PSR Director's update for June 2025
A. Section 92 agreements effective in June 2025
Eight agreements were entered into by the Director or an Associate Director and persons under review (under section 92 of the Act) came into effect in June 2025:
Dermatologist
During the review period, the practitioner rendered more MBS item 14050 (UVA or UVB phototherapy administered in a whole body cabinet or hand and foot cabinet) services than 99% of their peers. They rendered the highest volume of MBS item 14050 services in the review period. They were also at the 99th percentile for the volume of services rendered during the review period, and the volume of services per patient.
The Director reviewed this practitioner’s rendering of MBS items 14050, 18234 (trigeminal nerve, primary branch, injection of an anaesthetic agent or steroid) and 45506 (scar, of face or neck). The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate, including that there was no entry in the patient record for the date of service for some of the reviewed services, and for others, the records were brief and unclear
- the practitioner’s billing of MBS item 45506 was inappropriate because they charged fees significantly higher than the Schedule fee, resulting in significant cost to the Commonwealth arising from the availability of the Extended Medicare Safety Net on this uncapped MBS item
- the practitioner’s clinical input and management was insufficient, including that there was inadequate exploration of alternative diagnoses and/or treatments
- the MBS requirements for MBS items 18234 and 45506 were not always met, including that the practitioner injected the infraorbital nerve rather than the trigeminal nerve, and only CO2 laser treatment was provided which would not be revision of a scar.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 14050, 18234 and 45506. The practitioner agreed to be counselled by the Director and to repay $320,000.
Medical practitioner
During the review period, the practitioner rendered the following MBS items in excess of 99% of their peers:
- 721 (preparation of a GP management plan (GPMP))
- 723 (coordination of team care arrangements (TCAs))
- 732 (review of a GPMP or TCAs)
- 703 (health assessment lasting 30-45 minutes)
- 705 (long health assessment lasting 45-60 minutes)
- 30192 (premalignant skin lesions)
The Associate Director reviewed this practitioner’s rendering of MBS items 23 (attendance – less than 20 minutes), 721, 723, 732, 30192 and 91891 (phone attendance by a general practitioner lasting at least 6 minutes). The Associate Director had persisting concerns that:
- the records often did not contain GPMP or TCA documents or otherwise record the relevant information in the patient file
- the practitioner’s record keeping was inadequate, including not always providing sufficient detail to describe what occurred during each service, and often being template based without being sufficiently individualised to each patient
- the MBS requirements, including taking sufficient patient history, were not always met
- the practitioner’s clinical input was insufficient as there was a lack of advice provided and additional or alternative management of conditions
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 23, 721, 723, 732, 30192 and 91891. The practitioner agreed:
- to repay $175,000
- to be disqualified from providing MBS item 721, 723, 732, 92024, 92025, 92028 services for 15 months
- to be reprimanded by the Director.
Nurse practitioner
During the review period, the practitioner rendered and prescribed the following items in excess of 99% of their peers:
- MBS item 91179 (nurse practitioner telehealth attendance - at least 20 minutes)
- MBS item 91190 (nurse practitioner phone attendance - at least 20 minutes)
- PBS item 12910L (molnupiravir 200mg capsule)
- PBS item 12996B (nirmatrelvir 150mg + Ritonavir 100mg tablets)
The Director reviewed this practitioner’s rendering of MBS items 91179 and 91190, and prescribing of PBS items 12910L and 12996B. The Director had persisting concerns that:
- the MBS requirements, including minimum time requirements were not always met
- the practitioner prescribed PBS items in circumstances where the PBS eligibility criteria was not met
- the practitioner’s clinical input was insufficient, including where the practitioner conducted inadequate assessments of patients’ history and medications
- the practitioner did not keep adequate and contemporaneous records, including records that lacked clinical information and did not include an adequate description of the patient’s presentation.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 91179 and 91190 and prescribing PBS Items 12910L and 12996B. The practitioner agreed to:
- repay $86,000
- to be disqualified from providing MBS item 91179, 91190 services for 8 months
- to be reprimanded by the Director
- to be counselled by the Director.
