RACGP role in influencing the DoH telehealth compliance campaign


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RACGP role in influencing the DoH telehealth compliance campaign

Late last week, the RACGP was accused of lying to its members by the publisher of a medical media outlet in Australia that focuses on general practice.

The article in question suggested the RACGP has deliberately misled members by saying up to 30,000 GPs had inappropriately billed Medicare Benefits Schedule (MBS) telehealth item numbers.

Here are some of the facts:

  • The Department of Health (DoH) wrote to the RACGP on 12 February 2021 regarding telehealth compliance, advising it will commence a compliance campaign in March/April 2021.

  • In its letter, the DoH states that 26,429 providers ‘may not have met the legislative requirements for an existing relationship’.

  • The DoH confirmed it would apply a tiered approach to compliance treatment, including targeted awareness letters to 9470 providers, targeted compliance letters to approximately 730 providers, and an audit of approximately 33 providers.

  • RACGP President Dr Karen Price responded to the DoH on 18 February 2021 regarding the proposed compliance campaign. In this letter, the Dr Price raised a number of serious concerns about this campaign for GPs

    • ‘The timing of the campaign puts undue pressure on GPs at a time when they will be implementing the most important public health initiative [vaccine rollout] seen in Australia for decades.’

    • ‘A high-profile compliance campaign will do little to encourage GP commitment and dedication that government need for a successful vaccination program.’

  • Dr Price also addressed the confusion regarding the existing relationship requirement introduced in July 2020 for access to MBS telehealth services

    • The RACGP’s specific concern was that we were unable to gain clarity for our members between July and December 2020 about the ambiguity around exceptions to the existing relationship requirement. Dr Price advised the DoH, ‘Given the ambiguity of this period and the lack of clarity provided until December 2020, the integrity of the data for this time period is called into question.’

    • The letter also sought DoH clarification on what criteria were used in their data extraction, seeking answers to a range of questions.

  • While the questions asked weren’t specifically answered by DoH, a follow-up meeting was held on 3 March 2021

    • At this meeting, also attended by RDAA, AMA and ACRRM, the RACGP once again led the charge against such a compliance campaign, citing professional fatigue, stress, anxiety and the COVID vaccine rollout.

    • Fortunately, the DoH then agreed to write only to 730 GPs (since revised further down to around 500 GPs) where there were clearer questions regarding potential non-compliance.

Ensuring an additional 9470 GPs don’t receive an anxiety-producing awareness letter during a public health emergency when we need their skills and expertise more than ever is a win, no matter how others choose to (mis)characterise it.

The RACGP maintains the existing-relationship requirement can help facilitate the delivery of high-quality primary healthcare by GPs and practices with knowledge of a patient’s medical history. As we saw in the first months after the March 2020 introduction of telehealth rebates for patients, there were rogue telehealth-only operators setting up shop to exploit the system. Supporting the introduction of an existing-relationship requirement was a reasonable measure taken to limit the erosion of quality healthcare, while supporting patient access to these vital services.

As the RACGP expressed in its 18 February 2021 letter to the DoH, the challenge for members in seeking to ensure compliance with the requirements was five months of ambiguity over what specifically constitutes a person in a COVID-19-affected area.

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