Key Takeaways
- Twelve MBS items for MHTP reviews and ongoing mental health consultations were removed from 1 November 2025. Review items removed: 2712, 92114, 92126, 277, 92120, and 92132. Consultation items removed: 2713, 92115, 92127, 279, 92121, and 92133.
- From 1 November 2025, GPs use time-tiered general attendance items to review an MHTP, refer a patient for psychological treatment, and deliver ongoing mental health consultation. There is no longer a dedicated MBS item for this work.
- MHTP preparation and referrals must now come from a GP at the patient's MyMedicare-registered practice, or from the patient's usual medical practitioner: someone who provided the majority of services to the patient in the past 12 months or is likely to do so in the next 12 months.
- From 1 November 2025, telehealth MHTP items are no longer exempt from the established clinical relationship rule. GPs must have seen the patient face-to-face at least once in the past 12 months before claiming telehealth MHTP items.
- Focused Psychological Strategies (FPS) telehealth items retain their exemption from the established clinical relationship rule. Any eligible GP or prescribed medical practitioner with appropriate GPMHSC training can deliver FPS via video without the prior face-to-face requirement.
- The annual session limit is unchanged at 10 individual sessions and 10 group sessions per calendar year.
- MHTP referrals issued before 1 November 2025 remain valid until all sessions specified in the referral have been delivered, within the annual maximum.
Twelve MBS items for mental health treatment plan reviews and consultations disappeared from the schedule on 1 November 2025. Practice management software flagged the change in October 2025. Five months later, practices are still finding compliance gaps in the workflows that replaced them.
The November changes were substantial. They removed the specific billing architecture GPs had used for Better Access since the program began and replaced it with a requirement to use ordinary time-tiered general attendance items. At the same time, they applied new MyMedicare restrictions to who can create an MHTP and refer a patient for psychological treatment. And they ended the telehealth exemption that had allowed GPs to deliver MHTP-related services via video without first having seen the patient in person.
This guide covers what changed, what those changes mean operationally for GP practices in 2026, and where the audit risk now sits.
The Items That Were Removed
MHTP Review Items
The following MHTP review items were deleted from the MBS from 1 November 2025:
- Item 2712 (face-to-face MHTP review, GP and prescribed medical practitioner)
- Item 92114 (video MHTP review)
- Item 92126 (phone MHTP review)
- Item 277 (face-to-face MHTP review, prescribed medical practitioner)
- Item 92120 (video MHTP review, prescribed medical practitioner)
- Item 92132 (phone MHTP review, prescribed medical practitioner)
Ongoing Mental Health Consultation Items
The following ongoing mental health consultation items were also removed:
- Item 2713 (face-to-face mental health consultation over 20 minutes)
- Item 92115 (video mental health consultation over 20 minutes)
- Item 92127 (phone mental health consultation over 20 minutes)
- Item 279 (face-to-face consultation, prescribed medical practitioner)
- Item 92121 (video consultation, prescribed medical practitioner)
- Item 92133 (phone consultation, prescribed medical practitioner)
Any claim for these items for services rendered after 1 November 2025 is non-compliant. If your practice management software has not been updated, or was configured incorrectly after the transition, claims submitted after that date using these item numbers represent a Medicare billing error and create audit exposure.
The changes were driven by a 2022 independent evaluation of Better Access that identified significant equity problems with the program, including widening access gaps for people from lower socioeconomic backgrounds and rural areas, and record-high gap fees that were pricing out vulnerable patients.
What Replaces Them: Time-Tiered General Attendance Items
From 1 November 2025, GPs use standard time-tiered professional attendance items for MHTP reviews, referrals, and ongoing mental health consultation. This means billing the same consultation items used for any other appointment: the appropriate item for the actual time spent with the patient, whether face-to-face, video, or phone.
There is no separate mental health billing item for this work. The GP selects the item that reflects consultation duration, applying exactly the same descriptors used for general attendance consultations.
This has two practical effects. First, greater flexibility: GPs can bill a longer consultation item for a thorough MHTP review, or combine the review with a physical health consultation in the same appointment, without being constrained by the fixed parameters of a dedicated mental health item. Second, the triple bulk billing incentive now applies to MHTP reviews for Commonwealth concession card holders and children under 16, because the consultation is billed using general attendance items rather than the dedicated mental health items that previously did not attract the tripled incentive.
