Report on the 2010 review of the Medicare provider number legislation

Chapter Four - Operation of Section 3GA

Page last updated: 15 November 2012

Section 3GA of the Act permits medical practitioners who are subject to s19AA to provide professional services that attract Medicare benefits through placements on approved workforce or training programs. Workforce and training programs operate in different contexts and as such these two programs face different issues, which need to be treated differently from a policy and funding perspective.

This chapter describes s3GA of the Act and issues relevant to both workforce and training programs. In particular, administration processes and updating of regulations. The following two chapters describe the findings for workforce and training programs separately.

4.1 Section 3GA: A suite of workforce and training initiatives to ensure Australian communities have access to quality medical services

Section 3GA of the Act works to ensure that only doctors who are enrolled in a training course or program specified in Schedule 5 of the Regulations can provide services for which a Medicare benefit is payable.

To ensure that all communities in Australia have access to quality medical services, a number of training and workforce programs funded by State and Territory or Commonwealth governments exist. Doctors without vocational qualifications, or who are in the process of becoming vocationally qualified, can be part of these programs and thereby access Medicare rebates for their work.

The programs are a mix of workforce and training initiatives, and some are a combination of the two. Training programs are delivered by AMC approved providers and represent most of the vocational training opportunities available for doctors in Australia. Doctors may be on concurrent, multiple 3GA placements - for example, enrolled in a specified training placement and also accessing rebates under a workforce program.

At 30 October 2010, there are 11 training and workforce programs listed under Schedule 5 of the Regulations (see Table 4.1). There have been several changes to the training and workforce programs since the last review in 2005.

  • RVTS is an independent training provider and was added to Schedule 5 Part 2 Specified bodies and programs in 2007.
  • Approved Placements for Sports Physicians Program ceased on the 31 October 2010 when Sports Medicine was recognised as a speciality. The Sports Physicians Trainees are listed under Schedule 5 Part 2 Specified bodies and programs.
  • PGPPP has been expanded and has replaced the Rural and Remote Area Placement Program.
  • The Metropolitan Workforce Support Program has ceased.
  • The Assistance at Operations is an obsolete program.

Table 4.1: Number of providers of at least one service for s3GA Programs by year of service between 2004 and 2010(a) (No. of providers made claims (b))

Approved Medical Deputising Program
Approved Private Emergency Department Program
Approved Placements for Sports Physicians Program (discontinued) (h)
Sports Physician Trainees Program
Metropolitan Workforce Support Program (discontinued)
Prevocational General Practice Placement Program
Queensland Country Relieving Doctors Program
Rural Locum Relief Program
Special Approved Placement Program
Temporary Resident Other Medical Practitioner Program (i)
Remote Vocational Training Program Trainees Program
Australian General Practice Training Program
2318 (j)
RACGP Training Program (k)
Specialist College Trainee Program (l)
Rural and Remote Area Placements Program(discontinued)
Assistance at Operations (discontinued)

(Note statistics not strictly based on financial year)

a. Source: Department of Health and Ageing
b. To be counted, providers had to have claimed for at least one service on a valid date for the program in question
c. Statistics for 2004-05 and 2005-06 had regard to claims processed up to the end of October 2006
d. Statistics for 2006-07 had regard to claims processed up to the end of October 2007
e. Statistics for 2007-08 had regard to claims processed up to the end of September 2008
f. Statistics for 2008-09 had regard to claims processed up to the end of October 2009
g. Statistics for 2009-10 had regard to claims processed up to the end of August 2010
h. Based on advice from Medicare Australia, providers on program 187 were only counted if they had an end date of 30 June 2011 and they had a valid date for this program. Medicare Australia uses code 187 for 3GA and non-3GA providers
i. The TROMP Program (198) and the Approved Placements for Sports Physician Trainees Program (187) were not location specific
j. Source: GPET-2318 registrars currently; 1037 on rural pathway and 674 of these on 10 year moratorium
k replaced by the Australian General Practice Training Program
l not currently in list of Approved Placements Programs

4.2 Administration processes for allocating provider numbers need streamlining

Previous reviews have recommended that approval processes for provider numbers be improved. Although some improvements to the efficiency of administration processes to issuing Medicare provider numbers have been made in the last five years, these processes remain a common and continuing source of frustration.  8  Potential consequences of inefficient provider number approval processes are: delays in doctors commencing new training or workforce positions; disruptions to service provision; and reduced mobility of the medical workforce.

