It used to be that areas which weren’t rural enough to attract overseas trained doctors could easily plead exceptional circumstances. Now, only one application has been approved since 2023.
The Department of Health, Disability and Ageing working group in charge of deciding whether certain locations are eligible to attract internationally trained doctors serving out their rural moratorium approved 96% of applications in 2021.
But for the last two years running it has not approved any – even in areas with high levels of socio-economic disadvantage, high population growth and dwindling GP numbers.
Is it the sign of a broken system, or a system which is working very well? It’s complicated.
The Distribution Priority Area system was introduced as a mechanism to force migrant doctors into Australia’s underserved regional and remote areas.
Under section 19AB of the Health Insurance Act 1973, foreign graduates of medical schools coming to Australia to work as a GP can only access Medicare by working in a DPA location for at least 10 years from the time of their registration.
For practices, the benefit of being in a DPA location is that recruitment of new GPs is slightly easier because the pool of applicants is larger.
Crucially, if a practice is in an area which it believes should be classified as DPA but is not – say, it believes there are exceptional circumstances affecting access to GP services – it can request a review from the distribution working group.
A record of all distribution working group reviews going back to 2021 was published by DoHDA on Wednesday and shows a sharp decline in both the number of applicants and the proportion of successful applicants over the last four years.
In 2021, the group conceded that there were exceptional circumstances in 24 out of the 25 applications included in the dataset.
In 2022 it accepted 27 applications out of 81, and in 2023 it accepted one out of 19.
In the two years that followed, the dataset shows four applications and 17 applications respectively. None were accepted.
Part of this trend may be explained by the fact that rules around what locations were automatically given DPA status were significantly relaxed in mid-2022.
Where it used to be that only MM3-7 locations automatically received DPA status, this was expanded to encompass all MM2 areas and some MM1 areas as part of an election pledge from Labor.
Locations which had applied for DPA status in the past but been rejected – e.g., Picton-Bargo in NSW – were automatically eligible DPA locations.
Then, in early 2025, DoHDA updated the Modified Monash Model classification system with new data from the 2021 census.
This had the effect of pushing more communities from MM1 regions to MM2 regions.
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At the same time, DoHDA also granted DPA status to 17 outer metropolitan locations that it had identified as having lower levels of GP services compared to the rest of the country.
“This includes considering data on the level of Medicare billed GP services patients received for the latest calendar year; and the demographics of the community, including age, gender, and socio-economic status,” the department wrote at the time.
Applications for DPA status due to exceptional circumstances for Armadale, Molonglo and Surfers Paradise were all denied in 2022 or 2023, only for these locations to be given DPA eligibility in 2025.
It seems possible, then, that there are fewer applications for special consideration of DPA status in recent years simply because there are fewer jurisdictions which haven’t already been granted DPA status.
Some of the more recent decisions included in the DoHDA dataset came from October 2025 and included applications for the NSW suburbs of Campbelltown and Mount Druitt, both of which were denied.
Despite acknowledging that both areas had high or moderate levels of socio-economic disadvantage, the DoHDA assessment was that there were high levels of GP service already and that DPA status was not warranted.
Others, like Lilydale-Yarra Valley, had a smaller than average GP workforce but high levels of GP service and low levels of socio-economic disadvantage; again, the department found that DPA status was not warranted.
