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Telehealth Billing and Compliance: Understanding the Nuances for Australian GPs

18 December 2023 - A/Prof Stephen Barnett

Building on our introduction to telehealth billing compliance, this blog post delves into the differentiation between telephone consultations and what constitutes telehealth under Australian legislation. As we continue to adapt to the ever-evolving landscape of digital healthcare, it is imperative for General Practitioners to be well-versed in the details that ensure compliance and optimal patient care.

Telehealth encompasses both telephone (audio-only) and video consultations, each with its own set of item numbers. While they may both fall under the broad category of telehealth, it is crucial for billing purposes to distinguish between the two. A telephone consultation is exactly that—an audio link between you and the patient. However, for a consultation to qualify under video item numbers, it must maintain both a visual and an audio link throughout the duration of the call.

In both scenarios, the service provided must be clinically appropriate and capable of being delivered safely via the chosen medium. As practitioners, the onus is on us to select platforms that meet the necessary security and privacy requirements. While there has been no definitive list from the Department of Health, platforms like Zoom and FaceTime are generally accepted, assuming they are encrypted and recognized for their security.

There has been an ongoing debate regarding the use of telephone consultations. While there was an initial push for video consultations during the early stages of COVID-19, the acceptance of telephone as a viable option has grown, recognizing its accessibility and convenience.

For specialists, there has been a significant shift, with longer telephone consultations being discontinued as of June 30th. GPs should be aware that each telehealth item has a face-to-face equivalent, and the same requirements for item numbers apply in both settings.

The nuances of billing, such as the differentiation between a brief, straightforward consultation (91890) and a more involved one (91891), are vital to grasp. These distinctions highlight the importance of clinical judgement and documentation in determining the level of service provided.

Compliance is not just about time spent with the patient; it is about the complexity of the task and the quality of care. The clinical standards of consultation must be met and documented, whether it is a telephone or video link. This includes taking a clinically relevant history, performing an examination, managing the condition, and providing preventive health advice.

Documentation is paramount. The adage "if it wasn't documented, it didn't happen" holds true in the realm of billing compliance. Templates and shortcuts need to be used very carefully. If templates are used, they should be seen as prompts, with individualised information recorded against each prompt. This has been one of the compliance traps which we will talk about later, in which practitioners’ notes all look the same across a range of patients. 

As we move forward, changes continue to align telehealth with traditional consultations. For instance, from November 1, 2023, all Level B consultations have a minimum time requirement of six minutes, further harmonising telephone item numbers with face-to-face encounters.

Join us for our next article, where we'll explore the latest item numbers and incentives, ensuring your practice remains compliant, safe and sustainable.

Mastering Medical Billing

To access more resources including webinars, blog posts, learning activities and more, visit the Mastering Medical Billing hub. 


A/Prof Stephen Barnett
A/Prof Stephen Barnett

Stephen is a GP Supervisor, Medical Educator, GP academic and Medical Director of Medcast. He has completed a PhD on Virtual Communities of Practice in GP Training.

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