Stakeholders said that the processes for administering applications are inefficient and impose an unnecessary administrative burden on practice management. In some cases, the complexity and length of the application process also discourages practices and non-traditional providers of medical services from taking on trainees. In particular, the requirement that doctors have a separate provider number for all their work locations is seen as an unnecessary and inefficient way to organise the system. Another problem is that doctors on certain placements need to get new provider numbers if their placement is extended.

The actual application process is also complicated. For example, registrars on the AGPT program need new provider numbers when their placements are extended or changed. To apply for the new provider number, registrars must complete two forms: one is sent to the Regional Training Provider (who submits the form to Medicare) and the other is sent directly to Medicare. On some occasions there are delays in allocating provider numbers because only one form has been received. Registrars report that this is a cumbersome and confusing process.

In addition, the application requirements are the same no matter what the type of placement or risk level. For example, placement in a general practice requires the same level of information and paperwork as placement in a hospital setting. GPET, who manage this training program, considers that the level of information required should be commensurate with the level of risk for the placement.

A related concern is that it takes longer to process applications for a doctor subject to s19AB than it does for other applications. The review understands that DoHA and Medicare Australia implemented a more streamlined process for s19AB exemptions in June 2010, which has proved successful. The statutory processing time for these exemptions is 28 days. GPET indicated that there are eight steps in the application process for provider numbers for registrars on the AGPT program who are subject to s19AB, and processing these applications takes an estimated 60 days (eight weeks).

Stakeholders also reported that it is difficult to get timely advice about administrative requirements for allocating provider numbers. The program area in DoHA that processes requests for s19AB exemptions require any queries to be submitted in writing and do not offer any way of contacting officers by telephone. Industry stakeholders report that the email enquiry system is an inefficient way of sorting out issues and getting questions answered in a timely manner.

There are specific administrative requirements for certain programs. Table 4.2 summarises the way stakeholders believe these requirements should be changed to ensure a more streamlined way of applying for provider numbers.

Currently, DoHA makes policy decisions about provider number processes, which Medicare Australia follows. Medicare Australia has indicated that it would be technically possible to streamline information requirements for personal and professional information based on doctors being known to Medicare Australia. There are new communication and information sharing arrangements between AHPRA and Medicare Australia, but at this stage these have not affected the provider number application processes.

Table 4.2: Stakeholder suggestions for streamlining program specific requirements for provider number applications

Administrative requirementSuggested change
New provider number for every practice locationIssue each medical practitioner with one provider number, which can be combined with an identifying code number for each practice location, with the two numbers working in tandem to identify the practitioner and the location at which the service was provided.
Processing s19AB exemptionsAllow these to be processed while doctors are offshore to improve timeliness of processing.

Allow GPET to approve exemptions for AGPT program applicants as part of placement approval process.
Applying for s3GA provider numbers on the AGPT programAGPT program registrars complete and submit one application form whilst on the program. The form is specific to the program and the information carries them through work on multiple placements.
APEDP trainees must re-apply for a provider number every yearRequire one application for the four years of advanced emergency training.

4.3 New programs for Schedule 5 of the Regulations

Only one new program for Schedule 5 was formally put up for consideration as part of the review - the ACRRM Independent Pathway. The ACRRM Independent Pathway program is a fully accredited general practice training pathway that has been independently assessed by the AMC as equivalent to other general practice vocational training programs. There are currently 35 registrars on this program.

Under current arrangements, ACRRM Independent Pathway registrars are treated differently to doctors on other vocational training programs. Registrars on the program are less recognised and face significant barriers in securing training posts and negotiating the same terms and conditions as their peers. Because the Independent Pathway is not a recognised s3GA program, registrars must deal with multiple agencies to get approvals (practice, college, workforce agency, Medicare and sometimes DoHA), which causes delays in completing training and obtaining Fellowship.

