If your practice will not be Assignment of Benefit ready by 1 July 2026, the practical and safest interim is to bill 100% privately, or risk being accused of Medicare fraud.
If your practice is not ready for the Medicare assignment of benefit (AoB) changes coming on 1 July, it is safer, easier and cheaper to bill the patient privately.
The alternative is to keep bulk billing under a workflow that does not yet capture a valid AoB and risk being accused of Medicare fraud. Patients pay the gap or full fee at the counter and claim the rebate themselves. Harder on reception in week one. Far less risky than the alternative.
Reading the public statements from Best Practice Software, MedicalDirector, ZedMed, Clinic to Cloud, PracSuite and other practice management software (PMS) vendors, the payment integrators Tyro Health and the Health Industry Claims and Payments Service (HICAPS), the online claiming platforms, the Services Australia conformance pipeline, and the exchanges between their representatives and practice managers over the last fortnight, the honest picture is this: the ecosystem is still moving.
Customers using each piece of it are not yet fully configured. Most practices will not be fully ready on 1 July 2026.
The largest concern
If a practice offers billing and receipting services to its practitioners through its service agreement, and that workflow does not capture a valid Assignment of Benefit before the bulk bill claim is lodged, the practice owner runs a real and material risk of being sued by the practitioner for assisting in the preparation and lodgement of non-complying Medicare claims.
The software vendor commentary this fortnight has made this exposure unavoidable. Until now, the indemnity and risk allocation in most service agreements either ignored Assignment of Benefit capture or buried it.
Every service agreement should be reviewed this month.
The clause that needs to be in there allocates the obligation to capture and retain the AoB to the practice where the practice is doing the front desk work, indemnifies the practitioner against any front desk failure, and gives the practitioner an express right to bill privately where a valid AoB has not been captured. Without those three elements, the practice owner is exposed.
The practical reality, from speaking to a number of well-run practices is that it will be difficult for practices to be 100% compliant from 1 July 2026 if they are not already there. The day-to-day workflow problem this creates is concrete.
For practices using Tyro Easyclaim, because the signed Assignment of Benefit artefact returned by the terminal is paper and not a digital file in the practice management system, a receptionist will need to scan every printed AoB into the relevant patient record, every working day, to discharge the section 65C two-year retention obligation.
That is more admin time and more money, every day, for the next two years. The alternative is to bill the patient 100% privately. Strictly the AoB obligation does not arise in a private claim, because no Medicare benefit is being assigned (the patient pays in full and claims their rebate from Medicare themselves).
The real practical benefit is cashflow certainty.
The practice is paid at the counter, there is no risk of a claim being rejected or clawed back under audit for AoB non-compliance, and there is no two-year paper retention burden. The practice still has to issue a Medicare-compliant receipt with provider number, item code, date of service and amount paid so the patient can claim their rebate, and the underlying service entity and payroll tax questions are unchanged.
But the bulk-billing specific AoB exposure is avoided. Either way the front desk will get slower, patient explanations at the counter will take longer, and cash flow will be affected in any practice that submits a bulk bill claim without a provable consent on file. That is the choice.
It is not really a choice between technology systems. It is a choice about how the practice wants to spend reception time and which risk it is prepared to carry.
This is not a criticism of any vendor. Tyro, Best Practice, MedicalDirector and the others are doing the work in good faith on the part of the ecosystem they control, and their willingness to engage publicly with practice managers this week has been constructive and welcome.
The integrated picture covering accountant, lawyer, doctors, staff, IT vendors and patients is not in scope for any one vendor. It sits on the practice owner.
Why this matters, and why the cash flow stakes are higher than they look
Lodging a bulk bill claim without a valid AoB is the structural equivalent of lodging a tax return for a refund without the taxpayer signing it.
That is not paperwork. It is Medicare fraud.
Penalties under the Health Insurance Act 1973 and the Criminal Code apply to the practitioner whose provider number is on the claim, and to the practice entity that submitted it.
The cash flow stakes compound this. If your structure relies on the state-by-state GP payroll tax concession, that concession is contingent on the practitioner being genuinely treated as a tenant doctor.
