Q&A -Medicare Monitoring and the PSR

Where a patient has a concern, and asks for a skin check then you can apply an appropriate Medicare item ensuring all requirements (time and complexity) of that item number are met. The situation when a patient presents for a ‘skin check’ and is asymptomatic is more complex. If the patient has a previous personal history or a family history which makes them high risk then it could be argued that due to their ‘higher risk’ then ‘screening’ is appropriate. The RACGP advises: A 'skin check' can be defined as a comprehensive assessment and examination of an asymptomatic patient for any evidence of skin cancer. Current Australian guidelines advise against general population screening for skin cancer, citing the lack of evidence for the feasibility of organised screening and the effectiveness of screening in reducing mortality. Patient self-examination with opportunistic screening is the current standard.5–7

If the student consults you for example in relation to a needle stick injury or high-risk activities then that is not screening. If you are consulted by the student as this is required by the hospital then in most circumstances this is also usually not screening. It could be considered as part of ‘employment medical’ however we believe that most practitioners would bill Medicare. However, only Medicare can provide a definite answer.

If for example a company wants to vaccinate its 1000 workers. They require you to visit the factory, supply the vaccination and the company pays for this then that is mass vaccination and is not covered by Medicare. It depends on who is paying for it and the circumstances. Vaccinations for older people in general practice however is not regarded as mass vaccination.

At the uni. we run " flu clinics" seeing the patient individually, obtain a written consent, history checked, vaccine given and fact sheet given re the vaccine + 10 min observation post immunisation, we bill an item 3. Is that valid? Assuming the patient consulted you and asked for the vaccination then that is not mass vaccination and provided the requirements of item 3 number are met, then that should be ok. The notes should reflect an item 3

There are no fines. Practitioners may negotiate an agreement regarding how much of patient fees should be reimbursed to Medicare. The individual practitioner is always responsible for all billings under their provider number and currently the practitioner is liable for any determination concerning repayment. If applicable, ensure you have something in your employment agreement in the event a repayment is required e.g. if invoicing under Medicare in public outpatient clinics. The employer can refund your service charge so that Medicare can collect all or part of the repayment from your employer.

The 80/20 rule is a deeming provision to address consistent high volumes of rendered services by general practitioners and other medical practitioners. The regulations specify that a general practitioner (GP) or other medical practitioner (OMP) is deemed to have practised inappropriately if they have rendered 80 or more professional attendances on each of 20 or more days in a 12-month period. You are automatically guilty of inappropriate practice unless you can prove otherwise.

Yes, it does and you have to justify it. Your notes very important and need to include examination, detailed history, management plan. High standards of notes are expected. You have got to meet the requirements of the item number - time and complexity.

The issue is whether this occurs on each of 20 more days in a 12-month period. Practitioner in flu clinics should be able to justify such a pattern of billings with appropriate contemporaneous records

After the full Professional Services Review process has been completed and determinations made, there is an appeal process but no practitioner has been successful in upholding a decision in the past 10 years. MIPS does not routinely fund appeals and would only do so if a legal opinion stated that to do so was legally justified and that the chances of success were high.