General physician and geriatrician
During the review period, the practitioner rendered a total volume of MBS services for the review period, and on a daily basis, in excess of 99% of their peers. The practitioner also rendered MBS item 110 (initial attendance, consultant physician), 116 (subsequent consultant physician attendance) and 132 (professional attendance by a consultant physician (other than psychiatry) of at least 45 minutes) services at the 99th percentile.
The Director reviewed this practitioner’s rendering of MBS item 110, 116, 132 and 880 (case conference - consultant physician in geriatric or rehabilitation medicine) services. The Director had persisting concerns that:
- the practitioner’s records were inadequate, including that they often lacked sufficient clinical information to explain the service or allow another practitioner to effectively take over care of the patient
- MBS requirements were not always met, including minimum time requirements where relevant
- the practitioner’s clinical input was not always adequate.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 110, 116, 132 and 880. The practitioner agreed to repay $97,000, and will be reprimanded by the Director.
Medical practitioner
During the review period, the practitioner rendered the highest volume of MBS item 229 and 233 services in the review period. They were also at the 99th percentile for the volume of total and daily services rendered during the review period. During the review period, the practitioner also rendered the following MBS items in excess of 99% of their peers:
- 54 (long consultation between 25 and 45 minutes)
- 225 (professional attendance to perform health assessment between 30 and 45 minutes)
- 229 (preparation of GPMP)
- 230 (coordinate the development of TCAs)
- 233 (review or coordinate a review of GPMP or TCAs)
- 91893 (phone attendance lasting at least 6 minutes)
The Associate Director reviewed this practitioner’s rendering of MBS items 53 (consultation between 5 and 25 minutes), 54, 225, 229, 230, 233, 16500 (antenatal attendance) and 91893, and had no concerns in relation to MBS items 53 and 16500. The Associate Director had persisting concerns that:
- the MBS requirements were not always met, including the time and complexity requirements for professional attendances
- the practitioner sometimes initiated pathology or other services when it was neither relevant nor indicated based on the patient’s presenting condition
- the practitioner’s records were not adequate, including containing little to no patient history, generic examination notes and only basic observations
- the practitioner’s GPMPs and TCAs often lacked sufficient personalisation and significant patient information, and often appeared to be generic templates with limited clinical detail.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 54, 225, 229, 230, 233 and 91893. The practitioner agreed to:
- repay $125,000
- to be disqualified from providing MBS item 225, 229, 230, 703, 721, 723, and 92024, 92025, 92055 and 92056 (telehealth equivalents for items 721, 723, 229 and 230 respectively) services for 12 months
- to be reprimanded by the Associate Director.
Nephrologist
During the review period, the practitioner rendered more MBS item 116 and 132 services than 99% of their peers. The practitioner rendered the largest volume of MBS item 132 services compared to all practitioners in Australia during the review period. The practitioner also rendered more total services during the review period than 99% of their peers.
The Director reviewed this practitioner’s rendering of MBS items 116 and 132. The Director had persisting concerns that:
- MBS requirements were not always met, including the practitioner not attending the patient for the minimum time required and there not being a management plan of significant complexity
- the practitioner’s record keeping was inadequate, including failing to include sufficient information to explain what happened for other services.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 116 and 132. The practitioner agreed to counselling by the Director and to repay $250,000.
Medical practitioner
During the review period, the practitioner rendered the following MBS items in excess of 99% of their peers:
- 591 (urgent after-hours care)
- 5028 (consultation at a residential aged care facility (RACF))
- 91800 (telehealth attendance not more than 20 minutes)
- 91801 (telehealth attendance at least 20 minutes)
- 92210 (telehealth attendance on not more than one patient on one occasion)
The Director reviewed this practitioner’s rendering of MBS items 591, 5049 (consultation at a RACF lasting at least 20 minutes), 91800 and 92210, and had no concerns in relation to MBS item 91800. The Director had persisting concerns that:
- the MBS requirements for MBS items 591 and 92210 were not always met in relation to the ‘urgent’ nature of the attendances
- the practitioner’s record keeping was inadequate including a lack of evidence or explanation as to the urgency of the attendances
- the practitioner did not always provide sufficient clinical input including instances where they did not appropriately manage a patient’s presenting health issue.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 591, 5049 and 92210. The practitioner also agreed to be counselled by the Director.
