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Frequently asked questions are grouped according to the following categories:
Psychologists applying for membership of the APS College of Clinical Psychologists must show evidence of receiving specialist clinical supervision as part of the application process. It is the preference of the APS College of Clinical Psychologists that eligible supervisors should have full Membership of the APS College of Clinical Psychologists of at least two years duration prior to providing supervision to the prospective applicant, and should be experienced in the supervisee's area of practice. Further, the supervisor themselves must be up to date with their own clinical professional development points.
In special circumstances, the APS Medicare Assessment Team may approve a person as a supervisor who is not a full College Member, or who has less than two years of College Membership. For example, a person who has been assessed by the APS Medicare Assessment Team as ‘eligible to join the APS College of Clinical Psychologists' (and has chosen not to join) and has been considered eligible for at least two years could be approved as a suitable supervisor for the purposes of joining the Clinical College.
It is recommended that a psychologist who is planning to supervise prospective applicants for membership of the APS College of Clinical Psychologists check with the APS Medicare Assessment Team whether they are an eligible supervisor for this purpose prior to providing supervision.
Applications for assessment of eligibility for membership of the APS College of Clinical Psychologists via the non-standard route include a requirement for at least 1,000 supervised hours of clinical experience in a mental health setting. It is recommended that the applicant provide details of two years of appropriate placements or employment experiences under the supervision of a clinical psychologist. Under normal circumstances, a clinical psychologist will provide supervision directly. In some settings this may not be possible (e.g. remote locations, or mental health settings without a clinical psychologist on staff). In such cases it may be appropriate for regular supervision to be provided by an appropriately experienced mental health professional (e.g. psychiatrist, or other senior psychologist or health worker with appropriate mental health qualifications and experience) with a clinical psychologist overseeing the supervision and providing secondary supervision.
Supervision under the auspices of a clinical psychologist will be assessed on a case-by-case basis, however, it should be noted that only in rare cases would the acquisition of clinical expertise under the supervision of a psychologist without special clinical psychology training be assessed as sufficient for ‘demonstrating equivalence' to the standard training in accredited and approved Masters/Doctorate clinical psychology programs.
For applicants who are dissatisfied with the outcome of the assessment for eligibility for membership of the APS College of Clinical Psychologists, there is an appeal process.
Information about how to appeal is provided in the Guidelines for Applicants contained within the application pack itself (Terms and Conditions point number 9). An appeal must be lodged with the Medicare Assessment Review Panel within 90 days from the date of the outcome letter from the APS Medicare Assessment Team. An appeal will incur a cost of $1,000 which is refundable if the appeal is successful.
It is critical that the Medicare Assessment Review Panel operates independently of the APS Medicare Assessment Team. Therefore, all correspondence in regards to an appeal must be directed to the Panel. All correspondence regarding an appeal should be directed to Medicare Assessment Review Panel, c/o Alex Bignell at the APS National Office.
Completion of a professional development (PD) seminar/workshop will provide evidence of a psychologist’s PD in a particular area of practice. As PD activities are not part of an integrated training program and do not include a formal assessment component, in most cases attendance at a particular PD workshop on its own will not be sufficient to demonstrate equivalence to certain requirements for eligibility for Clinical College membership.
Assessment of eligibility for membership of the Clinical College is conducted on a case-by-case basis. PD activities are considered in the context of an applicant’s sequence of qualifications, period of time since gaining full registration, clinical experience in particular settings, supervision history, and other factors such as research, publication, and/or teaching experience in clinical psychology.
Applications for membership of the APS College of Clinical Psychologists must show evidence of at least 40 hours of clinical psychology specialist professional development (PD). This requirement refers to workshops, professional courses, seminars, conferences, and/or reading/internet learning that an applicant has undertaken in the clinical psychology area. For PD to be considered clinical, the content of the workshop/seminar must be specialised clinical psychology knowledge (rather than general psychology). Thus clinical PD points are those that have been endorsed by the APS College of Clinical Psychologists as continuing education in that specialist area (e.g., they have the letters CCLIN approved in the PD advertisement, see the APS Events Calendar), or be able to meet the criteria for endorsement (see PD Information Guide, page 15).
