PSR Director's update for July 2025

Published date

20 August 2025

A. Section 92 agreements effective in July 2025

Twelve agreements entered into by the Director or an Associate Director and persons under review (under s 92 of the Act) came into effect in July 2025:

General practitioner

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

707 (prolonged health assessment lasting at least 60 minutes)
721 (preparation of a GP management plan (GPMP))
723 (coordination of team care arrangements (TCAs))
732 (review of a GPMP or TCAs)
900 (participation in a domiciliary medication management review)
2712 (review of a GP mental health treatment plan (GPMHTP))
2715 (attendance to prepare a GPMHTP, lasting 20 to less than 40 minutes)
2717 (attendance to prepare a GPMHTP, lasting at least 40 minutes)

An Associate Director reviewed this practitioner’s rendering of MBS item 707, 721, 723, 732, 900, 2712, 2715 and 2717 services. The Associate Director had the following persisting concerns:

The MBS requirements were not always met, including where the practitioner did not provide sufficient clinical input to justify the service billed. In relation to MBS items 721, 2715 and 2717, the records did not always reflect that the patient had a chronic disease or mental health condition. The practitioner may have regularly billed chronic disease management (CDM) items on a day proximate to a day on which they billed a standard professional attendance item where they only attended the patient once to avoid co‑billing restrictions.
The practitioner did not always satisfy the definition of the patient’s usual GP for the purposes of the Health Insurance (General Medication Services Table) Regulations 2021 when rendering MBS item 707 services. The practitioner may not have always attended on the patient when billing MBS item 707 because of the lack of detail in progress notes.
In some cases, the practitioner’s clinical input was inadequate. They failed to address positive findings when performing health assessments, failed to discuss and arrange treatment options for patients and failed to always ensure they had current relevant measurements when providing CDM services.
The practitioner’s record keeping was inadequate, including that the medical record did not always include progress notes or the required documentation for the billed service.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 707, 721, 723, 732, 900, 2712, 2715 and 2717. The practitioner agreed to:

repay $700,000
be disqualified from providing MBS item 707, items 721, 723 and 732 (and equivalent telehealth items 92024, 92025 and 92028), item 900, and items 2712, 2715, and 2717 (and their equivalent telehealth and phone items 92114, 92116, 92117 and 92126) services for 12 months
be reprimanded by the Associate Director
be counselled by the Associate Director.

Ophthalmologist

During the review period, the practitioner rendered a higher volume of total services than 98% of their peers. The practitioner was in the 99th percentile for rendering the following MBS item services:

104 (specialist attendance – first attendance)
11240 (unidimensional ultrasonic echography or partial coherence interferometry of orbital contents prior to lens surgery)
18240 (retrobulbar or peribulbar injection)
42673 (corneal incisions to correct corneal astigmatism of more than 1½ dioptres)
42702 (lens extraction and insertion of intraocular lens)
42739 (paracentesis of anterior chamber or vitreous cavity for the injection of therapeutic substances, for a patient requiring the administration of anaesthetic by an anaesthetist)
42743 (irrigation of blood from an anterior chamber)

The Director reviewed this practitioner’s rendering of MBS item 104, 11240, 18240, 42673, 42702, 42738 (paracentesis of anterior chamber or vitreous cavity for the injection of therapeutic substances), 42739 and 42788 services, and had no concerns in relation to MBS items 42702. The Director had persisting concerns that:

in relation to MBS items 11240, 1840, 42673, 42738 and 42739, the respective MBS requirements were not always met, and the services were not always clinically indicated or relevant
the practitioner’s record keeping and billing practices were inadequate.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 104, 11240, 18240, 42673, 42738, 42739 and 42788. The practitioner agreed to repay $38,400, to be disqualified from providing MBS item 18240, 42673, 42739 services for 9 months, and to be counselled by the Director.

