Billing and remuneration

  • Are there any circumstances under which the Medicare rebate will not be paid for services provided by a psychologist?

    A Medicare rebate for services provided by a psychologist will not be paid under the following circumstances:

    • An invalid referral, where the client was not referred by a GP managing the client under a GP Mental Health Treatment Plan, and/or a psychiatrist assessment and management plan, or referred by a psychiatrist or paediatrician from an eligible psychiatric or paediatric service. This includes a client referred by a psychiatrist or paediatrician in the public sector where the referring physician did not use a private Medicare Provider Number for the referring consultation.
    • Treatment by a non-eligible psychologist, where the treating psychologist did not have a Medicare Provider Number, or was not accredited as eligible to provide clinical psychology services where this is applicable.
    • The client has exceeded the 10 individual and 10 group psychological services allowable per calendar year.
  • How much can a psychologist charge for providing services under Medicare?

    Psychologists providing Medicare services may set their own fees but the Medicare rebate for each item is a set amount. If a psychologist chooses to bill Medicare directly for a service (i.e. bulk bill) the Medicare rebate for that service must be accepted as the full fee for the service. No additional fee can be charged by the psychologist. 

    Psychologists are encouraged to bulk bill clients who are Health Care Card holders and low income earners who would not otherwise be able to access psychological services.

  • How are Medicare schedule fees and rebates set?

    For the psychology items, the Medicare rebates are set at 85 per cent of the schedule fee. Using an indexing process, the Medicare Benefits Schedule fees are raised by the Australian Government each November.

    However, in 2013 the then Labor Government put a ‘temporary’ freeze on the indexing of the Medicare fee schedule. Subsequent governments have extended this freeze which was extended in the 2016 Federal budget to 2020.

  • Does the Medicare Safety Net apply to client out-of-pocket expenses under this initiative?

    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 the Medicare Safety Net for that client.

  • If a private organisation wishes to pay the gap between the Medicare rebate and the psychologist's fee, how can this be done?

    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 psychologist must bill the client who received the service, as per usual fee payment arrangements.

    The client and the private organisation would then need to work out their own financial arrangements for how the bill is to be paid.

  • For clients who were referred to me but fail to attend, can I bill these clients under Medicare?

    It is important that your practice has a cancellation policy which informs your clients prior to receiving services of your expectations regarding cancellations and non-attendance, including any fee charged if they do not provide sufficient notice of non-attendance. However, this fee cannot be billed under Medicare.

    When providing services under the Medicare Benefits Scheme, a Medicare rebate can only be claimed for services provided directly to the client and therefore cannot be used to cover a cancellation or a non-attendance fee. 

  • Can I bill for a cognitive assessment under Better Access?

    Medicare rebates under the Better Access initiative are provided for an identified mental health problem. The assessment component under this initiative, as specified in the Medicare Benefits Schedule, is for assessment and therapy for a mental disorder.

    Unfortunately, even though there may be benefits to determining a client's cognitive abilities as a way to identify a treatment approach suitable for the client, an intellectual assessment does not fall into the category of assessment services that are allowable and a Medicare rebate under the Better Access initiative cannot be claimed for this service.

Eligibility of psychologists and allied health professionals

  • Can a provisionally registered psychologist provide psychological services under Medicare?

    No, only psychologists who hold full (‘general’) registration with the Psychology Board of Australiaare eligible to apply for a Medicare Provider Number and to provide psychological services under Medicare.

    Students and provisionally registered psychologists working under the supervision of a fully registered psychologist are not eligible to provide psychological services under Medicare.

    The only exception to this is where the student already holds general registration as a psychologist.

  • Can other allied health professionals provide services under Better Access?

    Yes. In addition to psychologists, general practitioners and appropriately qualified social workers and occupational therapists are able to provide the Focussed Psychological Strategies (FPS) under Medicare.

    General practitioners, social workers and occupational therapists must meet mental health competency criteria set by their respective professional associations in order to provide the items. 

Eligible services

  • Can assessment of a client be conducted as part of services provided under the Better Access initiative?

    Allied mental health services provided under the Better Access initiative are 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. Better Access Medicare item numbers cannot be used for formal psychological assessment such as cognitive, educational or neuropsychological assessment.

    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.

  • If I conduct a parent interview as part of my psychological assessment of a child, would this be considered a valid service under Medicare?

    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 brought to the attention of the Government and the APS continues to advocate for changes in this area.

  • When can the ‘out of office consultation’ Medicare items be used?

    The Medicare items related to professional attendances at places other than consulting rooms can be used to provide services at a client's home or in the community where treatment in an environment other than the consulting room is necessary to achieve therapeutic outcomes.