For example, a workshop on autism, psychopathology, psychopharmacology, clinical assessment, or on an evidenced-based clinical therapy could be counted as specialist clinical PD. A workshop on running a private practice, how to be a supervisor or conflict resolution would be considered generalist PD (i.e. applicable to all psychologists). PD activities are considered in the context of an applicant's sequence of qualifications, period of time since gaining full registration, clinical experience in particular settings, supervision history, and other factors such as research, publication, and/or teaching experience in clinical psychology.
A Medicare rebate for services provided by a psychologist will not be paid under the following circumstances:
It is important to note that before a rebate can be paid for psychology services, Medicare Australia must have already received a claim for direct payment for the relevant GP Mental Health Care Plan item or other relevant medical practitioner referral item. If these GP Mental Health Care Plan or referral items have not been received by Medicare Australia first, a rebate for psychological services will not be paid.
Psychologists providing Medicare rebateable services may set their own fees but the Medicare rebate for each item is a set amount. However, if a psychologist chooses to direct bill Medicare for a service (i.e. bulk bill), the Medicare rebate for that service must be accepted as the full fee for that service. Psychologists are encouraged to bulk bill clients who are Health Care Card holders.
The Australian Government sets the Medicare schedule fees following consultation with relevant professional associations. The Medicare rebates are set at 85 per cent of the schedule fee. Medicare rebates are indexed in November of each year.
The client is responsible for paying any charges in excess of the Medicare benefit for items under this initiative. However, these out-of-pocket costs will count towards both the original and the extended Medicare Safety Nets for that client.
The family-based Safety Net protects high users of health services from big out-of-pocket costs. Once the client or their family has reached the relevant threshold in the calendar year, Medicare benefits will increase to 100% of the schedule fee under the original Safety Net, and 80% of total out-of-pocket expenses for out-of-hospital services under the extended Medicare Safety Net.
It is important to note that if the psychologist bulk bills the client, no additional fee can be charged for the service. If a fee is being charged for the service, the account must be addressed to the client who received the service, as per the usual practice. The client and the private organisation would then need to work out their own financial arrangements for how the bill is to be paid.
No, only psychologists who are fully registered with the Psychologists Registration Board in the State or Territory in which they are practising are eligible to provide psychological services under Medicare. Students who are under the supervision of fully registered psychologists are also not eligible to provide psychological services under Medicare (unless the student is already a fully registered psychologist).
Yes. In addition to psychologists, social workers and occupational therapists with mental health expertise are able to provide the Focused Psychological Strategies (FPS) Medicare items. Social workers and occupational therapists must meet certain mental health competency criteria set by their respective professional associations in order to provide the items. The schedule fees and rebates for FPS items provided by social workers and occupational therapists are set at a lower level than those for FPS services provided by psychologists.
Allied mental health services provided under the Better Access initiative are expected to be for the purpose of providing treatment to eligible clients with an assessed mental disorder. Some assessment activity may, however, form part of the initial consultation with the client, for example, to enable the practitioner to confirm and refine a differential diagnosis of the client or to identify a baseline for establishing the client's progress in response to the treatment provided.
It is anticipated that any assessment provided will be appropriate to the client's presentation and the likely condition to be treated, and will be necessary in informing and directing provision of treatment to the client. Any assessment should occur in preparation for treatment of the client and generally should not extend beyond the initial consultation with the client.
These guidelines, provided by the Department of Health and Ageing, apply to both the ‘Psychological Therapy' items (clinical psychologists) and ‘Focussed Psychological Strategies' items (psychologists). Initially, assessment services were restricted to the items provided by clinical psychologists.
Psychological services under Medicare are specified as ‘professional attendance’ and as such require face-to-face attendance. Other methods of service delivery, such as providing psychological services over the telephone, internet, or via video link, are not allowable under the MBS psychology items. The implications of this for providing services to clients in rural and remote locations have been brought to the attention of the Department of Health and Ageing and will be considered in the post-implementation review of the Better Access initiative.
A valid Medicare service requires the ‘identified patient’ to be present, so a session cannot be conducted with the child’s parents alone under the Better Access Medicare initiative. The discrepancy between best practice psychological assessment of a child and allowable services under Medicare has been raised with the Department of Health and Ageing and will be considered in the post-implementation review of the initiative.
The Medicare items related to out of office consultations can be used to provide services at a client's home or in the community where it is inappropriate or not possible for treatment to be conducted in a consultation room. Use of the out of office item need not be restricted to cases where the location of treatment is prescribed by the therapy (e.g., treating a client with agoraphobia at home), but the diagnostic indications must be appropriate and the treatment provided must be acceptable. An example of this would be working with a terminally ill client at home.