General practitioner

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

44 (consultation lasting at least 40 minutes)
707
721
723
732
2717
91801 (telehealth attendance lasting at least 20 minutes)
92024 (video attendance to a prepare a GPMP)
92025 (video attendance to coordinate a TCA)
92028 (video attendance to review a GPMP or TCAs)

An Associate Director reviewed this practitioner’s rendering of MBS item 36 (consultation lasting at least 20 minutes), 44, 707, 721, 723, 732, 2717, 91801 and 92028 services. The Associate Director had persisting concerns that:

the MBS requirements were not met for some item 36, 44, 707, 2717 and 91801 services, including minimum time requirements where relevant, and because the practitioner did not always undertake clinically relevant actions
for MBS items 721 and 707, the record did not always reflect that the patient had a chronic condition or was eligible for a health assessment
the practitioner did not always develop a comprehensive written plan or consult with at least 2 other healthcare providers when rendering CDM services
the practitioner’s clinical input was not always adequate because it was not always clear whether they discussed abnormal results with patients, and they did not always ensure they had current relevant measurements when providing CDM services
the practitioner’s record keeping was inadequate, including that their clinical notes were brief and at times confusing, and CDM and mental health treatment plans could not always be found for the date of service.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 36, 44, 707, 721, 723, 732, 2717, 91801 and 92028 services. The practitioner agreed to:

repay $460,000
be disqualified from providing MBS item 721, 723, 732, 2717, 91801, 92024, 92025, 92028, 92117 and 91900 (phone attendance lasting at least 20 minutes) services for 12 months
be disqualified from providing MBS item 44 and 707 (and their telehealth equivalents 91910 and 91802) services for 6 months
be reprimanded by the Associate Director
be counselled by the Associate Director.

General practitioner

During the review period, the practitioner rendered MBS item 705 (long health assessment lasting at least 45 minutes and less than 60 minutes), 721, 723 and 732 services in excess of 99% of their peers.

An Associate Director reviewed this practitioner’s rendering of MBS items 705, 707, 721, 723 and 732, and had persisting concerns that:

the practitioner did not always provide sufficient clinical input, nor meet the minimum time requirements, when rendering MBS items 705 and 707
the practitioner did not always prepare an adequate GPMP or meet the requirements for coordinating TCAs when rendering MBS items 721, 723 and 732.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 705, 707, 721, 723 and 732 services. The practitioner agreed to repay $106,000, and to be disqualified from providing MBS item 723 (and its telehealth equivalent 92025) services for 12 months.

General practitioner

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

585 (consultation during the after-hours period for a patient requiring urgent assessment)
599 (consultation during unsociable hours for a patient requiring urgent assessment)
5028 (consultation at a residential aged care facility (RACF))
5049 (consultation at a RACF lasting at least 20 minutes).

An Associate Director reviewed this practitioner’s rendering of MBS item 36, 585, 5028 and 5049 services. The Associate Director had persisting concerns that:

the MBS requirements were not always met, including where the practitioner did not appear to personally attend on the patient or where minimum time requirements were not met
in relation to services provided as MBS item 585, the consultations did not appear to be requested and performed in the same unbroken after-hours period, and the patient’s condition did not always appear to require urgent assessment
the practitioner’s record keeping was inadequate, including that the records did not contain sufficient clinical information to explain the service.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 36, 585, 5028 and 5049 services. The practitioner agreed to repay $350,000, to be disqualified from providing MBS item 585, 5049, 91801 and 91900 services for 12 months, and to be reprimanded by the Associate Director.

General practitioner

During the review period, the practitioner rendered MBS item 44, 721, 723, 732, and 2713 services in excess in excess of 99% of their peers. An Associate Director reviewed this practitioner’s rendering of MBS items 36, 44, 721, 723, 732 and 2713. The Associate Director had persisting concerns that:

the MBS requirements, including minimum time requirements where relevant and limited to no CDM documentation, were not always met
CDM and mental health services rendered by the practitioner were not always clinically indicated
the practitioner’s clinical input was not always adequate, including that important information about patients’ significant conditions was not maintained
the practitioner’s record keeping was universally inadequate, including that handwritten notes were often illegible and records routinely did not include sufficient information to explain the service.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 36, 44, 721, 723, 732 and 2713 services. The practitioner agreed to:

repay $300,000
be disqualified from providing MBS item 36 (and telehealth equivalents 91801 and 91900) services for 12 months
be disqualified from providing MBS item 44, 721, 732, 723 and 2713 ( and telehealth equivalents 91802, 92024, 92025, 92028, 92115, 92127 and 91910) services for 24 months
be reprimanded by the Associate Director
be counselled by the Associate Director.

