Telehealth is least available to people without a regular doctor
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.
Steps this would change
Rationale
The requirement is a continuity of care protection and this proposal does not argue against its purpose. Telehealth was made permanent on the understanding that it would supplement a relationship with a regular doctor rather than replace it with a stranger who has never examined the patient and will not follow them up. That is a real clinical concern and it was the right thing to protect.
Its distributional effect is the problem. A patient qualifies if they have had a face-to-face MBS service with the same practitioner or practice in the preceding 12 months — so telehealth is least available to people without a regular GP. That is disproportionately people who move often, work irregular hours, are new to an area, are young, or live where bulk-billing practices have closed. The barrier is highest where the need is greatest.
The fix chosen was MyMedicare, and the take-up figures are the finding. From 1 November 2025, registration satisfies the requirement. More than 2.6 million patients had registered as at March 2025 — about one in ten. About one third of Medicare card holders were aware the scheme existed. Of those who registered, 78.2 per cent found it easy.
Easy, and unknown. The barrier is not friction; it is awareness. A voluntary registration that most people have never heard of reaches patients already engaged with a practice and misses the ones who are not — who are precisely the population the exemption exists to help.
This is now the fourth instance of the same pattern in this database, after the energy rebate, the embedded network application and the VET FEE-HELP remedy: an opt-in route reaches the people who needed it least.
Two changes that do not touch the clinical objective:
- Register by default at the next face-to-face visit, with the patient able to decline — turning an awareness problem into a conversation the practice is already having.
- Extend the exemption list to cohorts where the relationship requirement predictably fails rather than protects: people who have recently moved, people in areas without an accepting practice, and people leaving custody or institutional care.
Who acts: the Commonwealth alone, through the Medicare Benefits Schedule and MyMedicare settings.
What is being traded away
Default registration weakens what registration is supposed to mean. MyMedicare is meant to signal a genuine ongoing relationship, and a patient auto-registered at a single visit they may never repeat is not in one. Since registration also unlocks funding and incentives to the practice, defaulting it creates a financial interest for practices in registering patients who are not really theirs. That is a straightforward integrity problem and it would need to be designed against.
The continuity concern is clinically real and it is not evenly distributed either. The patients most likely to be harmed by a telehealth-only relationship — no examination, no records, no follow-up — overlap substantially with the patients this proposal would let in. Widening access and protecting continuity pull in opposite directions here, and anyone claiming otherwise is not being straight about it. The honest framing is that this is a trade, and that the current setting has chosen one side of it.
Exemption lists grow and are hard to administer. Every added cohort needs a definition, evidence, and a practitioner able to apply it at the point of billing. "Recently moved" is not a fact a practice can verify. A rule that is unverifiable in practice becomes either unused or a compliance risk for the doctor, and MBS compliance risk sits with the practitioner personally.
And this changes no elapsed time at all. The process itself models at four days and zero per cent addressable — once a patient is eligible, telehealth is fast and works. The entire finding is about who gets through the gate, which is a coverage question wearing a process costume.
Precedent
Targeted exemptions already exist and work: patients under 12 months of age, people experiencing homelessness, blood-borne virus and sexual and reproductive health services, and natural disaster provisions. The mechanism for exempting a defined group is established.
Sources
- Department of Health, AskMBS advisory on eligible telehealth practitioner requirements, updated 1 November 2025
- MyMedicare: more than 2.6 million patients registered as at 19 March 2025, about one in ten patients; about one third of Medicare card holders aware of the scheme; 78.2 per cent of users found registration easy
- Published exemptions including patients under 12 months of age, people experiencing homelessness, blood-borne virus and sexual and reproductive health services, and natural disaster provisions