A workflow where the front desk fails to capture an AoB and the practice still submits the claim erodes the documentary record those concessions sit on top of.
Medicare fraud exposure plus payroll tax risk is a much bigger problem than either alone. If you want to keep the exemption and maintain cash flow, you cannot bulk bill under a broken workflow.
The Easyclaim memory, fact checked, and the bulk bill vs private claim distinction
“We stopped using Easyclaim a couple of years ago due to IT issues and too many patients not being able to get rebate payment back via phone and not having a debit card with them. Is this still the case? Our IT has been sorted,” a practice manager posted in one Facebook thread last week.
Tyro Health drew an important distinction on this point in the Practice Managers Network thread this week. The card eligibility issue the practice manager was remembering is a private claim issue, not a bulk billing one. The two flows are different and worth keeping separate.
In bulk billing, the patient assigns the Medicare benefit to the provider. There is no rebate going to the patient. What is required is a compliant Assignment of Benefit captured before the claim is lodged, which is the focus of the 1 July changes and of this article.
In private claims, the patient pays the practice in full. The Medicare benefit is then paid to the patient, not the practice.
For Easyclaim to deliver the instant rebate to the patient at the counter, the rebate has to land on a card connected to the EFTPOS payment rail with a savings or cheque account on insertion.
For practices whose decision is purely about whether they can process bulk billing on Tyro from 1 July, the card eligibility question is not the one to focus on.
The right question is whether the workflow captures a compliant Assignment of Benefit, retains the evidence for two years, handles MBS item changes, and supports telehealth.
Thanks to Tyro Health for raising this. It is exactly the kind of distinction the wider profession needs drawn cleanly before 1 July.
The real cost of bulk billing from 1 July
Until 1 July, bulk billing is operationally cheap.
From 1 July, bulk bill the same number and type of consults will cost more in three ways:
- More IT: working text message infrastructure with an ACMA-registered Sender ID, a PIN-protected web form or tablet, and a PMS that stores the signed artefact against the encounter for two years.
- More staff time: a clinic seeing 60 bulk billed patients a day on a text message catch-up workflow can expect 15 to 20 per cent non-response on day one. That is nine to 12 reconciliation calls per day, plus 30 to 45 minutes of end-of-day batching admin on a 40-patient day.
- More patient-facing friction: the concession card holder who used to walk out in ten minutes now has a longer counter interaction, a text to act on, or a tablet to read and tap.
The marginal cost of one bulk billed service has gone up. A fixed Medicare rebate cannot absorb it. It comes out of margin, doctors’ billings, or volume by converting some services to private billing. The decision needs the doctor in the room.
Related
Tyro
Section 65C of the Health Insurance Act 1973 and the Department of Health, Disability and Ageing FAQ released 21 May 2026 are clear that there is no prescribed template for AoB. The agreement may be paper or electronic, provided it includes the required data set and is agreed to in writing.
In their 31 May 2026 webinar, Tyro confirmed that on their Medicare Easyclaim workflow the patient is prompted on the EFTPOS screen with a yes or no choice after the consult, both patient and provider copies of the assignment advice can be printed, and the assignment is recorded electronically with Services Australia for audit purposes.
For the in-person post-consult press at the counter, this is well supported on the Tyro rail. As at 1 June 2026, it is the strongest published vendor position in that one workflow. Credit to Tyro for it.
However, Adrian Perillo from Tyro Health confirmed in the Practice Managers Network thread this week that the standalone Easyclaim terminal is in pilot, and that bulk billing through Clinic to Cloud, telehealth and other non-in-person workflows are “expanding later this year”. Until those releases land, Tyro covers only the in-person post-consult workflow.
On 1 June 2026 Tyro Health published a blog post which confirmed that its Easyclaim terminal automatically prints a compliant post-consultation AoB agreement assigned by the patient pressing YES or NO on the EFTPOS machine and that compliance currently applies only to PMS-initiated bulk bill transactions on Countertop and Mobile EFTPOS devices, with the Pro Key standalone terminal bulk bill ‘coming later this year’ and not yet available.