Residents of aged care facilities are NOT eligible to receive psychological treatment under a GP Mental Health Care Plan unless they meet one of the following conditions:
If the aged care resident meets one of the above criteria, an ‘out of office' consultation can be charged if the session occurs outside the usual consulting rooms.
Residents of aged care facilities can be seen under the Enhanced Primary Care Chronic Disease Management items, where GPs are able to contribute to care plans for residents of aged care facilities using Medicare item 731. In this case, the resident's GP can contribute to the care plan prepared by the facility and the resident is eligible for referral to allied health services, including services by psychologists.
A child under the age of two years may receive services under the Better Access initiative if they have been assessed as having a mental health disorder and have been referred by a psychiatrist, pediatrician or GP under a Mental Health Care Plan. The MHCP must be written for the child (not the parents) and the child must be present during the sessions for the rebate to be paid.
In order for a GP to refer a client for psychological services under the Better Access to Mental Health Care initiative, the GP must first complete a detailed assessment and diagnosis of the client. The GP must then prepare the GP Mental Health Care Plan, which includes documenting results of the assessment, client's needs, goals and actions, referrals and required treatment/services, and a review date. There is no particular form that is used for preparing the Mental Health Care Plan. Clients are encouraged to book a longer session with their GP if they are requesting a referral for psychological services, in order to enable the GP to complete the assessment and GP Mental Health Care Plan.
Further information on the GP Mental Health Care Plan is available from the Australian Government Department of Health and Ageing.
Clients continue to be eligible for referred services while they continue to be managed by their GP under the relevant GP Mental Health Care Plan (through regular reviews by their GP). A new GP Mental Health Care Plan should not be prepared unless clinically required (there is a restriction of one GP Mental Health Care Plan per client in a 12-month period).
Generally a new referral for further allied mental health services will be planned by the GP in a face-to-face consultation with the client. This could be as part of a review of the client’s Care Plan or as part of a normal consultation. In some instances the GP may consider that a separate consultation is not necessary (for example, having recently seen the client) and may consider that further allied mental health services are required based on their knowledge of the client and feedback from the treating provider. Decisions regarding referral for further services should be documented in the client's record.
Where a client has had a GP Mental Health Care Plan developed by a GP who is no longer managing the client's care, the new GP should attempt to access the client's existing plan from the previous GP and update the plan using the GP Mental Health Care Plan Review item. If this is not possible and the GP considers that exceptional circumstances apply, the GP could develop a new GP Mental Health Care Plan within the usual minimum period of 12 months. However, there should be clear reasons why a new plan needed to be developed.
Clients who are being managed by their GP under a GP Mental Health Care Plan who need to access further referred services during a new calendar year do not need to have a new Care Plan prepared (unless required by the client’s clinical condition, needs or circumstances).
A new referral for allied mental health services may be provided by the GP in the new calendar year where a client has used all previously referred services and the GP considers that the client requires additional allied mental health services (up to the calendar year entitlement of 12 sessions). As noted above, it is not necessary to prepare a new Care Plan just to make a new referral for services.
The Mental Health Care Plan (MHCP) and referral for psychological services must be developed by the client's referring GP and only by the GP. Under no circumstances can a psychologist write the MHCP.
Psychologists who are providing services under the Medicare Benefits Scheme (MBS) may be subject to ‘random compliance audits’ conducted by Medicare Australia. These audits are conducted to check that the services that have been claimed under Medicare have actually been provided. The audit for psychological services involves three checks: (1) confirming with the referring doctor that the client was indeed referred; (2) checking with the psychologist that the service was provided; and (3) verifying with the client that they actually received the service. The random compliance audit does not involve disclosure of any personal client information regarding the nature of the referral or the treatment that was provided. Random compliance audits are conducted across all service provider groups in the entire MBS program as part of Australian Government requirements. Approximately 2,000 random compliance audits are conducted every year.
Medicare Australia also conducts more detailed ‘research audits’ to determine compliance with the requirements of various MBS programs. Members were advised of the research audit being conducted into the Allied Health and Dental Care initiative (formerly known as MedicarePlus) earlier this year. The Better Access initiative is not currently subject to a research audit and this will not occur without the APS being consulted and notified. However, for Medicare Australia auditing purposes, a requirement of providing services under Medicare is that for each client seen under the MBS, psychologists are required to retain documentation of the medical practitioner’s referral for 24 months from the date the first service under that referral was provided.
