PSR Director's update for June 2026

A. Section 92 agreements effective in June 2026

Twelve agreements entered into by the Director or an Associate Director and persons under review (under section 92 of the Health Insurance Act 1973 (Cth) (Act)) came into effect in June 2026:

Psychiatrist

During the review period, the practitioner rendered the following Medicare Benefits Schedule (MBS) item services in excess of 99% of their peers:

• 14216 (treatment mapping for an initial course of Repetitive Transcranial Magnetic Stimulation (rTMS))
• 14217 (rTMS treatment of up to 35 services)
• 14219 (treatment mapping for a subsequent course of rTMS)
• 14220 (rTMS treatment of up to 15 services for a patient who has previously received rTMS treatment)

The Director reviewed this practitioner’s rendering of MBS item 14216, 14217, 14219 and 14220 services, and had persisting concerns that:

• the MBS requirements for these services were not always met, including where:
  • the required content for MBS items 14216 and 14219 services was split across 2 attendances that were each billed to Medicare
  • MBS item 14219 was billed where the patient’s response to prior rTMS treatment was not established using a validated major depressive disorder tool
  • the practitioner did not always provide adequate follow-up or monitoring to patients when providing MBS item 14217 and 14220 services, or billed these steps as additional services
  • the practitioner billed attendance services under their provider number when the patient was attended on by a different practitioner
• patients were impermissibly charged an additional administration fee for bulk‑billed services, which is prohibited by subsection 20A(b) of the Act
• the practitioner’s record keeping was sometimes inadequate, including where the clinical record did not contain sufficient information to explain the service or where there was no record for a date of service.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 14216, 14217, 14219 and 14220 services. The practitioner agreed to:

• be counselled by the Director
• repay $418,000 to the Commonwealth
• be disqualified from providing MBS item 14216, 14217, 14219, 14220 services for 12 months. 

General practitioner and consultant physician

During the review period, the practitioner rendered a prescribed pattern of services (rendering 30 or more relevant phone services on 20 or more days in a 12-month period). The practitioner also provided the following MBS item services and Pharmaceutical Benefits Scheme (PBS) items in excess of 99% of their peers:

• 36 (attendance lasting at least 20 minutes)
• 66596 (iron studies)
• 66833 (quantification of 25-hydroxyvitamin D in serum)
• 90043 (attendance at a residential aged care facility (RACF) lasting at least 20 minutes) 
• 91801 (video attendance lasting at least 20 minutes)
• 91891 (phone attendance lasting at least 6 minutes)
• 2622B (oxycodone hydrochloride 5 mg tablet, 200).

The Director reviewed this practitioner’s provision of MBS item 36, 44 (attendance lasting at least 40 minutes), 66596, 66833, 90043, 91801 and 91891 services, and PBS items 1215Y (paracetamol 500 mg + codeine phosphate hemihydrate 30 mg tablet, 20), 2622B and 3162K (diazepam 5 mg tablet, 50), and had no persisting concerns in relation to MBS item 66596 and 66833 services and PBS item 3162K. 

In relation to the remaining items, the Director had persisting concerns that:

• the practitioner rendered 30 or more relevant phone 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 MBS requirements were not always met, including the respective minimum time requirements where relevant
• the practitioner billed for services in circumstances where their records did not reflect that they attended on the patient, including when there was no record for a date of service or there were multiple services billed on one day where each service was not supported by clinical notes
• the practitioner’s prescribing of PBS items 1215Y and 2622B was inappropriate, including that PBS restrictions for these items were not met, the practitioner did not adequately assess whether the medication was clinically indicated, or the practitioner did not otherwise provide adequate clinical input.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 36, 44, 90043, 91801 and 91891 services and PBS items 1215Y and 2622B, and in providing services that constituted a prescribed pattern of services. The practitioner agreed to:

• be reprimanded by the Director
• be counselled by the Director
• repay $410,000 to the Commonwealth
• be disqualified from providing MBS item 44 services for 9 months
• be disqualified from providing MBS item 90043 services for 3 months.

General practitioner

During the review period, the practitioner rendered 20 individual professional attendance items in excess of 99% of their peers, and rendered the highest volume nationally of MBS item 758 (attendance to participate in a community or multidisciplinary case conference) and 92027 (video contribution to a multidisciplinary care plan for a patient in a RACF) services.

An Associate Director reviewed this practitioner’s rendering of the following MBS item services: 

• 707 (attendance for health assessment lasting at least 60 minutes)
• 731 (contribution to multidisciplinary care plan for patient in a RACF)
• 743 (attendance to organise and coordinate a community or multidisciplinary case conference)
• 758
• 5028 (after-hours attendance at a RACF lasting at least 6 minutes and less than 20 minutes)
• 5049 (after-hours attendance at a RACF lasting at least 20 minutes)
• 90043
• 90051 (attendance at a RACF lasting at least 40 minutes)
• 91801
• 92210 (video attendance in the unsociable hours for a patient requiring urgent assessment).

