PSR Director's update for December 2025

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A. Section 92 agreements effective in December 2025

Eight agreements entered into by the Director or an Associate Director and persons under review (under section 92 of the Act) came into effect in December 2025:

Psychologist

During the review period, when compared to their peers the practitioner rendered the largest number of services as MBS item 82365 (eating disorder psychological treatment lasting at least 50 minutes) and the third largest number of services as MBS item 91184 (focused psychological strategies phone attendance lasting at least 50 minutes). 

The Director reviewed this practitioner’s rendering of MBS item 82365 and 91184 services. The Director had persisting concerns that:

  • the MBS requirements were not always met, including that the practitioner billed MBS item 82365 or 91184 services when the patient was absent despite both services requiring personal attendance by the practitioner on the patient, and the minimum time requirement of 50 minutes was not always met
  • the clinical indication for each service was not always clear, particularly when there were frequent attendances in close succession
  • the practitioner did not keep adequate and contemporaneous records, as records were often brief, incomplete, duplicative or out of sequence. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 82365 and 91184. The practitioner agreed to: 

  • repay $165,000 to the Commonwealth
  • be counselled by the Director
  • be disqualified from providing MBS item 82365 services for 12 months. 

Radiologist (diagnostic radiology)

During the review period, the practitioner rendered the largest number of services as MBS item 55850 (musculoskeletal ultrasound) in Australia. The Director reviewed this practitioner’s rendering of MBS item 55054 (ultrasonic cross-sectional echography), 55850 and 57341 (computed tomography in conjunction with a surgical procedure) services. 

The Director had no concerns in relation to MBS item 57341 services but had persisting concerns that:

  • the practitioner billed MBS item 55054 incorrectly due to a systemic billing error by the practice
  • the practitioner co‑billed other items with MBS item 55054 and 55850 services, including items excluded by the MBS item 55054 and 55850 descriptors.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 55054 and 55850. The practitioner agreed to repay $30,000 to the Commonwealth and to be counselled by the Director. 

General practitioner

During the review period, the practitioner rendered or initiated the following MBS item services in excess of 99% of their peers:

  • 36 (attendance lasting at least 20 minutes)
  • 723 (coordination of team care arrangements (TCAs))
  • 66596 (iron studies)

The Associate Director reviewed this practitioner’s rendering of a prescribed pattern of services (rendering of 80 or more relevant services on each of 20 or more days in a 12‑month period), and rendering or initiating of the following MBS items: 

  • 23 (attendance lasting between 6 and 20 minutes)
  • 36
  • 721 (preparation of a GP management plan (GPMP))
  • 723
  • 66596
  • 90035 (attendance at a residential aged care facility (RACF) of at least 6 minutes and less than 20 minutes)
  • 90043 (attendance at a RACF of at least 20 minutes)
  • 91891 (phone attendance lasting at least 6 minutes)

The Associate Director had persisting concerns that:

  • the practitioner rendered 80 or more relevant services on each of 27 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
  • the practitioner’s record keeping was inadequate, including that there was not always a separate entry for each service, and records were often brief and non‑contemporaneous with some records updated after PSR had issued notices to produce
  • the MBS requirements were not always met, including the minimum time requirements
  • the practitioner’s clinical input was not always adequate
  • the practitioner’s initiating of MBS item 66596 services was not always clinically relevant.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 23, 36, 721, 723, 66596, 90035, 90043 and 91891 services and in providing services that constituted a prescribed pattern of services. The practitioner agreed to: 

  • repay $590,000 to the Commonwealth
  • be disqualified from providing MBS item 36, 965 (preparation of a GP chronic condition management plan), 90043, 91800 (telehealth attendance lasting at least 6 minutes and less than 20 minutes), 91801 (telehealth attendance lasting at least 20 minutes), 91891, 91900 (phone attendance of at least 20 minutes for a MyMedicare patient) and 92029 (video attendance to prepare a GP chronic condition management plan) services for 12 months
  • be reprimanded by the Associate Director. 

General practitioner

During the review period, the practitioner rendered the following MBS items in excess of 99% of their peers:

  • 731 (GP contribution to a multidisciplinary care plan)
  • 5028 (attendance at a RACF lasting between 6 and 20 minutes)
  • 90035
  • 90043
  • 90051 (attendance at a RACF lasting at least 40 minutes)

The Associate Director reviewed this practitioner’s rendering of MBS item 731, 5028, 90035, 90043, 90051 and 91891 services, and prescribing of PBS items 13333R (methadone hydrochloride 5 mg/mL) and 8865N (buprenorphine 5 microgram/hour patch). 

The Associate Director had no concerns in relation to MBS item 731, 5028 and 90035 services, and the practitioner’s prescribing of PBS items 13333R and 8865N, but had persisting concerns that:

  • the practitioner’s record keeping was not always adequate, including where records failed to include sufficient clinical information to enable another practitioner to take over the patient’s ongoing care in reliance on the record
  • the MBS requirements were not always met, including that the practitioner did not attend to the patient by phone when billing MBS item 91891, and they did not always meet minimum time requirements
  • the practitioner’s clinical input was not always adequate, including that they did not always provide adequate management plans.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 90043, 90051 and 91891 services. The practitioner agreed to repay $35,000 to the Commonwealth. 

Medical practitioner

During the review period, the practitioner rendered the fifth highest volume of MBS item 723 services, the sixth highest volume of MBS item 721 services and the seventh highest volume of MBS item 2715 services (preparation of a GP mental health treatment plan, with a duration of at least 20 minutes but less than 40 minutes) compared to all practitioners in Australia. 

