Understanding telehealth MBS items is critical for GPs who want to bill correctly, avoid Medicare compliance issues, and maximise revenue from virtual consultations. Since the permanent inclusion of telehealth in the Medicare Benefits Schedule, the billing rules have stabilised, but many GPs still struggle with item selection, patient eligibility, and documentation requirements.
HCPA, as Regulatory Growth Consultants for healthcare providers across Australia, helps GP practices structure their telehealth billing processes for compliance and revenue optimisation. This guide covers the key telehealth MBS item numbers, eligibility criteria, billing rules, and documentation standards that every GP practice needs to understand.
Telehealth MBS Item Categories for GPs
Video Consultation Items
Video consultations attract higher MBS rebates than phone-only consultations, reflecting the additional clinical value of visual assessment. The primary video consultation items for GPs mirror their in-person equivalents in terms of consultation duration and complexity requirements.
Key video items include Level A (brief), Level B (standard), Level C (long), and Level D (prolonged) consultations. The clinical documentation requirements for each level are identical to face-to-face consultations. You must record the clinical content, duration, and complexity that justifies the item level billed. GPs who default to Level B for every video consultation often leave revenue on the table when consultations genuinely meet Level C or Level D criteria.
Phone Consultation Items
Phone-only consultations have separate MBS item numbers with lower rebate values than video equivalents. These items apply when the patient cannot access video technology or when the clinical situation does not require visual assessment. Common scenarios include medication reviews, pathology results discussions, and follow-up calls for stable chronic conditions.
Medicare restricts phone consultations more tightly than video consultations. The existing relationship requirement applies, and there are limits on the proportion of phone-only consultations a GP can bill relative to their total consultation volume. Practices with a high ratio of phone to video or in-person consultations may trigger Medicare audit flags.
Patient Eligibility Requirements
The Existing Relationship Rule
To claim telehealth MBS items, the patient must have an existing clinical relationship with the practice. This generally means the patient has attended the practice for a face-to-face consultation within the preceding 24 months. The relationship is with the practice, not necessarily the specific GP, so any GP at your clinic can conduct a telehealth consultation with a patient who has seen another GP at the same practice.
Exceptions to the existing relationship rule exist for patients in certain geographic areas (such as rural and remote locations with limited GP access), patients of Aboriginal Community Controlled Health Services, and specific vulnerable populations. Check the current MBS Online guidelines for the full list of exceptions, as these are updated periodically.
Consent and Record-Keeping
Every telehealth consultation requires documented patient consent that covers the nature of the telehealth consultation, its limitations compared to face-to-face assessment, privacy and data security measures, and the circumstances under which an in-person follow-up may be required. Record consent in the patient file and refresh it periodically, particularly if the patient’s clinical circumstances change.
Bulk Billing Rules for Telehealth
Telehealth consultations can be bulk billed under the same rules as face-to-face consultations. The Bulk Billing Incentive Payment applies to eligible telehealth items, providing an additional payment for practices that bulk bill concession card holders and children under 16. This incentive makes bulk billed telehealth financially viable even at lower per-consultation rebates.
Practices that mixed bill should apply the same gap fee structure to telehealth as to face-to-face consultations, unless a deliberate pricing strategy differentiates the two. Some practices choose to bulk bill telehealth to attract patient volume and reserve gap fees for in-person consultations. For a comprehensive look at billing models, see our guide on bulk billing setup and revenue optimisation.
Chronic Disease Management via Telehealth
GP Management Plans (GPMPs) and Team Care Arrangements (TCAs) can be initiated and reviewed via telehealth under specific conditions. The initial GPMP consultation benefits from video format, as it allows the GP to visually assess the patient’s environment and functional capacity. Reviews and TCA coordination can often be completed effectively via phone.
These items carry significantly higher MBS rebates than standard consultations and represent a major revenue opportunity for telehealth practices. A GP who identifies eligible chronic disease patients and systematically initiates GPMPs and TCAs via telehealth can generate $150 to $300 per patient in additional annual revenue beyond standard consultation items. Understanding GP clinic profitability levers helps you quantify the impact of chronic disease management on your bottom line.
Documentation and Audit Compliance
Medicare actively audits telehealth billing patterns. Every telehealth consultation must be documented with the mode of delivery (video or phone), clinical content of the consultation, time spent (particularly for longer items), the MBS item selected and the rationale for that item level, patient consent confirmation, and any follow-up actions or referrals.
Common audit triggers include unusually high volumes of phone-only consultations, consistently billing long consultation items (Level C or D) without supporting documentation, billing telehealth items for patients who do not meet the existing relationship requirement, and billing patterns that differ significantly from peer benchmarks. Implementing standardised templates within your practice management software ensures consistent documentation without adding clinical time.
For practices building or expanding telehealth services, structuring your billing and documentation processes correctly from the start prevents compliance issues. Our guide on the telehealth business model covers the broader operational framework, while understanding your Medicare provider number obligations ensures your claiming credentials are in order.
Frequently Asked Questions
Can I bulk bill telehealth consultations?
Yes. Telehealth consultations can be bulk billed under the same rules as face-to-face appointments. The Bulk Billing Incentive Payment also applies to eligible telehealth items for concession card holders and children under 16.
Do patients need to have visited the practice in person first?
In most cases, yes. The existing relationship rule requires patients to have attended the practice for a face-to-face consultation within the preceding 24 months. Exceptions apply for patients in certain geographic areas and specific vulnerable populations.
Are video consultations paid more than phone consultations?
Yes. Video consultation MBS items attract higher rebates than phone-only items for the same consultation level. Video is also subject to fewer billing restrictions, making it the preferred modality for both revenue and compliance purposes.
Need help structuring your telehealth billing for compliance and revenue growth? Talk with our consultants for tailored guidance on telehealth MBS billing within your practice.