    Valid examples include working with a client who is unable to leave their home due to illness or disability, or undertaking exposure work with a client in a specific setting. The “out-of-office” item cannot be used to provide a regular service in a location that is not a consulting room (e.g., school, organisation) in circumstances where there is no indication that treatment away from the professional consulting room is necessary to achieve a therapeutic outcome.

  • Can psychological services be provided to a resident of an aged care facility under the Better Access initiative?

    Residents of aged care facilities are NOT eligible to receive psychological treatment under Medicare unless they meet one of the following conditions:

    • A privately funded resident in a private aged care facility (i.e., they do not receive a subsidy for their care from the Australian Government under the Aged Care Act) OR
    • A privately funded resident in a public aged care facility (i.e., they do not receive a subsidy for their care from the Australian Government under the Aged Care Act) OR
    • A private inpatient being discharged from hospital (where the GP who completes the GP Mental Health Treatment Plan is providing inpatient care).

    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.

  • Can psychological services be provided to an infant under the Better Access initiative?

    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, paediatrician or GP under a Mental Health Treatment Plan.

    The Treatment Plan must be written for the child (not the parents) and the child must be present during the sessions for the rebate to be paid.

GP Mental Health Treatment Plans

  • What is involved in a GP Mental Health Treatment Plan?

    Under the Better Access to Mental Health Care initiative, a referral can occur through a GP, a psychiatrist or a paediatrician. If referral is by a GP, the GP must complete a detailed assessment and diagnosis of the client as part of preparing a Mental Health Treatment Plan (MHTP).

    The plan will document results of the assessment, client's needs, goals and actions, and services to be provided. There is no particular form that is used for preparing the MHTP, although some templates are available to assist the GP. Clients will need to book a longer session with their GP if they are requesting a referral for psychological services, to enable the GP to complete the assessment and MHTP.

    A MHTP is not a referral and alone is not sufficient for the psychologist to provide a service. A referral letter requesting services must be provided to the psychologist by the referring me

  • How often does a new GP Mental Health Treatment Plan have to be prepared?

    A new GP Mental Health Treatment Plan (MHTP) should not be prepared unless clinically required. A MHTP triggers the client’s eligibility for funding under Better Access. A client can continue on the same MHTP indefinitely with the GP updating the original plan as necessary. In some circumstances it may be appropriate for the GP to prepare a new plan, for example if there is a significant change in the client’s circumstances or if the client moves to a new GP.

    It is the referral letter from the GP that allows the psychologist to provide services under Better Access and which the psychologist must have for their records. It is not a requirement that the GP provide the psychologist with a copy of the MHTP. For the GP to provide a copy of the MHTP they must have client consent and this may not always be forthcoming.

Medicare Australia audit

  • Will I be audited by Medicare Australia and, if so, what will it involve?

    Psychologists who are providing services under the Medicare Benefits Scheme (MBS) may be subject to a compliance audit. These audits are often conducted on the basis of an analysis of Medicare data and the identification of practitioners whose billing patterns differ from those of their peers. That is, they are considered outliers (e.g., higher billing patterns than typical of psychologists). Medicare Australia may also undertake random audits of health professionals.

    These audits are conducted to check that billing under Medicare is legitimate. The audit for psychological services may be conducted either by phone and letter or as part of a face-to-face interview. Medicare audits do not involve disclosure of any personal client information. 

    For Medicare Australia auditing purposes, psychologists are required to retain documentation related to the Medicare service for a period of 24 months, including the medical practitioner’s referral, appointment and billing schedules and evidence that reporting requirements are met (at the six session review and/or at completion of treatment, whichever comes first). 

Number of services

  • Are there any circumstances under which a client can receive more than 10 psychological services per calendar year?

    The maximum number of Medicare funded services per calendar year under the Better Access initiative is 10 individual and 10 group sessions. There are no exceptional circumstances that allow further services once these have been completed.

  • What happens if a client hasn’t used up all the sessions they were referred for by the end of the calendar year (i.e. December 31)?

    Referrals for the provision of psychology services do not have an expiry date. They are valid for the stated number of services on the referral rather than a period of time. Where these referred services are not used during the calendar year in which the client is referred, the unused services may be used the next calendar year, where they will count towards the maximum number of services available to the client in that year.

    If a client stops attending and after follow-up fails to present for services for an extended period of time (e.g., three months), it is good practice to inform the referring practitioner and provide a completion of treatment report. If the client represents after this time the client file can be reopened using the remaining services available on the referral and the GP informed.

Private Health Insurance

  • Can clients use their private health insurance along with the Medicare rebate to cover the cost of sessions?

    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 whether they will use Medicare or private health insurance ancillary cover to pay for psychological services they receive. Where the client chooses to claim against their health insurance (gets a better rebate, has exhausted the 10 sessions, or does not have a specified mental health disorder), the psychologist can assist the client and the health insurance company by not including the Medicare item numbers on the account and including a statement to that effect such as ‘This service does not attract a Medicare rebate'.

