Medicare Provider Number Application Guide Australian General Practice Training Programme Semester 1, 2016
Purpose This document explains how the Department of Health (Health) and the Department of Human Services Medicare (DHS) will process Australian General Practice Training Programme (AGPTP) Placements from 1 November 2015. This document: 1. explains how the Medicare eligibility requirements apply to GP Registrars; 2. explains the Medicare provider number application process for the AGPTP; 3. defines the responsibilities of each of the parties involved in making AGPTP placements and assessing related Medicare provider number applications; 4. confirms the handling strategy for processing AGPTP applications for semester 1, 2016 onwards; and 5. provides contacts in Health and DHS for further advice regarding the Medicare legislation and the AGPTP placement process It is suggested that you read this document in tandem with the AGPTP Handbook, which explains the training pathways that are currently offered under the AGPTP. The AGPTP and the Medicare provider number restrictions Medicare restrictions apply to doctors, including Registrars and other trainees, under sections 19AA and 19AB of the Health Insurance Act 1973 (the HIA). These restrictions apply to all doctors once they are registered with the Medical Board of Australia. All GP Registrars who were first registered in Australia on or after 1 November 1996 are subject to Medicare restrictions under S19AA of the HIA. S19AA compels doctors to obtain vocational qualifications as a GP, a specialist or a consultant physician to qualify for Medicare access. S19AA also provides that a doctor may be granted access to Medicare benefits if they are working towards vocational qualifications in their specialty through a training programme that is recognised for Medicare purposes. The AGPTP is a recognised general practice training programme and therefore allows participant GP Registrars to apply for provider number to access a Medicare benefit while they work towards Fellowship of either the Royal Australian College of General Practitioners (FRACGP) or the Australian College of Rural and Remote Medicine (FACRRM). Some GP Registrars are also subject to the restrictions under S19AB depending on where they obtained their primary medical degree (equivalent of the Bachelor of Medicine/Bachelor of Surgery qualification). These are Registrars who meet the definition of: an overseas trained doctor (OTD) a doctor who obtained their primary medical degree outside of Australia or New Zealand; or a foreign graduate of an accredited medical school (FGAMS) a doctor who was not a citizen or permanent resident of Australia or New Zealand on the day they enrolled to do their medical degree at a medical school in either country. AGPTP Medicare Provider Number Application Guide 2
S19AB has a workforce distribution objective and establishes a broad requirement for OTDs and FGAMS to practise in a recognised district of workforce shortage (DWS) to qualify for Medicare rebates. This requirement is generally called the ten year moratorium because it applies for a minimum of ten years from when the doctor is first registered in Australia. OTDs and FGAMS are not restricted from applying to join the AGPTP. However, when considering the AGPTP against the S19AB restrictions, Health considers that: the general pathway does not satisfy the workforce distribution intent of S19AB and is therefore generally not available to OTDs and FGAMS; and the rural pathway satisfies workforce distribution intent of S19AB and is available to OTDs and FGAMS once they are approved to join the AGPTP. Health does not apply DWS to OTDs and FGAMS who meet the rural pathway requirement. Registrars who meet the definition of an OTD or FGAMS can be granted a S19AB exemption (access to a Medicare benefit) for any rural pathway placement, even if it is in a non-dws area. GP Registrars and Medicare eligibility requirements A GP Registrar requires a Medicare provider number to perform the following functions while undertaking their training placement: claim Medicare rebates for their services or have rebates claimed on their behalf by their employer; refer their patients to other specialists through the Medicare system; and request services on behalf of their patients. A Medicare provider number does not allow a GP Registrar to prescribe medicines. They will need a separate prescriber number to perform this function. A prescriber number is issued at the same time as a Medicare provider number. Alternatively, a GP Registrar can apply for a prescriber number only. When applying the provider number application process, Health and DHS split GP Registrars into two groups based on whether they are subject to the S19AB Medicare restrictions (i.e. registrars with S19AB restrictions and registrars who are not subject to S19AB). GP Registrars who are subject to S19AB are assessed according to: the restrictions that apply to their eligibility to train on the general pathway; and their requirement under S19AB to have an exemption and their eligibility to gain a Medicare provider number to access a Medicare benefit. It is imperative that the AGPTP placement documentation correctly identifies all Registrars who are subject to the S19AB restrictions to ensure these assessments are applied consistently. When applying the S19AB restrictions, Health splits AGPTP placements into three categories general pathway, rural pathway and extended skills. It is imperative that the completed request for AGPTP placement correctly identify the requested placement as belonging to either the rural or general pathway and whether the placement has an extended skills purpose. The below table summarises how S19AB is applied to registrars according to the requested training placements. AGPTP Medicare Provider Number Application Guide 3
Table: S19AB Restrictions and GP Registrars General Pathway Rural Pathway Extended Skills Registrar (Not S19AB) Eligible Eligible Eligible Registrar (S19AB) Not Eligible (unless prior approval)* Eligible Eligible (after S19AB assessment by Health) * the process for 19AB Registrars to seek approval from Health so that they may be assessed for placements under the general pathway is explained on page 5 of this document The AGPTP Medicare provider number application process To participate on the AGPTP, a Registrar requires both an AGPTP placement and a Medicare provider number. From 1 November 2015, the application for an AGPTP Placement will also serve as the Medicare provider number application for Registrars who have previously had a Medicare provider number. (the Registrar will not need to apply separately to DHS for their provider number). The Application for an AGPTP Placement Form (Attachment A) has been revised to provide the information required by DHS to grant a provider number to any Registrar who has previously held a Medicare provider number (either as an intern, hospital medical officer or temporary resident working in general practice). This form allows each Regional Training Organisation (RTO) to submit provider number applications for GP Registrars