Report on the 2010 review of the Medicare provider number legislation

Executive summary

Page last updated: 15 November 2012

The 2010 Review of the Medicare Provider Number Legislation was done to meet the requirement of s19AD (1) of the Health Insurance Act 1973 (the Act).

The independent review was completed under contract to the Australian Government Department of Health and Ageing (DoHA) by ARTD Consultants in October and November 2010.

Industry stakeholders provided feedback about the legislation during one-to-one interviews or group meetings (65 participants); formal submissions (six organisations) or by completing a semi-structured electronic submission form (37 responses). Two stakeholder forums were also held: one at the start of the consultation period (29 October 2010) to ensure all relevant issues were being covered; and another on the 30 November 2010, to discuss the preliminary findings and the practicality of the recommendations.

Key findings


The review found that s19AA is well accepted by the medical profession. As in other specialist areas, vocationally trained medical practitioners are now seen as the norm in general practice. Section 3GA workforce and training programs assist with placing doctors in areas where it is difficult to attract doctors. At least 2,000 doctors a year are providing medical services in areas where it is difficult to attract doctors under s3GA placements.

But the review also found that general practice stakeholders hold differing views as to whether the Medicare Provider Number Legislation is achieving the right balance between workforce supply and quality care provision in rural areas. A related issue is the adequacy of resources and support for non-vocationally recognised general practitioners (GPs), many of whom are overseas trained doctors (OTDs) on workforce programs, to achieve vocational recognition. The sector also has differing views about the right way to recognise the skills and experiences of the estimated 600 experienced non-vocationally recognised general practitioners who graduated prior to 1996.

Another substantive finding is that implementing s19AA in conjunction with other related Medicare Provider Number Legislation is complex for Government officers, specialist colleges and practitioners alike. The review found there is a need to harmonise legislation in order to address anomalies of access to provider numbers that impact on the ability of registered doctors to practice and earn an income.

One continuing issue for industry is that the administration processes and requirements for allocating provider numbers are inefficient and place an unnecessary burden on medical practitioners. A medical practitioner is required to have a provider number that is specific for each practice location, meaning that a doctor who works across several locations needs several provider numbers. This is inefficient, delays service provision and works against the intent of the National Registration and Accreditation Scheme, which is to promote a more flexible and responsive workforce.

The review also identified parts of the Health Insurance Regulations 1975 (the Regulations) that need updating to reflect changes in accreditation of training courses, specialist colleges, and where s3GA programs are defunct. In particular, the review found that the Australian College of Remote and Rural Medicine (ACRRM) Independent Pathway should be added to the Regulations as an approved program.

Many program stakeholders identified operational issues that should be addressed as a matter of course rather than waiting for the next legislative review or for DoHA to initiate a formal review of program guidelines.

Status of 2005 Biennial Review Recommendations

Just over half of the recommendations from the 2005 Biennial Review have been fully implemented with four recommendations being superseded over the five years since the last Review. The seven recommendations not yet fully implemented address issues that are still current. In most instances there is little information to explain why the recommendations were not actioned. The seven recommendations not yet implemented are listed below.

  • Recommendation 1: Provide one more opportunity for doctors who meet the necessary criteria to be grandfathered onto the Vocational Register.
  • Recommendation 3.3: Consider further investment to support the quality and training aspects of the Rural Locum Relief Program (RLRP); Approved Medical Deputising Service (AMDS) Program and other s3GA workforce programs because of their value in providing quality care to rural areas.
  • Recommendation 5.3: Specifically, implement a staged program that over time will lead to ensuring that all medical practitioners participating in the RLRP for an extended period of time (e.g. more than 12 months) receive the appropriate assessment and training to achieve Fellowship of a recognised specialist college.
  • Recommendation 6.2: The Divisions of General Practice and local Medical Deputising Service (MDSs) are to develop closer cooperation to promote coordination between general practice and MDSs with a particular emphasis on participation of MDSs in Division Aged Care GP Panels to assist in providing after-hours services to residential aged care facilities and the possible use of MDSs in providing in-hours care to these facilities.
  • Recommendation 8: General Practice Education and Training Limited (GPET), the Australian Medical Council (AMC) and the relevant medical colleges to review the entry criteria for the Australian General Practice Training (AGPT) Program to enable OTDs with suitable qualifications (other than passing the Australia Medical College exam) and experience to enter the Program.
  • Recommendations 10.1 and 10.2: The Australian Government to establish a review committee who will call for and respond to submissions on the problems and possible solutions associated with applications for provider numbers and Approved Placement Programs.

Findings for Workforce Programs

Since the 2005 Biennial Review, there have been major changes to systems for setting and managing clinical standards and assessing doctors’ competencies in Australia. In July 2010, a national registration system managed by the Australian Health Practitioner Regulation Agency (AHPRA) commenced. Before this, a national assessment process was established in 2006. Together, these measures have addressed major issues raised by the 2005 Biennial Review regarding inconsistencies in assessment of qualifications and in the setting of conditions of registration and practice for doctors working on workforce programs.

AHPRA (through the Australian Medical Board) now sets conditions of practice and supervision requirements for all doctors. However, there remains uncertainty about the extent doctors are able to access the required level of supervision and the capacity of private practices to provide that supervision, particularly in general practice in rural areas.

Guidelines for workforce programs have been revised and sections relating to quality processes have been strengthened. For most workforce programs, doctors must now be working towards gaining vocational qualifications. The program guidelines also now stipulate that doctors on workforce placements must receive adequate mentoring and supervision.

Despite the changes to program guidelines, mentoring and support for doctors training on workforce programs is underfunded and inconsistent across programs. There needs to be more investment in training placements and support for non-vocationally recognised doctors to ensure they provide high quality services.

The current review identified specific issues related to individual workforce programs, which are described in the report.

Findings for Training Programs

Training programs are generally operating effectively. The sector has welcomed the recent increases in training places and funding for these, and the programs that promote expansion of training into private hospitals and other non-traditional settings. But the increasing number of medical graduates highlights the need for good data that will allow accurate monitoring of the demand for, and capacity of, specific sectors to provide training positions. General practice stakeholders are concerned that training positions (prevocational and vocational) will fall well short of requirements unless more teaching sites are recruited or larger numbers of trainees are placed at each site.

The review found that two specialist training programs that allow registrars to access Medicare rebates in private and/or community settings appear to have low uptake, in part because of a lack of clarity about how and when Medicare rebates can be claimed.

The review also identified specific issues related to individual training programs, which are described in the report.

Findings for the Medical Training Review Panel (MTRP)

The MTRP is monitoring the supply of medical training opportunities, although more needs to be done to monitor demand.

Stakeholders value the monitoring data on medical training published by the Panel and want the statutory role of MTRP to continue. There is also general support for the MTRP and Health Workforce Australia (HWA) to have formal links around medical training.

The current membership of the MTRP is appropriate. Three stakeholders expressed interest in becoming members of the Panel on the grounds that they have an interest in and involvement with training and workforce programs. These are the Remote Vocational Training Scheme Ltd (RVTS), the National Association of Medical Deputising Services (NAMDS) and Rural Health Workforce Australia (RHWA).