General practitioner
During the review period, the practitioner was at the 99th percentile for their rendering of MBS items 23, 721 and 723. The practitioner also prescribed at least 20 PBS items at volumes greater than 97 percent of their peers.
The Associate Director reviewed this practitioner’s rendering of MBS items 23, 721, 723 and 5020 (afterhours consultation lasting less than 20 minutes), and prescribing of PBS item 1215Y (paracetamol + codeine tablet). The Associate Director had no persisting concerns in relation to MBS items 23 and 5020, and PBS item 1215Y. The Associate Director had concerns regarding the practitioner’s rendering of MBS items 721 and 723, including that:
- the MBS requirements were not always met, including the requirements for comprehensive plans, and evidence of collaboration with 2 providers in TCAs
- GPMP and TCA services were co-billed with MBS item 10997 (service provided by a nurse or Aboriginal and Torres Strait Islander health practitioner to a person with a chronic condition that is consistent with a GPMP or TCA) services in circumstances where the nurse’s role appeared to be for the provision of the MBS item 721 and 723 service and not separately attributable to an MBS item 10997 service.
- the practitioner’s record keeping was inadequate.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 721 and 723. The practitioner agreed to repay $150,000, and to be disqualified from providing MBS item 721, 723, 92024 and 92025 services for 12 months.
B. No further action decisions
General practitioner
During the review period, the practitioner rendered MBS items 91890 (phone attendance lasting less than 6 minutes) and 91891 in excess of 99% of their peers. 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 20 or more days during a 12‑month period.
The Associate Director reviewed a random sample of services rendered as MBS items 91890 and 91891, and considered whether the practitioner had rendered a prescribed pattern of services. After reviewing the practitioner’s records, the 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 services were claimed appropriately and supported by adequate clinical documentation. Regarding the prescribed pattern of services, the documentary evidence indicated that the practitioner did not render a prescribed pattern of services, even though they had billed 30 or more relevant phone services on 20 or more days.
Medical practitioner
During the review period, the practitioner rendered some MBS items in excess of 99% of their peers. 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 20 or more days during a 12 month period.
After obtaining evidence regarding the practitioner’s circumstances, the Director formed the view that no further action was required as it would be impossible for a PSR Committee to conduct a proper investigation due to the practitioner’s health.
C. PSR Committee final determinations
There were 3 PSR Committee final determinations come into effect in June 2025. Details of 2 of those final determinations are set out below. Details of the third PSR Committee final determination will be published at a later date.
PSR Committee 1607
On 11 June 2025 a final determination came into effect regarding a general practitioner. In the final report of the PSR Committee, the practitioner was found to have engaged in inappropriate practise in connection with the following MBS services during the review period:
- 23
- 36
- 44 (consultation lasting at least 40 minutes)
- 721
- 723
- 732
- 5040 (afterhours consultation lasting at least 20 minutes)
- 5060 (afterhours consultation lasting at least 40 minutes)
- 10997
- 31362 (excision of non‑malignant skin lesion)
- 91810 (phone attendance lasting at least 20 minutes)
The Determining Authority directed that the practitioner:
- be reprimanded
- be counselled
- repay the amount of $500,000. This reflects approximately 87% of the benefits paid for the MBS item 23, 36, 44, 5040, 5060, 91810, 721, 723, 732, 31362 and 10997 services in connection with which the practitioner was found to have engaged in inappropriate practice
- be disqualified from providing MBS item 44, 5040 and 5060 services, and equivalent telehealth MBS item 91801 and 91802 services for a period of 6 months, and MBS item 721, 723, 732 services (and equivalent telehealth MBS item 92024, 92025, 92028 services), and MBS item 91810 and 10997 services for a period of 12 months.
In relation to the MBS item 23, 36, 44, 5040, 5060 and 91810 services the Committee made findings based on one or more of the following:
- The practitioner’s clinical input into the service was inadequate.
- The practitioner did not provide a clinically relevant service for which a Medicare benefit was payable.