GP training requirements are unchanged. GPs must still hold Level 1 training accredited by the General Practice Mental Health Standards Collaboration (GPMHSC) to prepare MHTPs and use Better Access. The November 2025 changes affect the billing mechanism, not the clinical competency framework.
For practices managing the interaction between Better Access and general telehealth billing, the full telehealth item framework including how the established clinical relationship rule applies across different item types is covered in our guide to telehealth Medicare billing compliance.
MyMedicare: Who Can Prepare an MHTP
From 1 November 2025, MHTP preparation, referrals for psychological treatment, and MHTP reviews must come from a GP who meets one of two criteria:
- The GP works at the general practice where the patient is enrolled under MyMedicare, or
- The GP is the patient's usual medical practitioner, meaning they provided the majority of services to the patient in the past 12 months or are likely to do so in the following 12 months.
The second criterion covers GPs at a different practice who have a genuine ongoing relationship with the patient. "Majority of services" is assessed against the patient's MBS claiming history. A colleague at the same practice location also qualifies as the patient's usual medical practitioner, provided the relationship is genuine and documentable.
This restriction does not apply to Focused Psychological Strategies. GPs and prescribed medical practitioners with appropriate GPMHSC training can provide FPS services to any eligible patient, without requiring a MyMedicare enrolment match or a usual medical practitioner relationship.
For practices where multiple GPs see mental health patients, the operational implication is specific: a GP who sees a patient for the first time and prepares an MHTP, without being at the patient's enrolled practice or having an established majority-of-care history, is not entitled to bill for that MHTP preparation from 1 November 2025. Practices should confirm patient MyMedicare enrolment status at the time of MHTP preparation. For a full account of how MyMedicare affects billing obligations across the practice, see our MyMedicare compliance obligations guide.
Telehealth: The Established Clinical Relationship Requirement
Before 1 November 2025, telehealth MHTP items were exempt from the established clinical relationship rule. A GP could prepare or review an MHTP by video with a patient they had never seen face-to-face.
That exemption ended on 1 November 2025.
From that date, telehealth MHTP services must comply with explanatory note AN.1.1. In practical terms, the GP must have seen the patient face-to-face at least once in the past 12 months before claiming a telehealth item for MHTP-related work. Prior video or phone consultations do not satisfy this requirement. The intent of AN.1.1 is that the treating relationship has some grounding in physical presence before transitioning to remote delivery.
Focused Psychological Strategies telehealth items remain explicitly exempt from this requirement. FPS services by video continue to be available to any eligible patient from any eligible provider, without the face-to-face prerequisite.
For practices that shifted heavily toward telehealth during the pandemic and maintained that model for mental health patients, this change requires a direct review of patient records. Any patient who has not had a face-to-face encounter with the GP in the past 12 months cannot receive telehealth MHTP services until a face-to-face appointment is completed and recorded.
The audit risk is specific: a telehealth MHTP service claimed for a patient with no face-to-face consultation in their clinical record in the prior 12 months is non-compliant. Services Australia uses MBS claiming data, including the relationship between consultation type and documented patient history, when reviewing practices flagged for audit. Our guide to Medicare compliance and the 80/20 rule covers how pattern-based analysis identifies practices for review.
What Has Not Changed
The annual session limit remains 10 individual sessions and 10 group sessions per calendar year. The session allocation was reduced from 20 sessions as part of the 2023 changes to the program. The November 2025 overhaul did not alter these limits.
MHTP referrals issued before 1 November 2025 remain valid until all sessions specified in the referral have been delivered, within the annual maximum. Practices do not need to reissue referrals for patients who were already mid-course when the changes took effect.
GPs still require Level 1 GPMHSC training to provide Better Access services. The clinical competency and training framework is unchanged.
How ClinicComply Helps
Better Access compliance now spans three overlapping requirements: correct item selection for MHTP-related work, MyMedicare enrolment verification at the time of plan preparation, and face-to-face history confirmation before telehealth MHTP consultations. Each is a workflow check that must be embedded in practice rather than remembered case by case.
ClinicComply's policy library lets you store updated billing checklists and clinical workflows against the specific Better Access obligations they address. When MBS rules change, you update the relevant policy, assign a review task to the responsible team member, and track completion through the dashboard. Automated reminders flag compliance review dates before they pass.
For practices with multiple GPs managing mental health patients across face-to-face and telehealth, the team management features in ClinicComply let you coordinate obligations across your workforce without relying on each clinician to stay current independently. Use the compliance calendar to keep all active Better Access, telehealth, and MyMedicare obligations visible in one place. For downloadable billing and clinical documentation templates, see the ClinicComply template library.
