increases flexibility, but also requires that podiatrists check MBS usage status via HPOS to avoid rejected claims.

Q: Is the 20-minute consultation requirement strict?

Yes. MBS items should only be billed where services are clinically relevant and the full item descriptor requirements have been met.

As listed in the item descriptor of MBS podiatry items 10962 and 81340, "the service is of at least 20 minutes duration". A Medicare benefit is eligible when the service is at least 20 minutes in duration with the patient in direct attendance. This may include time taken for consultation, treatment, planning and maintaining the patient record as long as the patient is in attendance.

Q: Can I charge for consumables when bulk billing?

No. When a provider bulk bills an MBS item, they are accepting the patient assignment of their Medicare benefit as full payment for the service. Additional charges cannot be raised in relation to a Medicare service being bulk billed, whether for consumables or some other reason.

Where a practitioner chooses not to bulk bill a service, a fee may be privately charged for the service which includes an amount to compensate for the use of consumables, provided this additional fee component is only in relation to the service being claimed.

Q: Can I bill Medicare for a patient who didn't attend (DNA)?

No. Medicare cannot be billed if the service was not provided.

A non-attendance fee can however be charged, noting that this cannot be claimed back on Medicare. The practitioner must see the patient in order to claim correctly. Any non-attendance fees charged cannot be attributed to Medicare.

Q: Can I claim the same item number twice on the same day?

No. Podiatry items 10962 and 81340 cannot be claimed twice for services split over the same day or for services provided to each foot.

In exceptional circumstances, where the service is required to be split over the same day or different days, these items should only be claimed once the entire service is complete. Such circumstances do not allow for these items to be claimed twice.

Q: Is the calendar year from January to December or from the referral date?

Medicare-rebateable CDM allied health services are assessed within the calendar year (1 January – 31 December).

Any unused services at 31 December can continue to be used in the following year but will be subject to the maximum limit of five. When patients have used all their referred services, they need to obtain a new referral from their GP.

Q: Can a GP refer all 5 visits to a single allied health practitioner?

Yes. Medicare benefits are available for up to five allied health visits per eligible patient, per calendar year. These can be made up of one type of service, or a combination of different types of services (e.g. one dietetic and four podiatry). All 5 services may be referred to one provider as outlined in the management plan.

Q: Are residents of aged care facilities eligible for CDM services?

Residents of a residential aged care facility (RACF) are ineligible for the preparation of a GP management plan under item 721 and team care arrangements for the purposes of accessing allied health services.

However, residents may be able to access allied health services as part of a multidisciplinary care plan under item 731. If a GP has contributed to a multidisciplinary care plan under item 731, the resident is eligible for Medicare rebates for up to five individual allied health visits per calendar year.

Note: Medicare benefits are not payable for services that should be provided by a RACF under the Aged Care Act 1997. MBS services should be additional to, and not duplicate or replace, services that are the responsibility of the RACF.

Q: Who is responsible for checking patient eligibility?

A patient's eligibility is based on their Medicare claiming history and the number of services specified in a referral. It is primarily the patient's responsibility to keep a record; however, as a provider, it is expected that a patient is aware of their eligibility for Medicare benefits prior to receiving the service.

The Health Professional Online Services (HPOS) system assists providers in tracking services, especially where they have been provided by different providers.

Learn how to use HPOS MBS Items Checker →

Q: Must referrals be signed and dated by the GP?

Yes. An allied health provider has a responsibility to only provide services on the basis of a valid referral. A referral must be signed and dated.

Electronic referrals: Electronic referrals can meet the requirements if the referral complies with the Electronic Transactions Act 1999 (the ETA). It is sufficient for the referring practitioner to simply indicate on the face of the electronic referral that it has been 'signed electronically' by the referrer, provided that you as the treating provider consent to this approach. Electronic referrals must also be dated.

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