Restricting Medicare rebates for telehealth risks increasing health inequalities

What does the recent Medicare review mean for Australians who rely on digital health services?
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What role should Medicare play in supporting Australians’ access to telehealth? The Medicare Review Advisory Committee (MRAC) recently sought to answer this question with the release of its final report on telehealth.

The final report is largely similar to MRAC’s interim report, which was released for public consultation in late 2023 (to which Eucalyptus contributed). As a government-commissioned review body, MRAC’s opinions carry some weight, however, the report’s status is only that of a recommendation. The federal government still may or may not decide to implement its viewpoints. 

Below we outline the key themes of the MRAC’s final report and how they impact telehealth platforms such as Eucalyptus.

The risk of the “12-month rule” for GP telehealth consultations 

Currently, Australians can only access Medicare rebates for telehealth consultations with a GP if they have seen that GP (or another GP in the same clinic) in person within the previous year. This is known as the ‘12-month rule’ and was introduced early in the COVID-19 pandemic.

The originally stated purpose of the rule was to foster continuity of care, prevent fragmentation of treatment and discourage patients from ‘doctor-shopping’. While these are admirable goals for the health system, in practice the rule does not necessarily achieve these aims and in fact, it may reduce access to care.

As Eucalyptus pointed out in its submission to the MRAC public consultation, the 12-month rule does not actually require a patient to have a long-standing or continuous relationship with a GP in order to become eligible for Medicare rebates for a telehealth consultation. All it requires is that the patient has had a single in-person consultation – which could have been six minutes long, for a simple antibiotic script – with any GP in the same clinic (not even the same individual GP who subsequently undertakes the telehealth consultation).

This is hardly the definition of continuity of care. And it also does nothing to stop the patient from attending three other GP clinics during the same 12 months – for instance, if the patient moves house, cannot secure an appointment in the original clinic, or finds a cheaper clinic.

At the same time, by prioritising face-to-face consultations as if they were the only method of ensuring continuity of care, the 12-month rule favours patients who are easily able (and can afford) to visit clinics in person. These are typically patients who live in metropolitan and suburban areas and not regional, remote or low socioeconomic areas, who, incidentally, also tend to have the greatest unmet health needs.

MRAC’s final report nonetheless retained its support for the 12-month rule (although, notably, it no longer defends the rule on the basis that it prevents ‘doctor-shopping’). But in a possible opening for future consideration, the report suggests that the rule could instead be defined by reference to a patient’s MyMedicare registration with a particular GP clinic. The potential implications of this for access to telehealth are as yet unclear.

Proposal to impose the 12-month rule on nurse practitioner telehealth consults

Currently, the 12-month rule does not apply to telehealth consultations conducted by nurse practitioners. This means that patients can obtain Medicare rebates for these consults even if they have not previously seen the practitioner in person. As it happens, though, most patients’ interactions with nurse practitioners are not purely via telehealth. According to MRAC’s own data, roughly 54% of nurse practitioner services were face-to-face only, while 33% were a mix of in-person and telehealth; only 15% were purely telehealth.

MRAC’s final report proposes to extend the 12-month rule to nurse practitioner telehealth consultations. It argues that it would be inconsistent to have the rule apply to telehealth consultations undertaken by doctors but not to those undertaken by nurse practitioners.

While this argument may seem reasonable at a surface level, it also assumes that GPs and nurse practitioners are otherwise in equivalent positions regarding Medicare rebates – but they are not. For example, GP consultations attract considerably higher rebates than nurse practitioner consultations. And until recently, consultations with a nurse practitioner did not attract rebates at all unless they had a ‘collaborative arrangement’ in place with a GP.

Moreover, nurse practitioners are key to improving access to care for the most vulnerable Australians, particularly those who cannot afford more expensive GP consults and those who live in regional and rural areas. While around 30% of nurse practitioners work in those more remote parts of the country, there would be many more who live in metropolitan areas and provide telehealth consultations to regional patients. Imposing the need for an in-person consultation on those patients will only further hinder their access to care.

While MRAC toned down its previous support for applying the 12-month rule to nurse practitioners by proposing to define it not by reference to an in-person consultation but instead by something else relevant to continuity of care, it remains to be seen whether the federal government takes up MRAC’s recommendation and what impact this may have on access to care.

The future of telehealth reimbursement

Despite some of its recommendations raising questions about intensifying inequalities in Australia’s health system, MRAC did accept that the existing research indicates telehealth to be as effective as face-to-face consultations and that it will continue to play an important role in our healthcare sector.

And while the final report included some disappointingly emotive comments about telehealth platforms such as Eucalyptus, it did also support the development of national accreditation standards for all forms of telehealth. As we have previously written, the need for such standards is a topic on which Eucalyptus agrees.


Lyndon Goddard
Senior Legal Counsel & Head of Public Policy