Assignment of benefit and signature requirements for MBS telehealth services

Update from Minister Butler - 6/10/23
Following the RACGP’s representations to Minister Butler, the Minister has advised that he has asked his department to provide options to address concerns about the assignment of benefit for Medicare bulk billed claims, including legislative amendments. The department has informed the Minister that until these changes are made, there are no plans to pursue any broad punitive actions on this issue unless it relates to fraudulent claims against Medicare.

The new assignment of benefit process outlined below remains in effect. The RACGP will provide further updates on this issue in due course.

GPs now need to document verbal consent from bulk billed telehealth patients using an approved form which can be downloaded from the Services Australia website. Previously the Department of Health and Aged Care (DoHAC) said verbal consent for telehealth consultations could be documented in a patient’s clinical notes, but this is no longer the case.

When seeking verbal consent for telehealth services:

  1. Download the relevant form from the Services Australia website:
    • DB4E digital form for electronically transmitted claims that can be claimed through HPOS Bulk Bill Webclaim. In most scenarios a DB4E is the appropriate form to use.
    • DB020 digital form to be used with Medicare Bulk Bill Webclaims.
  2. Obtain verbal consent and explain to the patient how you will document their agreement.
  3. If the patient agrees, type ‘patient verbally agreed’ in the signature field.
  4. Provide a copy of the form to the patient, ideally by email or text for record keeping.
  5. Keep a copy of all claims and forms for at least two years. This is for auditing purposes if you are subject to a compliance review.

More information about the new assignment of benefit and signature requirements for Medicare Benefits Schedule (MBS) telehealth services is available on the Services Australia website.

DoHAC have published frequently asked questions for providers on the new requirements, which are available from MBS Online.

What is the assignment of benefit rule?

The requirement for a patient’s signature is considered an important deterrent to fraud (eg claims for services that were not provided). The DoHAC is obligated to enforce these rules under section 20A of the Health Insurance Act 1973.

Compliance and auditing

We have received assurances from the DoHAC that no retrospective compliance activities will be completed. However, it is unclear what compliance measures will be undertaken going forward, so we strongly encourage members to follow the correct processes when providing bulk billed telehealth services. You should keep a copy of all correspondence, claims and forms for at least two years for auditing purposes.

RACGP advocacy: cut the red tape

We know many members see this change as further red tape, and a potential barrier to providing bulk billed care, and we are advocating for a better solution. 

The RACGP considers the need to document consent using a form to be an antiquated requirement that must be urgently reviewed. We will be raising our concerns with the Health Minister and calling for a solution that reflects current workflows in general practice.

Our preference is for verbal consent to remain available for bulk billed telehealth consultations, with a digital solution to record consent which minimises the administrative impact on GPs and practice teams. The digital solution needs to be fully integrated with existing clinical information systems and data so it easily fits in with clinical workflows.

Stay up to date with our advocacy on this issue. We know this is frustrating, and we invite you to share your feedback or questions with us. Please email to get in touch and let us know if the RACGP can share your de-identified feedback with the DoHAC.

Write to your local MP

RACGP members can write to their local federal MP about changes to assignment of benefit rules using the letter template below. The document has editable fields for you to fill in before sending.

Click here to find details of your local MP. You can search by name, postcode or electorate.
Download the letter template.