See the full feature set at cliniccomply.com.au/features, or start a free 30-day trial at cliniccomply.com.au/signup.
Frequently Asked Questions
What happened to MHTP item 2712?
Item 2712 was removed from the MBS from 1 November 2025 as part of the Better Access redesign. GPs now use time-tiered general attendance items for MHTP reviews, referrals, and ongoing mental health consultation, in the same way they bill for any other consultation. There is no longer a dedicated MHTP review item in the schedule. Any claim for item 2712 for services rendered after 1 November 2025 is non-compliant and creates Medicare audit exposure.
What item should I use now for an MHTP review?
Use the standard time-tiered professional (general) attendance item that reflects the time you spent with the patient during the MHTP review. For shorter consultations, the short attendance item applies; for consultations of 20 minutes or more, use the standard attendance item; for longer reviews of 40 minutes or more, use the extended attendance item. The same time-tiered logic applies to video and phone telehealth equivalents. From 1 November 2025, no specific mental health item number is required for MHTP review, referral, or ongoing mental health consultation work.
Does MyMedicare apply to all mental health Better Access items?
The MyMedicare and usual medical practitioner restriction applies to MHTP preparation, MHTP reviews, and referrals for psychological treatment services. It does not apply to Focused Psychological Strategies. Any eligible GP or prescribed medical practitioner with the appropriate GPMHSC training can provide FPS services to any eligible patient, regardless of where the patient is enrolled under MyMedicare.
What is the established clinical relationship requirement for telehealth mental health items?
From 1 November 2025, GPs must have seen the patient face-to-face at least once in the past 12 months to claim telehealth items for MHTP-related work, under explanatory note AN.1.1. This requirement previously did not apply to MHTP telehealth items, which were exempt. Prior telehealth or phone consultations do not satisfy the face-to-face requirement. A GP who has not seen a mental health patient in person in the past 12 months must schedule and complete a face-to-face appointment before resuming telehealth delivery of MHTP services.
Are FPS telehealth items exempt from the clinical relationship rule?
Yes. Focused Psychological Strategies telehealth items retain their exemption from the established clinical relationship rule after 1 November 2025. An eligible GP or prescribed medical practitioner with the appropriate GPMHSC training can deliver FPS services by video to a patient they have not seen face-to-face in the past 12 months, without satisfying the AN.1.1 requirement that now applies to MHTP telehealth items.
What are the audit risks for GP practices in 2026 under Better Access?
The three primary audit risks are: claiming removed items (2712, 2713, and the associated telehealth and prescribed medical practitioner variants) for services rendered after 1 November 2025; claiming telehealth MHTP services without a documented face-to-face encounter in the patient record in the prior 12 months; and preparing MHTPs or issuing referrals without satisfying the MyMedicare enrolment or usual medical practitioner criteria. Services Australia uses MBS claiming pattern data to identify outliers, and newly restructured item frameworks attract closer scrutiny in the transition period. Practices should review claims submitted since November 2025 against all three criteria.
Do referrals issued before 1 November 2025 need to be reissued?
No. An MHTP referral issued before 1 November 2025 remains valid until all treatment sessions specified in the referral have been delivered, within the annual maximum of 10 individual sessions per calendar year. Practices do not need to reissue referrals for patients who were already receiving treatment under a pre-November 2025 referral. Any new MHTP preparation or referral created on or after 1 November 2025 must comply with the new MyMedicare and usual medical practitioner requirements.
What is the annual Better Access session limit in 2026?
The session limit is 10 individual sessions and 10 group sessions per calendar year under Better Access. This was unchanged by the November 2025 overhaul. The reduction from 20 individual sessions was implemented as part of earlier changes in 2023. Patients who have used their annual allocation cannot access additional Better Access sessions in the same calendar year under any of the restructured billing arrangements.
Can a GP at a different practice from the patient's MyMedicare enrolment prepare an MHTP?
Yes, but only if that GP qualifies as the patient's usual medical practitioner. A usual medical practitioner is one who provided the majority of Medicare-billed services to the patient in the past 12 months, or who is likely to do so in the next 12 months. A GP at a different practice who has seen the patient regularly and can document a majority-of-care history satisfies this criterion. A GP who is seeing the patient for the first time, or who has provided only occasional services, does not satisfy the criterion and cannot prepare an MHTP from 1 November 2025.