Considered Health

Issue 18 - Health Newsletter

MBS Review: General Practice

The Department of Health has recently released the latest Medicare Review Report for General Practice and Primary Care Clinical Committee.  This Phase 2 report focusses on the general consultation, chronic disease management, health assessment and medication management items. 

The report has not yet been endorsed by the Minister for Health and the Commonwealth Government, peak bodies have been given the opportunity to make submissions by 1st March 2019.  It is however expected that the majority of these recommendations will be endorsed and implemented. 

General practices are encouraged to carefully consider the potential service model and revenue implications of these changes.  

Key recommendations in the report include:

  1. Move to a patient-centred primary care model supporting GP stewardship.
  2. Introduce a new voluntary patient enrolment fee.
  3. Introduce flexible access linked to voluntary patient enrolment.

Recommendations 1-3 mirror the Health Care Homes (HCH) Model and will prepare practices for the reforms that are likely to evolve from the HCH Trial. Registered patients will have access to non-face-to-face services via telephone, email, videoconferencing. This flexibility will be particularly useful for patients with disabilities, transport challenges or living in remote rural locations. 
  1. Combine GP Management Plans (GPMPs) and Team Care Arrangements (TCAs) and strengthen GPMPs.
This measure aims to reduce the red tape surrounding TCAs. GPMPs must be greater than 40 minutes so it will mean that involvement of a practice nurse in the process is necessary for it to be financial viable.
The financial impact will also depend on whether the new GPMP rebate is the combined value of the previous GPMP & TCA. To claim a GPMP, practitioners will be required to upload the patient's Shared Health Summary to My Health Record, where a patient has not opted out.
  1. Link allied health items to GPMPs.
  1. Equalise the rebate for GPMPs and GPMP reviews.
This measure is aiming to improve continuity of care delivered and will change the mindset of the current care planning process which focusses on the GPMP/TCA. A lot of practices do not regularly undertake systematic reviews of their care plans. These changes will mean that in future most patients will only require an initial GPMP and all subsequent care planning activities will be reviews of the current plan. This change also mirrors the approach promoted through Health Care Homes. To claim a GPMP Review practitioners will be required to upload the patient's Shared Health Summary to My Health Record, where a patient has not opted out.
  1. Increase access to care facilitation services for patients.
Three options are proposed for how this measure will operate. A fee-for-service payment; block funding outside of MBS or additional resources funded through PHNs. The block funding outside of MBS e.g. PIP payment, is likely to provide practices with the most flexible and efficient option for delivering facilitation services to their patients.
  1. Activate and engage patients in their own care planning.
This recommendation adopts the philosophy on which the Flinders Care Planning model is based which is also promoted through the HCH trial. It promotes a care planning approach focussed on the patient's goals for their health, rather than the approach where the focus is often driven by the paperwork required to access MBS rebated allied health services.
  1. Rebate participation in case conferencing for non-GP health professionals.
Finally, the recognition the allied health practitioners deserve for their contribution to case conferences. This measure will removed one of the distinct barriers that currently limits the the opportunity for case conferencing.
  1. Build the evidence base for Health Assessments and ensure that the content of Health assessments conforms to appropriate clinical practice guidelines.
  1. Delete Health Assessments less than 30 minutes and expand the at-risk groups who are eligible for Health Assessments.
Setting a minimum timeframe for Health Assessments is aiming to promote a high quality service. This measure will affect the GPs who do their own assessments and regularly claim item 701 which will be deleted from the schedule. This change is expected to promote the involvement of practice nurses in the process of completing a Health Assessment.
  1. Link Medication Management Reviews (MMRs) to GPMPs and reduce the schedule fee.
This measure is aiming to bundle care associated with the GPMP and aligns with the bundled care approach. Practices that utilise a lot of medication reviews will need to consider the impact once the adjusted rebate is known and incorporate the work into the GPMP process to make the GP's time more efficient.
  1. Increase the rebate for home visits for patients with a GPMP.
Linking HMR's & higher valued home visits to GPMPs is attempting to facilitate proactive, continuity of care for patients with chronic conditions. Another move towards a bundled service model of care.
  1. Introduce a 6 minute minimum time for a Level B consultation item.
Practices that regularly claim Level B rebates for consultancies lasting less than 6 minutes will need to reconsider their billing model.
  1. Introduce a new Level E consultation item at 60 minutes or more.
This item will be based on the same $ per minute value as a Level D consult. Shorter consultations (Level B&C) will still deliver better value for a GP's time.
  1. Increase access to primary health care in Residential Aged Care Facilities (RACF).
This recommendation has already been implemented in the 1 March 2019 Medicare update. It includes a call out fee of $55 for GPs attending RACFs. Any benefits of these changes may however be lost when the Aged Care PIP payment ceases on 1 May 2019 as part of the conversion to a Quality Improvement Incentive Payment.

Summary of Key Messages

  1. The alignment of MBS with Health Care Homes for patients with chronic diseases signals an ongoing commitment to MBS reform and the likely transition in time from the fee-for-service to a bundled payment model.
  2. The voluntary registration of patients for the management of their chronic condition will help to quarantine claiming for the higher value care planning services to the patient's nominated practice.
  3. The changes to GPMPs & deletion of TCAs will reduce administration and facilitate the bundling of care with other services such as health assessments, home visits and home medication reviews.
  4. The minimum time limit on GPMPs and deletion of the brief Health Assessment item aims to promote a higher quality intervention and reduce the incidence of high throughput care planning services.


Are you a high performing practice or on the path to becoming one?

In our experience working with medical practices there are a number of key financial drivers which we have identified as being integral in both becoming a high performing practice and continuing to operate as a high performing practice.  


Income maximisation is a key focus of all high performing practices.

