Practices charging ‘membership’ fees for bulk billing

4 minute read

'We’d all love to know’ what makes such fees compliant with the Health Insurance Act, says RACGP vice president.

More than 6% of clinics across the country that bulk bill for standard adult consults are charging “membership” fees for these services, a new Cleanbill report finds, despite the law clearly stating that GPs cannot levy additional charges on patients when bulk billing.

The new report, one of a series of analyses by Cleanbill on data from general practices across the country, found 98 practices that “bulk bill all of their non-concession adult patients [for a standard consultation], provided these patients pay some sort of membership fee to access the clinic”.

The frequency of “membership clinics” and average upfront costs varied markedly between states and territories.

NSW and Victoria had the highest numbers of membership clinics, 30 and 42 respectively.

No membership clinics were recorded in the Northern Territory and only one clinic was recorded in each of Tasmania and South Australia.

Average upfront costs ranged from $60 in South Australia’s clinic to $167 in Tasmania, with the national average sitting at $78.

According to Cleanbill CEO James Gillespie, while the report didn’t outline the exact structures of what it called “membership clinics”, 90% or more of the clinics seemed to operate by attaching an upfront fee to initial appointments and bulk billing thereafter.

“We [also] have yearly and monthly membership clinics, which are a far less common type of membership clinic,” he told The Medical Republic.

The structure of these clinics, and how they are billing patients, has prompted queries over their legality.

The national Health Insurance Act 1973 stipulates that practitioners who are bulk billing cannot levy additional costs on patients.

While there may be ways to legally charge membership fees, annual admin or registration fees are “not permitted to guarantee bulk-billed services to patients”, according to the federal Health Department.

“It does not matter how the fee is described (record keeping fees, booking fees, annual administration or registration fees, or cooperative membership fees) or when it is charged (annually, quarterly, before each appointment, or before/after an initial professional service is rendered),” said DoHAC.

Speaking to TMR, GP and AMA vice president Dr Danielle McMullen said that the Health Insurance Act 1973 was clear that practitioners could not bulk bill and charge an additional fee for the same service.

“We’ve seen over many years, a small number of clinics look at some of these subscription or membership type offerings,” she said.

“There is potentially scope for [membership fees] to be a legal option, but I would encourage practices and doctors to be very cautious and make sure that they’re getting advice around this.

“For [membership fees] to be legal, we would think it needs to be very clear that the subscription payment is not for those same services that are then bulk billed.”

As a practice owner himself, vice president of the RACGP Associate Professor Michael Clements said he understood the appeal of a membership fee model and that, if such a model was viable, he would be keen for the department to outline the ins and outs.

“We know that, with the years of the underfunding of Medicare and the very clear evidence, that Medicare rebates alone aren’t sufficient to run a viable practice,” he said.

“The idea of being able to charge patients a membership fee to access the clinic is appealing to a practice owner as it gives a reliable, regular, upfront income.

“It’s also convenient because it means that when patients sign up, they can continue to come as often as they please.”

The Cleanbill data showed that practices were adopting this model, “in what they believe must be a compliant way”, said Professor Clements, and, as far as he was aware, they have not been subject to investigation by Medicare or the PSR.

“We would just like some clarity,” he said.

“If membership fees are allowed in some structure or form, then let us all benefit from that, let all of the practices choose this option, as a way of maintaining viability of a practice.”

Professor Clements said the dichotomy between “what seems to be clear guidance from the government” and the lack of compliance action left other practice owners in “limbo”.

He called on the department to come to the college’s Practice Owners Conference to speak on what makes membership fees compliant.

“We’d all love to know.”

Dr McMullen encouraged practices to get advice, if in any doubt.

“We just need to make sure that any of these novel ideas, while they might be well intentioned, fit within our current legal frameworks,” she said.

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