Tyro’s Integrated Medicare Easyclaim documentation and Tyro Terminal Adapter documentation explicitly notes that “integrated receipts are not supported for Medicare Easyclaims”.
In practice this means the GetReceipts API call, which is the standard method by which a PMS retrieves a digital copy of what the terminal produced, returns empty for every Medicare Easyclaim bulk bill transaction.
The PMS knows the claim was lodged and approved. It does not receive the signed AoB receipt as a digital file to store against the patient encounter.
No PMS automatically receives or stores the AoB artefact from Tyro through the Easyclaim integration.
For Tyro Easyclaim on the EFTPOS terminal, the AoB artefact is paper only. There is no digital download available from Tyro’s portal for Easyclaim transactions.
Tyro’s own Medicare product page still lists “No batching or storage required for bulk bill claims” as a product feature. Under the pre-1 July regime that was a selling point. Under the new two-year retention obligation it is a clear disclosure of the gap.
For practices relying on Tyro Easyclaim for bulk bill claiming, the section 65C two-year retention obligation can only be met by physically filing and retaining the printed paper provider receipt, per patient, per episode of care.
That is a material operational cost practices need to plan for now.
Best Practice
Best Practice Software (Bp Premier Oxford) has built its own AoB capture and storage workflow inside the practice management system, running alongside the Tyro Easyclaim terminal transaction.
Bp Premier captures the section 65C data set in the PMS itself, stores the signed agreement against the encounter, and manages two-year retention on the PMS side, independently of what Tyro’s terminal does or does not return.
This is why the Easyclaim path only fully works end-to-end for practices using Bp Premier with the AoB configuration enabled.
Practices using MedicalDirector, ZedMed, Clinic to Cloud, PracSuite and other systems need to confirm in writing whether their PMS has built an equivalent parallel capture, because the Tyro integration on its own will not give them one.
It is also important that practices using Best Practice sign up for the AoB compliance configuration in time.
The gaps
Tyro’s June blog post is silent on the patient who leaves before the claim is submitted (end-of-day batching), silent on the MBS item change re-consent requirement, and confirms that telehealth bulk bill is in “further updates coming” and the Pro Key standalone bulk bill terminal is “coming later this year”.
Practices wanting to keep the payroll tax concession and maintain cash flow cannot wait. Either the AoB capture lives in the PMS (Bp Premier Oxford does this today, others may), or the practice manages paper filing manually, or the practice converts to private billing as the safe interim from 1 July.
Whether Tyro, HICAPS or any future entrant, the practitioner must be able to access the captured consent independently and store a copy outside the vendor’s system.
The two-year retention sits on the practice, not the vendor. If the answer to “can we extract everything ourselves at any time, in a format we can store outside your system?” is anything other than yes, that is the gap to close.
It’s also worth noting that a change in MBS item invalidates the existing AoB and requires a new one. The terminal has no native workflow to re-trigger consent. Bp Premier Oxford does.
Two layers of law, both apply
Section 65C tells you what has to be captured: the universal fields, the item-specific fields, one agreement per episode of care, two-year retention by the practice, and the agreement is invalid if the MBS item lodged does not match the item on the agreement.
The Electronic Transactions Act 1999, section 10, tells you what counts as a valid signature when captured electronically: the signatory must be identifiable, the method must be reliable for the purpose, and the patient must consent to the electronic method.
A record can satisfy section 65C on its face and still fall short on the Electronic Transactions Act. Both apply.
Pre-1 July checklist, in workflow order
I have devised a rigorous checklist, which you can access here.
Start with your accountant. Then your lawyer. Then your doctors and staff. Then your IT and software vendors, in writing. Finally your patients. They should not hear about it for the first time at the counter.
David Dahm is a chartered accountant and registered tax agent specialising in medical and allied health practice advisory since 1992. He gratefully acknowledges Lukasz Wyszynski of Hamilton Bailey Lawyers for assistance in the preparation of this article. This article is general in nature and does not constitute legal, tax, or financial advice. Every practice should obtain tailored advice from a qualified lawyer and a registered tax agent before acting on the matters discussed.