General practitioner

During the review period, the practitioner rendered more total services and more services as MBS item 91891 than 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23 and 91891 and had persisting concerns that:

the MBS requirements were not always met, including that the practitioner did not always undertake clinically relevant actions and failed to provide sufficient clinical input to justify a consultation that lasted 6 minutes or more
the practitioner may not have always attended on every patient when there were no progress notes for the date of service
the practitioner’s clinical input when prescribing medications as part of these services was not always adequate, including that it was not always clear that the medications were clinically indicated.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23 and 91891. The practitioner agreed to repay $510,000, to be disqualified from providing MBS item 91891 and 91800 services for 10 months, and to be reprimanded and counselled by the Director.

General practitioner

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

699 (heart health assessment)
721
723
732
11610 (measurement of ankle: brachial indices and arterial waveform analysis)
11707 (twelve-lead electrocardiography, trace only)

An Associate Director reviewed this practitioner’s rendering of MBS item 36, 699, 721, 723, 732 and 11610 services. The Associate Director had persisting concerns that:

the MBS requirements, including minimum time requirements where relevant, were not always met
not all elements of an MBS item 699 service were undertaken and for CDM services, the practitioner did not develop comprehensive written plans or collaborate with at least 2 other healthcare providers
the practitioner co-billed up to 5 other MBS items with MBS item 699 and the MBS requirements for each service were not always met
some MBS item 11610 services provided by the practitioner were not clinically relevant in the absence of pedal pulses being taken or significant risk factors
the practitioner’s record keeping was inadequate.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 36, 699, 721, 723, 732 and 11610. The practitioner agreed to:

repay $200,000
be disqualified from providing MBS item 723 and 92025 services for 12 months
be reprimanded by the Associate Director
be counselled by the Associate Director.

General practitioner

During the review period, the practitioner rendered 90% of consultations as a level D attendance and were at the 99th percentile for rendering the following MBS item services:

44
5060 (after-hours consultation lasting at least 40 minutes)
93716 (phone consultation lasting at least 20 minutes, to determine eligibility for receiving a COVID-19 oral antiviral treatment).

An Associate Director reviewed this practitioner’s rendering of MBS item 36, 44, 5060 and 93716 services. The Associate Director had persisting concerns that:

the MBS requirements, including minimum time requirements, were not always met
the practitioner may not have met the requirements that MBS item 5060 services be rendered in the after-hours period and that MBS item 93716 services be rendered by phone
the practitioner’s clinical input was not always adequate, including when they did not record their clinical reasoning for prescribing medication or a diagnosis for the patient’s complaint.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 36, 44, 5060 and 93716. The practitioner agreed to:

repay $410,000
be disqualified from providing MBS item 44, 5060, 91802 and 91910 services for 12 months
be disqualified from providing MBS item 36, 91801 and 91900 services for 6 months
be reprimanded by the Associate Director.

General practitioner

During the review period, the practitioner rendered services as 24 separate MBS items in excess of 99% of their peers, including the following items:

36
44
31363 (excision of malignant skin lesion – a least 14mm in diameter)
31367 (excision of malignant skin lesion – 15-30mm in diameter)
45201 (muscle, myocutaneous or skin flap to repair a surgical excision made in the removal of a skin lesion).

An Associate Director reviewed this practitioner’s rendering of MBS item 23, 36, 44, 721, 732, 31363, 31367, 45201 and 91891 services. The Associate Director had persisting concerns that:

the practitioner’s record keeping was inadequate, including where the notes did not sufficiently reflect what occurred during a consultation and templates were not always tailored for a patient’s presentation and treatment
the MBS requirements were not always met, including minimum requirements where relevant and documents for CDM services were not comprehensive
the margins excised during skin excision procedures appeared to be larger than necessary and did not always match the histology report
therapeutic procedure items were often co-billed with attendance items without a clear indication that both services were required or performed.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 23, 36, 44, 721, 732, 31363, 31367, 45201 and 91891 services. The practitioner agreed to repay $340,000, to be disqualified from providing MBS item 721, 732, 92024 and 92028 services for 12 months, and to be reprimanded and counselled by the Associate Director.

