Doctors who bill the MBS and PBS while working for on-demand telehealth platforms will find themselves under the proverbial microscope this year.
The Department of Health, Disability and Ageing has released its official list of compliance priorities for 2026, putting dodgy telehealth providers on notice.
“Our priority is on ensuring providers understand how to claim correctly, to ensure future growth is sustainable,” the department said.
“This includes a focus on Medicare Benefits Schedule (MBS) servicing and requesting, and Pharmaceutical Benefits Scheme (PBS) prescribing, from on-demand telehealth platforms.
“The rise of these businesses raises concerns about opportunistic and/or inappropriate claiming of health program payments, as well as commercial incentives conflicting with clinical best practice, continuity of care and patient safety.”
Since 2021, GPs have only been permitted to bill Medicare for telehealth items if they have seen the patient face-to-face at least once over the previous 12 months.
Until late last year, though, nurse practitioners were permitted to bill the MBS for patients they had never met in person.
There are still exceptions to the established clinical relationship rules, which apply to infants under the age of 12 months or patients affected by a natural disaster and to urgent after-hours services, blood-borne virus and sexual or reproductive health consultations and eating disorder treatment services.
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The DoHDA did not provide any further detail on the specific PBS telehealth prescribing practices or the opportunistic business practices it will potentially be looking out for.
Technically, there are no direct laws or regulations against some billing behaviours which may appear outwardly unethical, such as a clinic offering to pay a provider per script written rather than per patient seen.
The department has listed just five compliance priorities this year, compared to eight in 2025.
The other four priority areas are: care and management plans, claiming MBS services while overseas, open and uncertified PBS claims and inappropriate claiming of PBS medicines.
All four appeared on the 2025 compliance priority list as well.
Some of the areas which appeared on previous years’ priority lists but were not included for 2026 included duplicate payments and illegal bulk billing setups like administration fees.
It also listed four “enduring priorities”, which “present a persistent risk to the integrity and sustainability of Australian government health programs”.
These include preventing fraud, ensuring access to affordable healthcare, safeguarding high-quality services and ensuring health service sustainability.
