Key Takeaways
- From 1 July 2025, 23 new MBS telehealth items were introduced (18 video and 5 telephone), primarily covering GP Chronic Condition Management Plans that replaced the old GPMP and TCA structure.
- MyMedicare-registered patients are exempt from the 12-month face-to-face requirement for telehealth from 1 November 2025, and the terminology changed from "established clinical relationship" to "eligible telehealth practitioner."
- The 80/20 rule now includes telehealth: a GP who renders 80 or more services (combined face-to-face, video, and phone) on 20 or more days in a 12-month period is automatically referred to the Professional Services Review. A separate 30/20 rule applies specifically to phone consultations.
- PSR ordered over $1.7 million in repayments for inappropriate telehealth billing across five cases in the second half of 2024 alone, with the most common finding being failure to meet the usual medical practitioner requirement.
- More than 5,000 GPs received compliance letters in May and June 2025 about overseas telehealth claiming. Medicare cross-references MBS claiming data with Department of Home Affairs passenger movement records.
Telehealth billing in Australia changed significantly in the second half of 2025, and most of those changes are only now showing up in compliance enforcement. The introduction of 23 new MBS items from 1 July 2025, the MyMedicare telehealth exemptions from 1 November 2025, the removal of several mental health items, and the application of the 80/20 rule to telehealth have collectively redrawn the compliance landscape for GPs, allied health providers, and practice managers. Meanwhile, the Professional Services Review ordered over $1.7 million in telehealth-related repayments across just five cases in the second half of 2024, and more than 5,000 GPs received warning letters about overseas claiming in mid-2025. This guide covers what changed, what triggers an audit, and what your practice needs to get right.
The 23 New MBS Telehealth Items
From 1 July 2025, 18 new video consultation items and 5 new telephone consultation items were added to the MBS. The majority of these sit within the new GP Chronic Condition Management Plan (GPCCMP) framework, which replaced the old GPMP (item 721) and Team Care Arrangement (item 723) structure.
Under the new framework, item 92029 covers preparation of a GPCCMP via video consultation ($156.55), and item 92030 covers review of a GPCCMP via video. Items 92060 and 92061 are the telephone equivalents for preparation and review respectively. The remaining new items cover occupational medicine video and phone consultations and other specialist attendance categories.
The GPCCMP change matters for telehealth billing because referrals under the new framework no longer need to specify the number of allied health services. Patients can access up to five allied health services per calendar year under a GPCCMP, and those services can be delivered via telehealth where the allied health provider meets the eligible telehealth practitioner requirements. The old GPMP and TCA items (229, 230, 721, 723 and their telehealth equivalents) were removed from 1 July 2025, but patients with existing plans can continue accessing services under them until 30 June 2027 as a transitional measure.
For practices with MyMedicare-registered patients, there is an additional requirement: those patients must receive their GPCCMP from their registered provider. This links the care plan directly to the MyMedicare relationship and creates a compliance obligation that your practice management software should be tracking.
What MyMedicare Changed for Telehealth
The most consequential telehealth change from 1 November 2025 is the MyMedicare exemption from the face-to-face requirement. Previously, a patient needed to have had at least one face-to-face MBS service with the same practitioner (or another practitioner at the same practice) within the preceding 12 months to access MBS-rebatable telehealth. MyMedicare-registered patients are now exempt from this requirement entirely.
The terminology also changed on the same date. What was previously called the "established clinical relationship" requirement is now the "eligible telehealth practitioner" requirement. The substance is similar, but the new framing shifts the compliance obligation from the patient relationship to the practitioner's eligibility. The conditions for meeting the requirement remain: either the patient has had a face-to-face visit within the prior 12 months, or they are registered with your practice under MyMedicare.
Three other groups are also exempt from the 12-month face-to-face requirement: homeless patients, patients attending Aboriginal Community Controlled Health Services, and patients accessing certain nurse practitioner telehealth services. Focused Psychological Strategies sessions under the Better Access program also remain exempt, meaning any eligible patient can access these from any eligible GP or participating mental health professional without a prior face-to-face visit.
The MyMedicare exemption also unlocked longer MBS-funded telehealth consultations with a patient's registered GP. From 1 November 2025, the triple bulk billing incentive for longer telehealth consultations expanded from just children under 16, pensioners, and concession card holders to all Medicare-eligible patients registered through MyMedicare. For practices with high MyMedicare registration rates, this significantly changes the economics of telehealth.
The 80/20 Rule Now Includes Telehealth
Since 1 July 2022, telehealth and phone consultations have counted toward the 80/20 rule threshold. This is the rule that automatically deems a practitioner to have engaged in inappropriate practice, triggering a referral to the Director of the Professional Services Review.
The threshold is 80 or more relevant services on each of 20 or more days in a 12-month period. The count combines face-to-face, video, and telephone consultations. Before July 2022, only face-to-face services counted. The inclusion of telehealth means that a GP who sees 50 patients face-to-face and conducts 35 telehealth consultations on the same day has rendered 85 services and is above the daily threshold.