- The MBS requirements were not met, including that there was insufficient clinical input to justify a consultation of at least 20 minutes’ or 40 minutes’ duration, there was no detailed or extensive patient history and that the patient was not in attendance on the date of service.
- For MBS items 5040 and 5060, the service did not meet the afterhours requirement.
- The medical record was otherwise inadequate.
In relation to MBS items 721, 723 and 732 the Committee made findings based on one or more of the following:
- The MBS requirements were not met, including that the GPMPs were generic templates not adequately individualised for the patient, no evidence of two‑way communication with at least two other providers were involved in the patient’s case for TCAs, and there were no GPMP or TCA review documents found relating to the date of service.
- There was insufficient evidence in the record to show the patient attended on the date of service.
- No GPMP or TCA document was located relevant to the date of service.
- The practitioner billed a standard professional attendance item as well as an MBS item 721, 723 or 732 where the patient attended only once.
- The medical records were otherwise inadequate.
In relation to MBS item 10997 the Committee made findings based on one or more of the following:
- The MBS requirements were not met, including that a nurse did not attend the patient on the date of service, and there was no existing GPMP or TCA for the nurse to be providing a service consistent with a GPMP or TCA.
- The practitioner billed a standard professional attendance item before the date of service and subsequently billed MBS item 10997 where the patient only attended once.
In relation to MBS item 31362 the Committee made findings based on one or more of the following:
- The MBS requirements were not met, including that lesions were removed by shave excision, which is specifically excluded from the item descriptor, and the site requirements were not met.
- Excisions appeared to be for cosmetic reasons and were not clinically relevant.
- The practitioner billed for post-operative treatment which is deemed to be included in the professional service rendered.
- The practitioner’s clinical input into the service was inadequate.
- The medical record was otherwise inadequate.
PSR Committee 1643
On 4 June 2025 a final determination came into effect regarding a cardiologist. In the final report of the PSR Committee, the practitioner was found to have engaged in inappropriate practice in connection with rendering MBS items 110 (initial attendance by consultant physician), 11729 (multi-channel electrocardiogram monitoring and recording) and 55141 (exercise stress echocardiology study) services during the review period.
The Determining Authority directed that the practitioner:
- be reprimanded
- be counselled
- repay the amount the o $1,900,000. This reflects approximately the total amount of benefits paid for the MBS item 110, 11729 and 55141 services in connection with which they were found to have engaged in inappropriate practise
- be fully disqualified from providing MBS item services for a period of 12 months.
In relation to MBS item 110 services the Committee made findings based on one or more of the following:
- The practitioner’s clinical input into the service was inadequate, including that the recorded assessment was superficial and did not outline a focused history relating to the presenting complaint, the examination was inadequate, an adequate history was not taken, and the patient’s medication history and/or relevant signs and symptoms were not adequately addressed.
- The practitioner did not provide an adequate clinical indication for tests performed or their proposed management of the patient.
- The medical record was otherwise inadequate.
In relation to MBS item 11729 the Committee made findings based on one or more of the following:
- The MBS requirements were not met, including that the patient was not eligible for the service on the date of service, an adequate report of the service was not produced, and the monitoring and recording of the service did not always last 20 minutes as required.
- The practitioner’s clinical input into the service was inadequate including that the stress test was performed sub-optimally.
- The practitioner did not provide an adequate clinical indication for tests performed and/or their proposed management of the patient.
- The medical record was otherwise inadequate.
In relation to MBS item 55141 the Committee made findings based on one or more of the following:
- The patient was not eligible for the service on the date of service.
- The stress echo was not clinically indicated.
- The practitioner’s clinical input was inadequate, including that their proposed management of the patient was not clinically indicated, and the stress echo was performed sub-optimally.
- The medical record was otherwise inadequate.
D. Federal Court
There were no federal court decisions handed down in June 2025.
E. Referrals to the major non-compliance (fraud) division (89A & 106N)
No matters were referred to the major non-compliance (fraud) division in June 2025.
F. Referrals to AHPRA (106XA/B)
No matters were referred to AHPRA in June 2025.