Clients can receive up to 12 individual psychological services in a calendar year. The maximum of 12 allowable services includes any other psychological services provided either by other psychologists (Focused Psychological Strategies (FPS) items or clinical psychology items), or by other eligible social workers or occupational therapists (FPS items), or by GPs (FPS items). Services received under Better Outcomes - Access to Psychological Services (ATAPS) are also included in the 12-service limit for psychological items. However, services received under the Allied Health and Dental Care initiative (formerly 'MedicarePlus') are not counted in the 12 allowable services, so clients who have received services under that initiative are eligible for an additional 12 services under the new Medicare items.
In addition to these 12 individual psychology services, clients can also receive up to 12 group session psychology services in a calendar year. The maximum of 12 group services includes clinical psychology items, and FPS items provided by psychologists or eligible social workers or occupational therapists.
To ensure rebates are paid to clients, or that you will receive bulk billing payments, remember to check with your clients and/or Medicare Australia as to the number and types of psychological Medicare services they have received in the calendar year so far.
The referring medical practitioner may consider that in 'exceptional circumstances' the client may require an additional six psychological services above those already provided (to a maximum total of 18 services per client per calendar year). In these cases a new referral to the psychologist should be provided, and exceptional circumstances noted in that referral. The psychologist may need to include a reference on the client's account to state that exceptional circumstances were noted in the medical practitioner's referral.
Referrals for allied mental health services remain valid for the stated number of services on the medical practitioner’s referral. Where these referred services are not used during the calendar year in which the client is referred, the unused services may be used in the next calendar year, where they will count towards the maximum number of services able to be received during that year.
For example, if a GP prepared a GP Mental Health Care Plan for a client in November 2007 and referred the client for six allied mental health services but only two of these services were provided by 31 December 2007, the remaining four referred services would still be valid into 2008. The remaining four services could be provided in 2008 using the original referral but would count towards the client’s 2008 calendar year limit for allied mental health services.
Exceptional circumstances are defined as a significant change in a client's clinical condition or care circumstances that make it appropriate and necessary to increase the maximum number of services. Generally, a failure to note an improvement in a client's clinical state itself does not constitute an exceptional circumstance.
According to the Government, some examples of a significant change in a client's clinical condition that could be defined as exceptional circumstances include:
An exceptional circumstance can also include clients who have more severe mental illness, where the session limit leads to sub-optimal treatment services. In approving further treatment sessions for exceptional circumstances, the referring medical practitioner should have an expectation that the person would be assisted by a further series of sessions.
The psychologist must provide a written report to the referring medical practitioner at the completion of the first set of six sessions and before the review of the need for a further set of six services is conducted by the medical practitioner. A written report must also be provided to the referring medical practitioner at the completion of the second set of six services. Clients should be made aware of this reporting requirement to the referring practitioner before consenting to treatment to ensure that they know the limits of confidentiality. The psychologist's reports to the referring medical practitioner will become part of the client's medical record at the medical practice.
Clients cannot use their private health insurance ancillary cover to pay the gap between the Medicare rebate and the charge for psychological services.
Clients need to decide if they will use Medicare or their private health insurance ancillary cover to pay for psychological services they receive. Clients with this insurance can either access rebates from Medicare by following the claiming process or claim where available on their insurer's ancillary benefits. It is the client's choice, not that of the health insurance company or the psychologist.
Where the client chooses to claim against their health insurance (gets a better rebate, has exhausted the 12 sessions, or does not have a specified mental health disorder), the psychologist can assist the client and the health insurance company by not using the Medicare item numbers and marking on the account 'Not claiming under Medicare'. Such a process will ensure that any confusion will be removed for the private health insurance company and the client's claim will be processed promptly. No such confusion will arise where electronic claiming (HICAPS, IBA) is being utilised, as the very act of claiming against one of the collaborating health insurance companies electronically should make the client's intentions clear.
Clients need to decide if they will use Medicare or their private health insurance ancillary cover to pay for the psychological services they receive. Clients with health insurance can either access rebates from Medicare by following the claiming process or claim where available on their insurer's ancillary benefits. It is the client's choice, not that of the health insurance company or the psychologist.
