MBS billing for registrar services and requirements to personally perform services

There are many situations that can arise in the administration of Medicare billing in public hospitals. These case studies have been constructed to help you find how you can improve your Medicare billing practices.

Case study

Ms A is admitted as a private patient at her public hospital with a fractured forearm and is treated by Dr B, an orthopaedic surgeon.

While in hospital Ms A has an asthma attack and Dr B refers her to Dr C, a respiratory physician.

Dr C’s registrar, who is employed and paid a salary by the hospital, reviews Ms A and arranges for appropriate treatment of her asthma. Doctor C does not physically attend the patient for review or treatment.

Dr C then bills MBS item 110 for a consultation because Ms A is a private patient and was seen by his registrar who is a trainee physician accredited by the Royal Australian College of Physicians.

Is this appropriate?

No.

Registrars are not considered specialists for the purposes of claiming Medicare benefits. A registrar cannot give a referred initial attendance for a patient.

If the registrar provides an initial attendance for the physician, neither the registrar nor the physician can bill for this service.

MBS attendance items are personal attendance items and services such as referred consultation services will attract Medicare benefits. But only if the consultant physician who bills for the service is the person who performed the service.

If the service is performed by another doctor employed by the hospital, which in this case is the registrar. Medicare should not be billed for this service.

In circumstances like this, the payment by the hospital of a practitioner salary, and the payment of a Medicare rebate for the same service creates what is termed a duplicate payment. This is not permitted under the National Health Reform Agreement and the Health Insurance Act 1973.

Key Points

  • Registrars are not considered specialists for the purposes of claiming Medicare benefits.
  • A registrar cannot give a referred initial attendance for a patient.
  • If the service is performed by another doctor employed by the hospital, Medicare should not be billed for this service.
Last updated: 
9 June 2021

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