New approach to Medicare paperwork burden

Medicare paperwork can be really fraught. We feel that of course compliance matters and Medicare audits are to be taken seriously, but that there is also a balancing act between the needs of the client, clinician and the GP, all of which are time and cost sensitive and all with varying levels of understanding of the MBS system. In fact, in a recent internal audit we found that 31% of GP referrals received would be classed as “invalid” in the event of a Medicare audit.

We see our role as trying to be efficient and effective, to guard you from poor outcomes in the event of a Medicare audit, and also to look after your relationship with your GPs and of course to help your client access the rebates they are entitled to.  So, as an example, what should you do when you get handed an Enhanced Primary Care plan “referral”, with no patient address and no mention of the authorised sessions count accompanying a 2 page MHCP plan, with DASS results? What do you do when GP’s don’t respond to repeated written communication and verbal requests to fix their paperwork over a number of weeks? This nightmare scenario is a real situation but is not uncommon.


Suggested approach

Here is our suggested best practice solution for dealing with such “nightmare” scenarios and how we approach our paperwork management to achieve a sensible balance that still protects you in the event of a Medicare audit.

  • We try to resolve paperwork issues before the first appointment, but if the client is expecting a rebate on the first day then we need at least a reasonable attempt at a referral.
    • If for instance we are only given a MHCP plan with no referral we will ask the client for additional paperwork and if they don’t have it we will email / fax the GP and request the referral for the same date as the care plan but we will not rebate the session until we have it. We will not take responsibility for following up the GP or calling if they don’t respond however – that is ultimately the client’s responsibility.
    • If there is some reasonable but not entirely valid paperwork, for instance they have skipped the session count or got the sequence of the annual limits out of step or they are missing the Medicare scheme name, then we will prepare a fax for you to send to the GP stating your reasonable assumptions. This gives up coverage from a Medicare audit and is inline with recent guidance from AskMBS and ACPA.  Our default wording is:

Dear {ReferrerFirstName},

Re: {ClientFullName}, DOB: {ClientDOB}
{ClientMedicareNumber} {ClientMedicareIRN}
{ClientAddress}, {ClientSuburb}

I hope you are well and thank you for your referral under a Mental Health Care Plan, dated {ReferralStartDate}.

Earlier this year Medicare advised our professional association that psychologists can use our clinical judgement when there are minor issues with referrals such as missing session counts or referrals out of sequence with the various annual limits. Your referral is for ### Insert wording ###.

According to our records, {ClientPreferredName} is eligible for ### Choose 1
6 sessions under the Better Access scheme.
a further 4 sessions under the Better Access scheme.
a further 10 sessions under the Covid Response scheme.
a further 10 sessions under the Eating Disorder scheme.
### In my judgement a full course of treatment is warranted and unless we hear back from you we will proceed with a full allocation of these sessions {he/she} is entitled to and report back on progress following these sessions. Please do let me know if you would like to vary this number of sessions or if you would like to discuss this further.

For further information about the requirements and suggested compliant wording see the QR code article and example wording overleaf.

Kind Regards,



  • Whenever we get a reasonable attempt at the referral we will also setup the session pack for your price level and the referral type and session limits.




  1. ACPA: Communication from Department of Health – Referrals under the Better Access Initiative
  2. APS: InSight Feb 2021: Keeping up-to-date with Medicare requirements
  3. Dept of Health: Guideline for substantiating that a valid Allied Mental Health service has been provided.
  4. Dept of Health (MBS Associated Notes MN.7.1) 


Last updated 29 Nov 2021

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