There is also a separate 30/20 rule that applies specifically to telephone consultations. A practitioner who renders 30 or more telephone consultations per day on 20 or more days in a 12-month period is automatically referred to PSR. This is a lower bar and specifically targets high-volume phone consulting patterns.
The RACGP opposed the inclusion of telehealth in the 80/20 rule and recommended a comprehensive review before implementation. The government proceeded without the review. In March 2025, awareness letters were sent to GPs approaching or exceeding the prescribed pattern of services threshold, which means the Department is actively monitoring combined service volumes and will act on them.
If your practice runs a high-volume telehealth model alongside face-to-face consultations, you need to be tracking daily service counts across all modalities. The 80/20 referral to PSR is automatic: there is no discretion involved once the threshold is met.
The Overseas Claiming Crackdown
Billing Medicare for telehealth services while physically located outside Australia is a compliance priority the Department escalated significantly in 2025. Under Section 10 of the Health Insurance Act 1973, Medicare benefits are only payable where both the provider and the patient are physically in Australia. There are no exceptions for telehealth.
In May and June 2025, more than 5,000 GPs received compliance letters about overseas telehealth claiming. Approximately 50 GPs were already under active audit at that time. The detection method is straightforward: the Department cross-references MBS claiming records with Department of Home Affairs passenger movement data. If your provider number submitted claims on dates when border records show you were outside Australia, the discrepancy is flagged automatically.
The letters were characterised as an "educational campaign" and encouraged providers to complete a Voluntary Acknowledgement of Incorrect Payments form if they had incorrectly claimed. In practice, completing that form is a self-reported repayment. For providers who do not self-report, the next step is a formal audit.
This also affects locum arrangements. If a GP is overseas and a locum bills under the absent GP's provider number for telehealth services, the claims are still attributed to the provider number holder. Practices should have a clear process for closing provider numbers when practitioners travel overseas and reopening them on return.
Mental Health Telehealth: What Changed in November 2025
Several mental health MBS items were removed from 1 November 2025 as part of the Better Access Redesign. The removed items include 2712 (MHTP review, face-to-face), 92114 (MHTP review, video), 92126 (MHTP review, phone), 2713 (mental health consultation over 20 minutes, face-to-face), 92115 (mental health consultation over 20 minutes, video), and 92127 (mental health consultation over 20 minutes, phone).
GPs can now use the standard time-tiered general attendance items (Levels A through E) across face-to-face, video, and phone for MHTP reviews and mental health consultations that were previously covered by the removed items. This simplifies the item structure but requires practices to update their billing workflows.
The more significant compliance change is that mental health telehealth items lost their previous exemption from the eligible telehealth practitioner requirement. Before November 2025, mental health telehealth items could be billed without a prior face-to-face visit. That exemption is gone. Patients now need either a face-to-face visit in the prior 12 months or MyMedicare registration to access mental health telehealth from their GP.
Focused Psychological Strategies sessions remain exempt from this requirement and continue to be available to any patient from any eligible provider without a prior face-to-face visit. Referrals made before 1 November 2025 remain valid for their full course of treatment under the transitional arrangements.
Allied Health Telehealth Billing
Allied health providers can deliver MBS-funded services via video and telephone consultations, subject to the same eligible telehealth practitioner requirements as GPs. Under the new GPCCMP framework from 1 July 2025, eligible patients can access up to five allied health services per calendar year, and those services can be a single type (for example, five physiotherapy sessions) or a combination across different disciplines. The current Medicare rebate is $61.80 per session.
Referrals issued from 1 July 2025 under the new GPCCMP framework no longer need to specify the number of services. Patients with a GPMP or TCA in place before 1 July 2025 can continue accessing services under those older plans until 30 June 2027.
For DVA patients, allied health services (except dental, optical, and neuropsychology) can be delivered under permanent telehealth arrangements. Claims follow the DVA fee schedule and must comply with the Notes for Allied Health Providers.
Mental health allied health providers have separate item structures. Better Access provides four psychological therapy items for clinical psychologist services (video and phone available) and 20 Focused Psychological Strategies items for services by psychologists, GPs, occupational therapists, or social workers. The Focused Psychological Strategies items remain exempt from the 12-month face-to-face requirement.
What Triggers an Audit
PSR investigations related to telehealth billing resulted in over $1.7 million in ordered repayments across five cases in the second half of 2024 alone. The most commonly investigated item was 91891 (Level B telehealth consultation), and the most common finding was failure to meet the usual medical practitioner requirement. Sanctions included 12-month disqualifications from billing specific telehealth items and repayment orders ranging from $49,500 to $525,000.
