Like the AMA, the RACGP has outright rejected proposals allowing the PSR powers to cover informed financial consent cases.
As the Department of Health, Disability and Ageing contemplates stricter punishments for doctors who violate informed financial consent, the RACGP has given it a timely reminder that mixed and private billing arrangements are still totally legal.
The college’s submission to the DoHDA consultation on fee transparency and split billing in healthcare, which was published today, completely rejected nearly all proposed reform options.
“Government initiatives have increasingly sought to encourage higher rates of bulk billing to improve affordability,” the college wrote.
“While the RACGP supports affordable access to care, GPs are not required to bulk bill Medicare services, and many practices must continue to rely on lawful mixed and private billing arrangements to remain financially sustainable.
“Fee transparency reforms should support informed patient choice without unintentionally discouraging lawful billing models or undermining practice viability.”
The consultation itself was one part of the broader reform work looking at affordability, transparency, and access to non-GP specialist care, fitting alongside referral pathway reform and Medical Costs Finder changes.
In this instance, DoHDA was specifically looking at how practitioners who had potentially engaged in inappropriate practice by failing to gain financial consent from their patients should be regulated.
Of the six reform options presented, the RACGP only backed one, which was to continue relying on education, guidance, and voluntary compliance measures; even then, the college’s support was conditional on “any cost information [being] contextualised and accurately [reflecting] the factors influencing fees in general practice”.
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Among the five options that the RACGP outright rejected was one to expand the PSR’s role, which the college noted was likely to increase “perceived compliance pressures on GPs and practice staff”, and one which would expand the powers of the ACCC, which the college said risked oversimplifying the complexity of general practice.
The three other rejected options were: expanding DoHDA’s compliance role, amending Health Practitioner Regulation National Law, and establishing an entirely new regulator.
Overall, the college said it did support informed financial consent as a fundamental patient right, but that it feared a broad legislative approach was impractical.
It also skirted a direct question on whether providers should be penalised for not providing informed financial consent, writing that general practice was structurally different from non-GP specialist private practice and that GPs should not be penalised for the context in which they delivered care.
“Many general practices already discuss fees with patients before services are provided,” the college said.
“The RACGP’s primary concern is therefore not the principle of informed financial consent itself, but the risk that future reforms may increase administrative burden and red tape without improving patient outcomes.”
To that end, the RACGP also emphasised its stance that GPs should not be responsible for providing information about fees charged by other practitioners.
