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Regulatory10 January 202510 min read

Telehealth Medicare Billing: Compliance Requirements for Australian Practitioners

Complete guide to telehealth Medicare billing compliance. Learn about eligible services, patient consent, documentation requirements, and avoiding billing errors.

Hamilton Bailey

Principal Lawyer

Telehealth Medicare Billing Compliance

Telehealth has become an integral part of Australian healthcare delivery. Understanding Medicare billing requirements for telehealth services is essential for compliance and proper reimbursement.

Eligible Telehealth Services

MBS Telehealth Items

Medicare provides specific item numbers for telehealth consultations:

Video Consultations

  • General consultations (various levels)
  • Specialist consultations
  • Mental health services
  • Chronic disease management

Telephone Consultations

  • Available for established patients
  • Specific item numbers for different durations
  • Requirements for clinical appropriateness

Patient Eligibility

Who Can Access Telehealth?

Telehealth services are available to:

  • Patients in metropolitan areas
  • Rural and remote patients
  • Aged care residents
  • Patients with mobility limitations
  • Those requiring continuity of care

Informed Consent

Before providing telehealth services, practitioners must:

  1. Explain the nature of the telehealth consultation
  2. Discuss alternatives to telehealth
  3. Obtain and document consent
  4. Ensure patient understands limitations

Technical Requirements

Platform Standards

Telehealth platforms must meet certain standards:

  • End-to-end encryption for video consultations
  • Reliable audio/video quality
  • Recording capabilities if required
  • Integration with practice management software

Privacy and Security

  • Secure connection requirements
  • Patient verification procedures
  • Data storage compliance
  • Breach notification obligations

Documentation Requirements

Clinical Records

Telehealth consultations require the same standard of documentation as face-to-face consultations:

  • Patient identification and verification
  • Clinical findings and assessment
  • Treatment plan and recommendations
  • Referrals and follow-up arrangements

Billing Documentation

For Medicare compliance, document:

  • Mode of consultation (video/telephone)
  • Duration of consultation
  • Clinical necessity for telehealth
  • Patient consent obtained

Common Billing Errors

Mistakes to Avoid

  1. Incorrect Item Numbers: Using face-to-face items for telehealth
  2. Duration Misrepresentation: Billing for incorrect time periods
  3. Inappropriate Services: Telehealth when face-to-face is required
  4. Missing Documentation: Inadequate clinical records

Audit Triggers

Medicare compliance audits may be triggered by:

  • Unusual billing patterns
  • High telehealth-to-face-to-face ratios
  • Patient complaints
  • Random selection

Best Practice Guidelines

Before the Consultation

  • Verify patient identity and eligibility
  • Ensure technical setup is working
  • Review patient history
  • Confirm consent arrangements

During the Consultation

  • Maintain professional standards
  • Document as you would face-to-face
  • Consider when face-to-face is necessary
  • Address technical difficulties appropriately

After the Consultation

  • Complete documentation promptly
  • Bill using correct item numbers
  • Arrange follow-up as needed
  • Ensure referrals are processed

Regulatory Updates

Recent Changes

Medicare telehealth arrangements have evolved significantly. Stay informed about:

  • Changes to eligible items
  • Modified requirements
  • New service categories
  • Geographic eligibility updates

Conclusion

Telehealth Medicare billing requires careful attention to eligibility, documentation, and billing accuracy. Regular review of MBS requirements and maintaining comprehensive records are essential for compliance. When in doubt about telehealth billing, seek professional advice.

telehealthMedicare billingcompliancedigital health
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About the Author

Hamilton Bailey

Principal Lawyer

Expert in healthcare law with extensive experience advising medical practitioners across Australia.

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