General practitioner

During the review period, the practitioner rendered more total services to more total patients than 99% of their peers. They also rendered the following MBS item services and prescribed the following PBS items in excess of 99% of their peers:

23
5020
56507 (computed tomography scan of upper abdomen and pelvis)
1215Y (paracetamol 500 mg + codeine phosphate hemihydrate 30 mg tablet, 20)
3162K (diazepam 5 mg tablet, 50)

An Associate Director reviewed this practitioner’s rendering of MBS item 23, 5020 and 56507 services, and prescribing of PBS items 1215Y and 3162K. The Associate Director had persisting concerns that:

the MBS requirements were not always met, including minimum time requirements where relevant
the practitioner did not always provide adequate clinical input or provide adequate clinical management for patients to whom they prescribed medications on an ongoing basis
MBS item 56507 was not always clinically indicated
the PBS restrictions were not always complied with
the practitioner’s record keeping was inadequate.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23, 5020 and 56507 and prescribing PBS items 1215Y and 3162K. The practitioner agreed to repay $110,000 and to be reprimanded and counselled by the Associate Director.

Psychiatrist

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

306 (attendance by a psychiatrist, lasting more than 45 minutes but not more than 75 minutes – if applicable attendances have not exceeded 50 in a calendar year)
316 (attendance by a psychiatrist, lasting more than 45 minutes but not more than 75 minutes – if applicable attendances have exceeded 50 in a calendar year)
318 (attendance by a psychiatrist, lasting more than 75 minutes – if applicable attendances have exceeded 50 in a calendar year)
328 (attendance by a psychiatrist in a hospital, lasting more than 75 minutes)
91831 (video attendance by a consultant physician lasting at least 75 minutes - if applicable attendances have not exceeded 50 in a calendar year)
92459 (telehealth attendance by a consultant physician, involving an interview lasting at least 45 minutes of a person other than the patient, in the course of initial diagnostic evaluation of a patient)

The Director reviewed this practitioner’s rendering of MBS item 306, 316, 328, 91831 and 92459 services. The Director had persisting concerns that:

the practitioner’s record keeping was inadequate
the MBS requirements, including minimum time requirements, were not always met
the practitioner appeared to bill MBS item 92459 outside of ‘the course of initial diagnostic evaluation of a patient’ as required, or when the interview did not relate directly to the treatment of one of the practitioner’s patients
the volume and frequency at which extended consultation services were rendered were inappropriate.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 306, 316, 328, 91831 and 92459 services. The practitioner agreed to repay $103,500 and to be counselled by the Director.

B. No further action decisions

General practitioner

The practitioner was referred to PSR because it appeared they had rendered a prescribed pattern of services, namely that they had rendered 30 or more relevant phone services on 22 or more days during a 12‑month period.

After conducting their review, an Associate Director formed the view that no further action was required as there were insufficient grounds on which a Committee could reasonably find that the practitioner engaged in inappropriate practice during the review period. The Associate Director considered that a Committee would likely find that there were exceptional circumstances affecting the rendering of the phone services on each of the 22 days. This was because of the nature of the practitioner’s medical condition and the loss of another general practitioner from a practice where most of the phone services were provided.

C. PSR Committee final determinations

PSR Committee 1614

A final determination regarding PSR Committee 1614 came into effect in July 2025. Details about this final determination will be published at a later date.

PSR Committee 1621

Details of the final determination in PSR Committee were published in the April case outcomes. The April case outcomes have been updated to reflect the Director’s decision to name the practitioner.

PSR Committee 1525

On 27 June 2025 a final determination came into effect regarding Dr Karynne Finniear. In the final report of the PSR Committee, the practitioner was found to have engaged in inappropriate practice in connection with MBS items 44, 2713, 5067 (after hours attendance at a residential aged care facility – at least 40 minutes), 91811 (Covid‑19 phone attendance – at least 40 minutes) and 91843 (Covid‑19 phone attendance for focused psychological strategies – at least 40 minutes) services during the review period.