electronically to Health at: agptmpnapplications@health.gov.au. These applications will then be referred to DHS once the placement is signed into effect. It is important to note that if the Registrar has not previously had a provider number, they will need to make a complete provider number application for their first AGPTP placement to DHS after their placement form has been submitted to Health for assessment. The complete application form is called the Application for an Initial Medicare Provider Number and is available from the DHS website: http://www.humanservices.gov.au/health-professionals/forms/hw019 To ensure the provider number application process can be applied correctly and efficiently, the AGPTP application form requires the RTO to confirm: 1. if the Registrar is subject to the S19AB restrictions; 2. whether the placement belongs to either the general or rural pathway; and 3. (in addition to the pathway) identify if the placement is an extended skills opportunity. These confirmations support changes that have been introduced to shorten the timeframes for issuing provider numbers to Registrars. Specifically, Health has introduced S19AB class exemptions to cover most training placements issued under the rural and the general pathways of the AGPTP. The classes mean that DHS can apply the S19AB exemptions directly to Registrars, once the AGPTP placement form has been signed into effect and forwarded by Health. The effective date of the class exemption will be the date the placement is processed by DHS. AGPTP Medicare Provider Number Application Guide 4
Health will be responsible for applying S19AB to restricted Registrars who are undertaking extended skills placements, which are not covered by the class exemptions. Health will apply the S19AB restrictions for these placements as part of a separate process due to their unique nature. A map of the provider number application process as it will apply to most GP Registrars under the AGPTP is provided at Attachment B. S19AB Registrars and the general pathway As per the advice provided above, Registrars who are subject to S19AB are generally restricted from training under the general pathway of the AGPTP. However, Health does allow S19AB restricted doctors to seek discretionary approval to apply for the general pathway in their state or territory. These applications are made separately to the Medicare provider number application process, and generally before the doctor has even applied to join the AGPTP and been accepted as a Registrar. Health will continue to administer this separate application process and provide decisions in writing to assist the RTOs in assessing applications from doctors seeking to join the AGPTP. The Medicare provider number application process for the AGPTP does not affect this separate application process or provide any special eligibility to S19AB doctor to train under the general pathway. Further information regarding the general pathway restrictions is provided in the AGPTP Handbook 2016. 2016 Semester 1 applications The revised AGPTP placement form and application process will apply to all AGPTP applications from 1 November 2015. Any AGPTP placement that was submitted prior to this date will be assessed according to the information that was provided as part of the original application and the provider number process that was in place at the time of the application. RTOs do not need to re-submit any prior application for Semester 1, 2016 to account for the information that is provided in this document. Registrars who had training placements submitted prior to 1 November 2015, will be required to make a separate Medicare provider number application to ensure they have access to a Medicare benefit for their placement. When can a Registrar bill Medicare for their services? Submission of a completed AGPTP placement form to Health does not mean that the Registrar is eligible to claim Medicare benefits for their services. Health and DHS must assess the Registrar against the Medicare eligibility requirements and confirm in writing the Medicare provider number and access to a Medicare benefit before the Registrar can claim rebates. The HIA generally prohibits Health and DHS from backdating Medicare access for Registrars, meaning rebates cannot be paid for services that are provided before this confirmation is received. Accordingly, a Registrar must wait until DHS has granted them a Medicare provider number and confirmed access to a Medicare benefit for their training practice(s) before attempting to provide Medicare-subsidised services as part of their general practice training. AGPTP Medicare Provider Number Application Guide 5
When to use the Medicare provider number application portion of the AGPTP placement form The Medicare provider number application portion (2 nd page) of the AGPTP placement form should be completed for: all Registrars who have an existing Medicare provider number and require an additional provider number for a new training practice; and Registrars who are subject to S19AB and who are obtaining a new placement for their training practice (e.g. changing training semesters but staying with the same practice). This section does not need to be completed for: Registrars who are not subject to S19AB and staying with the same practice (DHS can extend their Medicare access based on the training placement information); or Any Registrar who has not held a Medicare provider number before their first AGPTP training placement. When their AGPTP Placement Form is submitted to Health, the Registrar must apply directly to DHS by completing an Application for an Initial Medicare Provider Number Form : http://www.humanservices.gov.au/health-professionals/forms/hw019 Tips for completing the Application for an AGPTP Placement Form When completing the application form: fill in all fields that are marked mandatory; ensure the name of the Registrar matches their current registration with the Medical Board of Australia; ensure you correctly identify the Registrar s status in regards to S19AB (either subject/notsubject) for all placements; identify the placement as belonging to either the rural or the general pathway; identify if the placement is an extended skills placement (in addition to rural or general pathway); ensure you have a placement form for each location the Registrar will be working; provide the name and code of the RTO as selected through the 2015 AGPT approach to market. NOTE: If you are unable to provide an existing Medicare provider number for the Registrar, the Registrar must apply to DHS by completing an Application for an Initial Medicare Provider Number Form: http://www.humanservices.gov.au/health-professionals/forms/hw019. When requesting a placement on behalf of the Registrar, the RTO must advise Health that the Registrar has applied separately for an MPN to DHS (i.e. reason for the second page of the placement request being left blank). Contacts: Submission of placement forms: agptmpnapplications@health.gov.au Queries about the operation of S19AB: 19AB@health.gov.au Queries about Medicare: 132 150 AGPTP Medicare Provider Number Application Guide 6