A practice should be:

  • Reviewing revenue streams.
  • Have a fee setting policy in place with consideration toward managing bulk billing rates and the potential to provide high value services to patients.
  • Ensure that all Practice Incentive Payments are being maximised and received.

Cost Management

Prudent expense management is vital in improving the financial performance of a practice. High performing practices review overhead costs regularly to identify outliers and confirm reasonableness. In addition, the practice manager should negotiate with suppliers to ensure that the best possible value is received.

Financial Reporting

Similar to all successful businesses, prudent and proactive financial control allows a practice to be agile in responding to issues or industry movements and efficient in service delivery. Financial reporting, we recommend on a monthly basis, allows the finance team to report to Principals on the financial performance and position of the practice. In addition to profit and loss and balance sheet analysis, typically management report templates include key performance indicators (KPIs) and budgeting.

Key Performance Indicators (KPIs)

KPIs can be either financial or non-financial. Particularly relevant to medical practices, these often have an operational focus to help determine if the business is operating within industry benchmarks or comparatively improving on prior years. Examples of operational KPIs include:

  • Numbers of Administrative staff / Practitioners
  • Attendances per day
  • Number of new patients
  • Active patients
  • Patient wait time
  • Bulk billing rates


Budgeting is also important for medical practices as it establishes the financial result Principals desire and provides a framework against which monitor performance to ensure financial objectives are achieved.

It is important that KPIs and the budget are carefully established with consideration to the Practice's strategy. This will ensure that reports provide valuable insights and assist management in executing their strategy and achieving their financial objectives.

Risk Management

Risk management is an area that needs to be reviewed at least annually. Ensuring that the appropriate level of insurance is in place is vital to mitigate exposure to any event which would compromise the operation and performance of the practice. Insurance cover we commonly see in the industry is:

  • Medical Indemnity
  • Practice Medical Indemnity
  • Property & Contents
  • Business Interruption
  • Public Liability
  • Cyber

Practice agreements should also be reviewed to ensure that they appropriately deal with unforeseen injury or accident of a principal. Furthermore, from a tax compliance perspective, service fees should be reviewed to ensure that arrangements are compliant with the Australian Taxation Office guidelines.


Are you considering opening a Satellite Clinic?

Here are some areas to consider when assessing the viability of a satellite clinic:


  • What is your business strategy and goals for this additional site?
  • Will the clinic have the same purpose and functions as the main practice? Some practices use the second site for specific clinics rather than duplicating the functions of the primary site. E.g. chronic disease management services, or skin clinics and procedures.


  • Which practitioners will work in the clinic? A rotation of providers across sites can cause confusion for clients.
  • What additional support staff are required at the site?
  • How will you back-fill resources when they are on leave?
  • Will providers be satisfied with working in a clinic with less resources available? E.g. if they are use to having access to a practice nurse and the satellite clinic does not have any nursing resources.
  • Appointment Book

    • Does your practice management software (PMS) support branch practices?
    • Does the PMS provide reports by branch.
    • How will you to set up in the appointment book?

    Information Technology

    • How will the clinic connect to the main practice to access the PMS and patient database?
    • Does it require duplication of some essential and expensive equipment such as vaccine fridge, ECG and Spirometry?
    • Will the phone system be integrated via a VPN?
    • An instant messaging product is a really useful communication tool.


    • Have you considered the accreditation requirements?
      For GP practices, the satellite clinic will require accreditation in its own right.


    • How will you manage the culture across your sites?
      Over time, cultural differences can develop between sites and teams. 


    Borrowing in Self-Managed Super Funds for Health Professionals

    Despite speculation that the Royal Commission into the Financial Services Industry may see a ban on SMSF borrowing, the recommendations released on Monday 4th February 2019 made no mention of any changes to current SMSF borrowing arrangements. 

    The Australian Labor Party has previously communicated its position to "restore the general ban on direct borrowing by superannuation funds" and if polling is an indicator, they are likely to win the upcoming election and form Government. The current Coalition Government has no plans to restrict SMSF borrowing at this stage. 

    If there is a change in Government and a ban on SMSF borrowings is implemented, it is important to note that SMSFs with existing borrowings would not be impacted (based on our understanding of Labor's position), just that new borrowings would not be allowed. Labor have made no announcement of their intention to unwind existing arrangements, and for many reasons we do not believe this is likely.

    Many of the major banks, including the Big 4 and Macquarie, are removing many of their SMSF lending products, particularly around residential property purchases. 

    For Health Professionals however, especially where seeking to purchase business premises, we are finding many banks are still able to support an SMSF borrowing application.

    We have been involved in several transactions with clients borrowing within their SMSF that have resulted in successful outcomes. We have worked with many of the Health focused financiers in recent times on these transactions and can assist in making an introduction if required. 

    If you believe a SMSF borrowing strategy is something that you would like to pursue, we recommend you get appropriate advice from your accountant, SMSF adviser and/or financial planner to discuss further and determine whether this approach is suitable. If it is suitable, it is important that all parties work with you to ensure the borrowing arrangement is established and structured both correctly and effectively.


    AAPM National Conference

    The 2019 AAPM National Conference (40th Anniversary) will once again be filled with a range of dynamic and inspirational speakers, workshops and its social events. The conference is being held at the Brisbane Convention and Exhibition Centre, QLD. The theme this year is "Waves of Change." held from 1-4th October 2019. We hope to see you there!


    Shali Manolev, Partner

    We would like to acknowledge the recent appointment of Shali Manolev, Partner to the Board of Orana.

    Orana was formed in 1950 by a small group of progressive and visionary parents who were seeking educational and training opportunities for their children with intellectual disabilities who previously had been denied access to such opportunities.

    Shali has over 15 years of experience in the health industry, and has the knowledge and understanding that will make her a valuable inclusion to the Board.


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