The practitioner was directed to:

be reprimanded
be counselled
repay the amount of $300,000. This reflects approximately 62% of the benefits paid for the MBS item 44, 2713, 5067, 91811 and 91843 services in connection with which they were found to have engaged in inappropriate practice
be fully disqualified from providing MBS services for a period of 3 years.

In relation to the MBS item 44 services the Committee made findings based on one or more of the following:

The regulatory requirements for billing MBS item 44 were not met, in that there was insufficient clinical content recorded to justify an attendance of at least 40 minutes, or the presenting complaint could not justify an attendance of at least 40 minutes.
The practitioner impermissibly co-billed MBS item 44 with another service for the same clinical input, or where insufficient clinical content was recorded to justify the co-billed service.
The clinical input into the service was inadequate.
The practitioner failed to maintain an adequate and contemporaneous record of the services she provided or otherwise billed Medicare for services which did not occur.

In relation to the MBS item 2713 services the Committee made findings based on one or more of the following:

The regulatory requirements for billing MBS item 2713 were not met, in that there was insufficient clinical content recorded to justify an attendance of at least 20 minutes.
The practitioner co-billing MBS items 44 and 2713 for the same clinical input.
There was no mental health component to the service that would justify the billing of an MBS item 2713 service in addition to MBS item 44. If there was such a component, it was not recorded.
There was insufficient clinical content recorded to explain the co-billing of MBS item 44. If there was sufficient clinical justification, the record is deficient in failing to record it.
The clinical input into the service was inadequate.
The practitioner failed to maintain an adequate and contemporaneous record of the services she provided or otherwise billed Medicare for services which did not occur.

In relation to the MBS item 5067 services the Committee made findings based on one or more of the following:

The practitioner did not attend patients for the purposes of MBS item 5067 services.
The MBS requirements were not met, including that there was no meaningful record of the service at all, or a record that would justify an attendance of at least 40 minutes’ duration.
The practitioner failed to maintain an adequate and contemporaneous record of the services she provided or otherwise billed Medicare for services which did not occur.

In relation to the MBS item 91811 services the Committee made findings based on one or more of the following:

The regulatory requirements for billing MBS item 91811 were not met, in that there was insufficient clinical content recorded to justify an attendance of at least 40 minutes.
The practitioner co-billed MBS item 91843 for the same clinical content as the MBS item 91811 service.
The practitioner co-billed MBS item 92196 (phone attendance for providing eating disorder psychological treatment – at least 40 minutes) for the same clinical content as the MBS item 91811 service.
The practitioner co-billing MBS items 44 and 2713 for the same clinical input.
The clinical input into the service was inadequate.
The practitioner failed to maintain an adequate and contemporaneous record of the services she provided or otherwise billed Medicare for services which did not occur.

In relation to the MBS item 91843 services the Committee made findings based on one or more of the following:

The regulatory requirements for billing MBS item 91811 were not met, including that the record did not disclose any provision of focused psychological strategies and the record did not disclose clinical content to explain an attendance of at least 40 minutes’ duration.
The practitioner co-billed MBS item 91811 for the same clinical content as the MBS item 91843 service.

The practitioner failed to maintain an adequate and contemporaneous record of the services she provided or otherwise billed Medicare for services which did not occur.

D. Federal Court

Director, Professional Services Review v Yoong [2025] FCAFC 95

Dr Yoong had challenged the validity of a notice to produce documents (NTP) sent as part of the Director’s review.

At first instance, Justice Perry found that the NTP was invalid.

On appeal, the Full Court of the Federal Court found in favour of the Director. The court stated that the documents to be produced under the NTP were relevant to the review and are likely to assist the Director in the performance of his investigative functions under Part VAA of the Health Insurance Act 1973 (Act). Further, the court stated the form and content of the NTP were sufficient to comply with the requirements of section 89B of the Act.

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

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

F. Referrals to AHPRA (106XA/B)

There were no matters referred to AHPRA in July 2025.