The most common telehealth billing errors that trigger compliance activity are billing from overseas (provider or patient not in Australia), failing the eligible telehealth practitioner requirement (no face-to-face visit in the prior 12 months and patient not MyMedicare-registered), exceeding the 80/20 or 30/20 thresholds, inadequate clinical records (generic or boilerplate notes without evidence of clinical findings supporting the item billed), not meeting minimum time requirements for the item level claimed, billing face-to-face item numbers for telehealth services instead of the correct telehealth item numbers, and failing the usual medical practitioner requirement, which is particularly relevant for corporate telehealth providers where patients see different doctors each time.
The ANAO's performance audit of the telehealth expansion found that the Department of Health conducted no risk assessment of integrity risks before implementing permanent telehealth items, did not document key implementation decisions, and established no performance measures. That report provides institutional context for why compliance enforcement is now intensifying: the system was expanded without adequate safeguards, and the Department is now retrospectively tightening controls.
Australia's enforcement model follows an escalating pattern. It starts with awareness letters (the March 2025 80/20 letters, the May-June 2025 overseas claiming letters), moves to voluntary acknowledgement and self-reported repayment, then progresses to formal audit and PSR referral. If your practice received an awareness letter, it is the first step in that sequence, not a standalone event.
How ClinicComply Helps
ClinicComply tracks your practice's Medicare compliance obligations alongside your other regulatory frameworks. The platform helps you document your telehealth billing policies, track which practitioners meet the eligible telehealth practitioner requirements for which patients, and maintain the records that demonstrate compliance if your practice is ever subject to a Medicare compliance review.
For practices managing the transition from GPMP/TCA to GPCCMP, ClinicComply can help you track which patients are on old plans (valid until 30 June 2027) and which are on new GPCCMP plans, ensuring your billing aligns with the correct item numbers and framework.
If your practice does not currently have a structured way to track Medicare compliance obligations, or if you received an awareness letter and want to tighten up your processes before the next escalation step, now is the time to get organised. Start your free trial at cliniccomply.com.au.
Frequently Asked Questions
What are the Medicare telehealth billing rules in Australia for 2026?
To bill Medicare for a telehealth consultation in 2026, both the provider and patient must be physically in Australia. The provider must meet the "eligible telehealth practitioner" requirement, meaning the patient has had a face-to-face MBS service with the same practitioner or practice within the preceding 12 months, or the patient is registered with the practice under MyMedicare. Video is the preferred modality for substituting face-to-face consultations. Phone items exist but are subject to the 30/20 rule. Email consultations are not billable under any MBS item.
Does the 80/20 rule apply to telehealth consultations?
Yes. Since 1 July 2022, telehealth and phone consultations count toward the 80/20 threshold. A medical practitioner who renders 80 or more relevant services (combined face-to-face, video, and telephone) on each of 20 or more days in a 12-month period is automatically deemed to have engaged in inappropriate practice and referred to the Professional Services Review. A separate 30/20 rule applies specifically to telephone consultations: 30 or more phone consultations per day on 20 or more days triggers an automatic PSR referral.
Can I bill Medicare for telehealth if I am overseas?
No. Under Section 10 of the Health Insurance Act 1973, Medicare benefits are only payable where the provider is physically located in Australia. There are no exceptions. The Department cross-references MBS claiming data with passenger movement records from the Department of Home Affairs. More than 5,000 GPs received compliance letters in May and June 2025 about this issue, and approximately 50 were under active audit. If you are travelling overseas, close your provider number before departure and reopen it on return.
What is the eligible telehealth practitioner requirement?
From 1 November 2025, the eligible telehealth practitioner requirement replaced what was previously called the "established clinical relationship" requirement. For a patient to access MBS-rebatable telehealth, one of the following must be met: the patient has had at least one face-to-face MBS service with the same practitioner or another practitioner at the same practice within the preceding 12 months, or the patient is registered with the provider's practice under MyMedicare. Exemptions apply for homeless patients, Aboriginal Community Controlled Health Services patients, and patients accessing Focused Psychological Strategies.
What mental health telehealth items changed in November 2025?
Several mental health MBS items were removed from 1 November 2025, including MHTP review items (2712, 92114, 92126) and mental health consultation items over 20 minutes (2713, 92115, 92127). GPs now use the standard time-tiered general attendance items (Levels A through E) for these consultations. Mental health telehealth items also lost their exemption from the eligible telehealth practitioner requirement, meaning patients now need a face-to-face visit in the prior 12 months or MyMedicare registration. Focused Psychological Strategies remain exempt.
How many allied health telehealth sessions can a patient access under Medicare?
Under the new GPCCMP framework from 1 July 2025, eligible patients can access up to five allied health services per calendar year. These can be a single discipline or a combination across different allied health types. The Medicare rebate is $61.80 per session. Referrals under the new framework no longer need to specify the number of services. Patients with a GPMP or TCA in place before 1 July 2025 can continue under those plans until 30 June 2027.