Patient receives a Medicare-rebated telehealth consultation
Telehealth removed distance from the consultation and left two things in place: a rule that the patient must already have a relationship with the practice, and eight sets of state law governing what can be prescribed at the end of it.
longest dependent chain
across 2 bodies
scheduling or queue, not assessment
vs. 4 if run end-to-end
Where the time goes
Critical-path days only. Steps that run alongside others are real work but do not lengthen the process, so counting them here would overstate the prize.
| third party | 3d | Waiting on an external body outside the regulator's control. | |
|---|---|---|---|
| assessment | 1d | Someone is genuinely evaluating the merits. |
The process, step by step
Applies when: A patient seeks a telehealth consultation attracting a Medicare benefit.
| # | Step | Who | Why it waits | Clock | Typical | Basis |
|---|---|---|---|---|---|---|
| 1 |
Establish an eligible telehealth practitioner relationship
registration
A face-to-face MBS service with the same practitioner or practice in the preceding 12 months, or registration with the practice under MyMedicare. |
Department of Health, Disability and Ageing | assessment | — | 0 published | Health Insurance Act 1973 (Cth) and the Medicare Benefits Schedule |
| 2 |
Register with the practice under MyMedicare
registration
only if triggered Voluntary patient registration with a general practice, which satisfies the relationship requirement and unlocks additional incentives. Triggered when: The patient has no qualifying face-to-face service in the preceding 12 months and registers instead.
|
Department of Health, Disability and Ageing | applicant | — | 30 published | — |
| 3 |
Book and attend the consultation
application
after
Establish an eligible telehealth practitioner relationship 1d slack
|
— | third party | — | 3 estimate | — |
| 4 |
The consultation
assessment
A real-time video or telephone consultation. after
Book and attend the consultation 1d slack
|
— | assessment | — | 0 estimate | — |
| 5 |
Medicare benefit claimed
fee
after
The consultation
|
Department of Health, Disability and Ageing | assessment | — | 1 published | — |
| 6 |
Prescribe, where the medicine is controlled
decision
only if triggered Schedule 8 prescribing is governed by the law of the patient's state, including permits, real-time monitoring checks and restrictions on new patients. Triggered when: The consultation results in a prescription for a Schedule 8 controlled medicine. after
The consultation
|
State medicines and poisons regulator | assessment | — | 14 estimate | — |
on the critical path scheduling/queue = delay not caused by the assessment itself
Proposed changes
-
Exempt prison health services from the Medicare exclusion
remove
~60d Section 19(2) of the Health Insurance Act keeps people in custody outside Medicare and the PBS. It was written to prevent double-dipping between governments. Its effect on prisons is that continuity of care breaks at both ends, for the population that uses health care most.
-
One consultation, four jurisdictions, and no clear answer about whose law applies
merge
~14d The practitioner is registered nationally. The medicine is regulated by the state. In a telehealth consultation the doctor, the platform, the patient and the dispensing pharmacy can be in four different jurisdictions, and published guidance acknowledges it is complex and confusing to know which law applies.
-
Telehealth is least available to people without a regular doctor
threshold
Medicare-rebated telehealth requires a face-to-face visit with the practice in the last 12 months, or MyMedicare registration. About one in ten patients has registered, and about one in three has heard of it. The exemption from a relationship requirement is itself an opt-in relationship.
Sources
- Department of Health, AskMBS advisory on eligible telehealth practitioner requirements, updated 1 November 2025 — previously the established clinical relationship requirement
- From 1 November 2025, MyMedicare-registered patients are exempt from the 12 month face-to-face requirement, and the triple bulk billing incentive for longer telehealth consultations extended to all Medicare-eligible patients registered through MyMedicare
- 23 new MBS telehealth items from 1 July 2025 (18 video, 5 telephone), primarily for GP Chronic Condition Management Plans
- MyMedicare: more than 2.6 million patients registered as at 19 March 2025, about one in ten patients, with about one third of Medicare card holders aware of the scheme
- State and territory Schedule 8 prescribing requirements, including permits, real-time prescription monitoring and restrictions on prescribing to new patients by telehealth
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