  • I’ve heard that some health insurance companies will not pay benefits because a client has not used up their 10 Medicare sessions in the calendar year. Is this allowable?

    Some private health insurance companies require individuals to use the 10 sessions under Better Access prior to accessing psychology services under their private health insurance. This information is generally provided to applicants in the information pack provided by the private health insurer.

    Clients should check their private health insurance policy and ask specifically about this requirement prior to taking out private health insurance.

    The Private Health Insurance Ombudsman provides an independent service to help consumers with private health insurance concerns.

Public-private work

  • Can Medicare items be provided by psychologists working in a publicly-funded organisation?

    No. Psychology Medicare items cannot be claimed for services that are provided within any other Commonwealth or State-funded program or facility in which the psychologist is an employee (e.g., hospitals, schools, community correction centres). 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.

    This means that an employed psychologist who is paid a salary cannot allow their employer to use a provider number assigned to the psychologist for the purposes of claiming a Medicare rebate for the services provided by the psychologist as an employee in a Government funded service. This is because Commonwealth and State funded programs and facilities are already in receipt of funding for services.

    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). More information can be found in the Medicare Benefits Schedule – Allied Health Services.

  • Are there any circumstances under which a psychologist can claim Medicare rebates for services provided in a public organisation (i.e., public hospital)?

    Psychologists can only provide Medicare services in a public health setting if they have entered into a private practice arrangement and are operating a private practice co-located within the service. This would include the situation where a psychologist pays a facility fee to cover the costs incurred by the public health setting for providing the facilities.

    The psychologist is not paid a salary by the public health setting under such an arrangement and does not sign over any of the Medicare benefits to the hospital.

Referral issues

  • What constitutes a valid referral under the Better Access initiative?

    According to the Medicare Benefits Schedule, “The referral may be in the form of a letter, or note to an eligible allied health professional signed and dated by the referring practitioner. The allied health professional must be in receipt of the referral at the first consultation.”

    The APS has been advised that the referral can be in the form of an email from the referring practitioner. If the referral does not specify the number of sessions, under the Better Access initiative the practitioner can assume it is for six sessions. The referral can be verbal rather than written however, the psychologist should be mindful that if audited, they must produce evidence of the referral. Hence, the APS recommends that information about a verbal referral is documented in the psychologist’s notes and followed by written and signed confirmation from the referring medical practitioner.

    The referral letter can be directed to the psychologist by name or may be addressed generically to ‘the psychologist’. According to advice from Medicare,

    “The legislation does not require that a referral should be addressed to a named health professional. If a referral is addressed to one provider, the patient is not obliged to go to the same practitioner. They can see another practitioner in the same discipline to provide the psychological service. However, this is for the initial consultation only. Once a course of treatment begins (that is the stated number of services on the referral) with a particular psychologist, the patient must be treated by that same practitioner for the stated number of services on the referral. The only exception is when the treating practitioner is on leave; the patient can then be seen by their locum (a practitioner replacing the psychologist while they are on leave for a specified period of time).”

  • How does a psychiatrist or paediatrician refer a client for psychological services under the Better Access to Mental Health Care initiative?

    A psychiatrist or paediatrician in private practice can directly refer their private patients for services from a psychologist as long as they use their Medicare Provider Number and charge the appropriate Medicare attendance item for the referring consultation (specialist psychiatrist Medicare items or consultant physician paediatrician Medicare items).

    Medicare Australia must have processed a claim for the referring consultation before a rebate for the psychology services can be given. A psychiatrist or paediatrician may complete an assessment and treatment plan, however, unlike the arrangements for a referral from a GP (where a GP Mental Health Treatment Plan must be completed), there is no formal requirement that they demonstrate completion of an assessment and treatment plan.

  • Does a client need to have a new referral at the beginning of a new year?

    A new referral is only required once a client has completed the number of sessions on their referral (up to a maximum of six sessions per referral). So if a client accessed two sessions, say, towards the end of one calendar year, and the referral allowed up to six sessions, the client has four sessions that can be accessed in the new calendar year before a review by the GP needs to be undertaken.  However, these four sessions will count towards the client’s 10 sessions allowable in the new calendar year.

Reporting requirements

  • What are the reporting requirements to the referring practitioner when seeking provision of additional services under Better Access?

    Psychologists must provide a written report to the referring medical practitioner at the completion of the course of treatment (a course of treatment is a maximum of six services, but may be less than six).

    In the report the psychologist should outline treatment undertaken, progress and any ongoing needs the client has, recommendations for how those needs could be met, including the need for any additional services under Better Access. The referring practitioner ultimately determines whether to provide the client with a referral for additional sessions under Better Access.