These registrars also have difficulty accessing Medicare provider numbers. They must negotiate access to Medicare provider numbers under a s3GA program, usually the RLRP. For doctors working in some larger centres, it might not be possible to access a provider number through a workforce program.

One issue, which was not widely canvassed but was raised by a stakeholder in the context of a request for an additional program to be listed under Schedule 5, is access to Medicare benefits by Career Medical Officers (CMOs)  9  in specific contexts. CMOs work in hospitals under the supervision of specialists (Fellows of a specialist college) and are outside s19AA. These doctors meet a need for medical workforce in public hospitals. One stakeholder is seeking access to provider numbers for CMOs who treat privately insured public hospital in-patients  10 , so long as the hospital maintains accreditation with the Australian Council on Healthcare Standards and each medical officer fulfils continuing professional development requirements that satisfy AHPRA.

One other related issue is the process for getting new programs onto Schedule 5, which stakeholders report is ‘convoluted, tedious and slow’.

4.4 Changes needed to Schedule 5 of the Regulations

Schedule 5 lists specified organisations and courses for s3GA programs. The review identified areas where it appears that Schedule 5 of the Regulations need updating.

Part 1—Specified bodies and qualifications needs updating as it does not include Fellowships of:

  • Royal Australian College of General Practitioners
  • Australian College of Rural and Remote Medicine
  • the Australasian College of Sports Physicians
  • the College of Intensive Care Medicine of Australia and New Zealand.

Schedule 5 Part 2-Specified bodies and programs needs updating to remove references to programs that have been discontinued, namely

  • the Rural and Remote Area Placements Program
  • the Metropolitan Workforce Support Program
  • the Assistance at Operations program.

References to RACGP and ACRRM as the specified bodies for PGPPP should also be removed as the program is now managed by GPET.

Further, consideration should be given to updating Schedule 5 as and when colleges and course are accredited by the AMC.

4.5 2010 recommendations for administration of section 3GA programs

Recommendation 6

6.1: DoHA to update Schedule 5 Pt 2 of the Regulations to remove references to s3GA programs that have been discontinued; namely, the Rural and Remote Area Placements Program; the Metropolitan Workforce Support Program; the Assistance at Operations program.

6.2: DoHA to routinely update the Regulations when the status of s3GA programs change.

Recommendation 7

DoHA to remove reference to RACGP and ACRRM as specified bodies for PGPPP as the program is now managed by GPET Limited.

Recommendation 8

DoHA (or relevant authority) to revise all s3GA workforce and training program guidelines to acknowledge the role of AHPRA in setting conditions for clinical practice and supervision requirements, and monitoring these conditions and requirements.

Recommendation 9

DoHA (or relevant authority) to revise relevant s3GA workforce and training program guidelines to ensure that both the RACGP and ACRRM are referred to as providers of general practice training, and to ensure that where the guidelines refer to Fellowship of RACGP, they also reference the Fellowship of ACRRM.

Recommendation 10

DoHA and Medicare Australia to reduce red-tape involved in applying for provider numbers not only for doctors on s3GA workforce and training programs but across the whole sector; and to improve information services about application processes for the sector.

10.1: By 2012, DoHA to allow one application for each doctor on a s3GA workforce or training program to cover all practice locations and for the entire time they are on the program.

10.2: By 2014, Medicare Australia to issue one provider number to each medical practitioner and an identifying code number to each practice location, with the two numbers working in tandem to identify the practitioner and the location at which the service was provided.

10.3: By 2012, Medicare Australia to automatically renew provider numbers for doctors working for AMDSs when the Deeds of Agreement are renewed.

10.4: Relevant parts of the Government to improve information services so that specialist colleges, doctors, practice managers and others can get queries about the allocation of provider numbers answered in-person and in a timely way.

8 For example, the timing of Deeds of Agreement for AMDSs
9 Career Medical Offices is NSW terminology
10 These cases are not supposed to be paid by public hospitals but rather by third party insurers who receive premiums from their members but refuse to pay claims from medical providers not registered for Medicare benefits.