Where the client chooses to claim against his/her health insurance (for instance, may receive a better rebate, has used the allowable 12 sessions, or is not eligible for services under the Better Access initiative), the psychologist can assist the client and the health insurance company by not using the Medicare item numbers and marking on the account 'Not claiming under Medicare'. Such a process will ensure that any confusion will be removed for the private health insurance company and the client's claim will be processed promptly. No such confusion will arise where electronic claiming (HICAPS, IBA) is being utilised, as the very act of claiming against one of the collaborating health insurance companies electronically should make the client's intentions clear.
Please be aware that the Private Health Insurance Ombudsman (PHIO: www.phio.org.au) provides an independent service to help consumers with health insurance problems and enquiries. The Ombudsman can deal with complaints from health funds, private hospitals or medical practitioners. Complaints must be about a health insurance arrangement.
The psychology Medicare items do not apply for services that are provided by any other Commonwealth- or State-funded programs. However, where an exemption under subsection 19(2) of the Health Insurance Act 1973 has been granted to an Aboriginal Community Controlled Health Services or State/Territory Government health clinic, these items can be claimed for services provided by eligible allied health professionals salaried by, or contracted to, the service as long as all requirements of the items are met, including registration with Medicare Australia. These services must be bulk billed (that is, the Medicare rebate is accepted as full payment for services).
No. Any treatment services provided through an organisation funded by the State or Commonwealth can NOT be paid for via Medicare. This is stated categorically under Section 19(2) of the Health Insurance Act 1973. The intention of this section of the Act is to preclude multiple payments being made through separate governing bodies for a single clinical service. State or Commonwealth organisations that provide services that are funded by Medicare should seek their own legal advice as to whether their current or proposed arrangements infringe the Act.
There is no particular form by which the doctor communicates with the treating psychologist. However, the referring practitioner should provide a referral letter, and when the patient is referred by a GP who is managing the patient under a GP Mental Health Care Plan, a copy of the plan may also be provided (with the patient's permission).
A psychiatrist or paediatrician in private practice can directly refer their private patients for services from a psychologist as long as they use their private Medicare Provider Number and charge the appropriate Medicare attendance item for the referring consultation (specialist psychiatrist Medicare items 104 to 109 or consultant physician psychiatrist items 293 to 370; or specialist paediatrician items 104 to 109 or consultant physician paediatrician items 110 to 131 ). Medicare Australia must have processed a claim for the referring consultation before a rebate for the psychology services can be given. Unlike under the arrangements for a referral from a GP (where a GP Mental Health Care Plan must be completed), there is no formal assessment item that psychiatrists or paediatricians must have undertaken other than consulting the client. Psychiatrists and paediatricians operating in the public sector cannot refer public clients under the Better Access initiative.
The APS website provides a list of psychologists who are eligible to provide services under the various Medicare initiatives - Better Access to Mental Health Care, Pregnancy support counselling, Children with autism or any other pervasive developmental disorder, and Chronic disease management under an Enhanced Primary Care plan. The list is searchable by both location and the practitioner's name. The list can be found at www.psychology.org.au/MedicareProvider/.
Eligible practitioners who wish to be included on the Medicare Provider List will need to register online. The process is as follows:
Practitioner details are uploaded to the Medicare Provider List once a week.
The Australian Government will continue to honour its commitment to supporting the key components of the BOMHC program, including Access to Allied Psychological Services (ATAPS) for delivery of Focused Psychological Strategies. In particular, the ATAPS component will continue through Divisions of General Practice to offer GPs an alternative referral pathway to funded psychological services.
The amount of detail in the report to the referring medical practitioner is not specifically mandated. The Medical Benefits Scheme Explanatory Notes do state that the report should include information about assessments carried out, treatment provided and recommendations on the future management of the client's disorder. In meeting these requirements, the psychologist should use clinical judgement on what information is appropriate to include in the report.
Psychologists must provide a written report to the referring medical practitioner following the first six psychological services or on completion of that course of treatment (which will be a maximum of six services, but could cover less than six services depending on the nature of the referral). The written report should include information on:
The client should be reviewed by the referring medical practitioner after the first six psychological services and following receipt of the psychologist’s report. The review will determine whether the second set of six psychological services is required. In some instances, a referring medical practitioner may authorise the second set of six psychological services without reviewing the client in person. Where this occurs, the psychologist should document any telephone conversation with the referring doctor and seek written authorisation from him/her to ensure that the validity of the second set of six psychological services can be substantiated at a later date, if required.