MIGA has over recent months received many queries from members and clients concerned about whether they are covered for claims arising from telehealth consultations, which have increased significantly during the COVID-19 pandemic.

Telehealth is essentially the use of digital technologies to provide health care services and is a well-recognised way of providing care in a wide variety of situations which can include consultations via a wide range of video platforms and telephone.

MIGA’s insurance policies do not stipulate how care must be provided, e.g. there is no requirement that it must by via a physical face-to-face consultation.

If you are confident that a reliable, secure telehealth system will allow you to provide the same level of care and advice as you can in a face-to-face consultation with a patient, and you have appropriate arrangements to see the patient face-to-face if necessary, telehealth is an appropriate alternative approach to face-to-face consultations. You must ensure your healthcare is provided appropriately, in accordance with any applicable published guidelines, within the scope of practice cover, and within the terms of your insurance.

In providing telehealth services there are a few things members and clients should note:

  1. What type of telecommunication solution can be used?
    The only requirements are that telecommunication solutions support clinical requirements and also satisfy privacy laws. AHPRA and the National Boards advise that telehealth services can be provided through telephone and video calling apps and software platforms such as Skype, FaceTime etc, however, they caution that non-commercial free versions of many applications may not meet applicable laws for security and privacy. For further information refer to the Privacy Checklist for Telehealth Services
  2. How are telehealth services charged?
    For the purposes of cover it doesn’t matter how the telehealth service is billed whether via professional fee or Medicare. But if billed via Medicare, please note that Medicare has introduced hundreds of telehealth items during the COVID-19 pandemic.These items extend to all Medicare eligible Australians, so long as the requirements for individual item numbers are met and the practitioner and their patient are in Australia.We have received several enquiries where the practitioner is outside Australia. It is important to understand that in these situations Medicare telehealth items cannot be used, however, the practitioner is free to charge professional fees for such services
  3. Do Medicare have any specific requirements?
    Yes – in determining whether telehealth is deemed appropriate Medicare requires the practitioner to:
  • have the capacity to provide the full service: this means safely and in accordance with professional standards
  • be satisfied that it is clinically appropriate to provide the service to the patient
  • maintain a visual and audio link (or audio only for telephone) with the patient
  • be satisfied that the software and hardware used to deliver the service meets the applicable laws for security and privacy
  • only use telephone if video cannot be used

Online chat, messaging and email cannot be used for Medicare telehealth items.

From 20 July 2020, GPs will only be able to claim COVID-19 telehealth items if they, or a doctor at the same practice, have seen the patient for a face-to-face consultation in the last 12 months.

We have also received enquiries from practitioners as to whether practitioners’ Medicare provider numbers can be used to bill telehealth consultations undertaken by other practitioners in the same practice.

A Medicare provider number can only be used by the practitioner for telehealth consultations undertaken by the practitioner. The practitioner is solely responsible for meeting Medicare billing requirements for an item billed using their provider number.

If incorrectly or inappropriately billed for services provided by another, the practitioner would be responsible for meeting any repayment to Medicare, and could also face Medicare restrictions or professional disciplinary action.

MIGA provides a significant amount of key information, including in relation to telehealth, to support our members and clients about our response to the challenges posed by the COVID-19 Pandemic. Please visit our coronavirus webpage for further information.

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