The Director reviewed this practitioner’s rendering of MBS item:

  • 23
  • 703 (attendance to prepare a standard health assessment lasting more than 30 minutes and less than 45 minutes)
  • 715 (health assessment for an Aboriginal or Torres Strait Islander patient)
  • 721
  • 723
  • 732 (review of a GPMP or TCAs)
  • 31360, 31362, 31364, 31366 and 31368 as a class of non‑malignant skin lesion excision items
  • 31361, 31363, 31365 and 31367 as a class of malignant skin lesion excision items
  • 91891

services, and the practitioner’s rendering of a prescribed pattern of services (rendering of 80 or more relevant services on each of 20 or more days in a 12-month period). 

The Director had persisting concerns that:

  • the practitioner rendered 80 or more relevant services on each of 41 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
  • the practitioner’s record keeping was inadequate as records were often brief and did not include relevant clinical input to explain the service
  • the MBS requirements were not always met, including that the practitioner did not always undertake all clinically relevant tasks, the minimum time requirements were not met, and some services did not appear to be clinically relevant
  • the practitioner often co-billed MBS services where it was not clear that each service was clinically necessary
  • the practitioner occasionally rendered therapeutic procedures without appropriate management or without clinical indication. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 23, 703, 715, 721, 723, 732, 31360, 31361, 31362, 31363, 31364, 31365, 31366, 31367, 31368 and 91891 services and in providing services that constituted a prescribed pattern of services. The practitioner agreed to: 

  • repay $600,000 to the Commonwealth
  • be disqualified from providing MBS item 703, 715 and 92004 services for 12 months
  • be counselled by the Director
  • be reprimanded by the Director. 

General practitioner

During the review period, the practitioner rendered the following MBS item services in excess of 99% of their peers:

  • 36
  • 5040 (afterhours attendance lasting at least 20 minutes)
  • 91801
  • 92024 (telehealth attendance for preparation of GPMP)
  • 92025 (telehealth attendance to coordinate the development of TCAs)

The practitioner was the highest renderer of MBS item 36 services and ranked fourth for rendering of MBS item 91801 services compared to all practitioners in Australia.

The Associate Director reviewed this practitioner’s rendering of MBS items 23, 36, 44 (attendance lasting at least 40 minutes), 721, 723, 732, 5040, 91801, 91891, 92024, 92025 and 92028 (telehealth attendance to review GPMP or TCAs). The Associate Director had persisting concerns that:

  • the practitioner’s record keeping was often inadequate and the records lacked sufficient details to explain what occurred during the service
  • the MBS requirements were not always met, including the minimum time requirements
  • the GPMPs were often not comprehensive written plans as required, and the consultations did not always relate to the management of chronic health conditions
  • the practitioner billed for TCAs when they did not attend the patient and there was not always two‑way communication with other health care providers.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 23, 36, 44, 721, 723, 732, 5040, 91801, 91891, 92024, 92025 and 92028 services. The practitioner agreed to:

  • repay $530,000 to the Commonwealth
  • be disqualified from providing MBS item 965, 967 (review of a GP chronic condition management plan), 92029 and 92030 (video attendance to review a GP chronic condition management plan) services for 12 months
  • be reprimanded by the Associate Director. 

General practitioner

During the review period, the practitioner rendered the following MBS item services in excess of 99% of their peers: 

  • 2712 (review of a GP mental health treatment plan)
  • 91891
  • 92126 (phone attendance to review a GP mental health treatment plan)

The Associate Director reviewed this practitioner’s rendering of MBS items 23, 2712, 91891 and 92126, and their rendering of a prescribed pattern of services (rendering of 30 or more relevant phone services on 20 or more days in a 12‑month period). The Associate Director had persisting concerns that:

  • the practitioner rendered 30 or more relevant phone services on each of 25 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
  • the practitioner’s record keeping was inadequate as records were often brief and did not include sufficient clinical input to explain what occurred during the service
  • the MBS requirements for MBS item 23 and 91891 services were not always met, including the minimum time requirements, and relevant clinical examinations or appropriate management plans were not always performed or provided
  • relevant elements of a GP mental health treatment plan were not always adequately reviewed.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 23, 2712, 91891 and 92126 services and in providing services that constituted a prescribed pattern of services. The practitioner agreed to repay $86,000 to the Commonwealth and to be counselled by the Associate Director. 

General practitioner

During the review period, the practitioner rendered the following MBS item services in excess of 99% of their peers:

  • 5203 (afterhours attendance lasting between 5 and 25 minutes)
  • 91893 (phone attendance lasting at least 6 minutes)

The Associate Director reviewed this practitioner’s rendering of MBS item 5020, 5203, 91891 and 91893 services and their rendering of a prescribed pattern of services (rendering of 30 or more relevant phone services on 20 or more days in a 12‑month period). The Associate Director had no persisting concerns in relation to MBS item 5203 services but had persisting concerns that:

  • the practitioner rendered 30 or more relevant phone services on each of 29 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
  • the MBS requirements were not always met, including minimum time requirements and for MBS item 5020 services it did not always appear that the service was rendered in the relevant afterhours period
  • the practitioner’s record keeping was inadequate because if the practitioner had met the MBS requirements, the clinical notes were very brief and did not adequately explain the service. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 5020, 91891 and 91893 services and in providing services that constituted a prescribed pattern of services. The practitioner agreed to repay $35,000, and will be reprimanded by the Associate Director. 

B. No further action decisions

There were no decisions under section 91 to take no further action in December 2025.

C. PSR Committee final determinations

There were no final determinations that took effect in December 2025. 

D. Federal Court decisions

There were no Federal Court decisions handed down in December 2025. 

E. Referrals to the major non-compliance (fraud) division (89A & 106N)

There were no matters were referred to the major non-compliance (fraud) division in December 2025.

F. Referrals to Ahpra (106XA/B)

One matter was referred to Ahpra in December 2025.

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