The Associate Director had no concerns in relation to the practitioner’s rendering of MBS item 707, 5028, 90051, and 91801services. In relation to the remaining items, the Associate Director had persisting concerns that:

• the MBS requirements for these services were not met, including that:
  • MBS item 90043 services did not last at least 20 minutes
  • the clinical records for MBS item 92210 services did not always support that the attendance was provided in unsociable hours or that an urgent assessment of the patient’s condition was required
  • MBS item 5049 services were sometimes not provided in the after-hours period
• the practitioner’s record keeping was inadequate, including where there were no clinical records for MBS item 731 services and where the notes for MBS item 743 services appeared to be duplicated from notes for previously billed MBS item 758 services
• the practitioner co-billed services in circumstances where the clinical records did not support that they provided more than one distinct service.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 731, 743, 758, 5049, 90043 and 92210 services. The practitioner agreed to:

• be reprimanded by the Associate Director
• be counselled by the Associate Director
• repay $120,000 to the Commonwealth
• be disqualified from providing MBS item 743 services for 12 months.

General practitioner

During the review period, the practitioner rendered MBS item 44 services in excess of 99% of their peers. An Associate Director reviewed this practitioner’s rendering of the following MBS item services:

• 36
• 44
• 721 (preparation of a general practitioner management plan (GPMP))
• 723 (coordination of team care arrangements (TCAs))
• 732 (review of a GPMP or TCAs).

The Associate Director had persisting concerns in relation to these services that:

• The MBS requirements were not always met, including that:
  • for MBS item 36 and 44 services, the records did not reflect that the practitioner undertook all relevant clinical actions or provided a service that met the respective minimum time required
  • for MBS item 721, 723 and 732 services, the practitioner did not always prepare a comprehensive written plan, ensure collaboration with additional healthcare providers or adequately document reviews of these arrangements
• the practitioner’s record keeping was inadequate, including where their clinical records did not contain sufficient information to explain the service
• the practitioner was assisted in providing medical services by a retired general practitioner who was not registered to provide these services.

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

• be reprimanded by the Associate Director
• be counselled by the Associate Director
• repay $204,000 to the Commonwealth
• be disqualified from providing MBS item 965, 967, 92029 and 92030 (current equivalents, including video equivalents, for MBS items 721, 723 and 732) services for 12 months.

General practitioner 

During the review period, the practitioner rendered a prescribed pattern of services (rendering 80 or more relevant services on 20 or more days in a 12-month period), and rendered MBS item 731, 903, 90020 (attendance at a RACF for an obvious problem characterised by its straightforward nature) and 90035 services in excess of 99% of their peers. 

An Associate Director reviewed this practitioner’s rendering of the following MBS and PBS item services:

• 731
• 903
• 90020
• 90035
• 2089Y (temazepam 10 mg tablet, 25)
• 2348N (pregabalin 25 mg capsule, 56)
• 2622B
• 3132W (oxazepam 15 mg tablet, 250)
• 8865N (buprenorphine 5 microgram/hour patch, 2)

The Associate Director had no persisting concerns in relation to MBS item 903 and 90035 services, and the prescribing of PBS items 2089Y, 2348N, 2622B, 3132W and 8865N. In relation to the remaining items, the Associate Director had persisting concerns that:

• the practitioner rendered 80 or more relevant services on each of 22 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 where:
  • for MBS item 731 services it was not always clear whether the practitioner contributed to or reviewed a multidisciplinary care plan, including where there was no plan in place
  • for MBS item 90020 services, the record did not always reflect that the practitioner attended on the patient
• the practitioner’s record keeping was not always adequate.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 731 and 90020 services, and in providing services that constituted a prescribed pattern of services. The practitioner agreed to repay $44,500 to the Commonwealth and to be reprimanded by the Associate Director.

General practitioner

During the review period, the practitioner rendered a prescribed pattern of services (rendering 30 or more relevant phone services on 20 or more days in a 12-month period), and rendered MBS item 91800 (telehealth attendance lasting at least 6 minutes but less than 20 minutes), 91801, 91853 (antenatal video attendance), 91891 and 92210 services in excess of 99% of their peers. 

An Associate Director reviewed this practitioner’s rendering of MBS item 721, 723, 90043, 91800, 91801, 91853, 91891 and 92210 services, and PBS item 1215Y and 8254K (amoxicillin 875 mg + clavulanic acid 125 mg tablet, 10) services, and had no concerns in relation to MBS item 91891 services. 

The Associate Director had persisting concerns in relation to the remaining items that:

• the practitioner rendered 30 or more relevant phone services on each of 26 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 where:
  • for MBS items 90043, 91801 and 92210, the minimum time requirements were not met
  • MBS item 91853 and 91800 services were co-billed where the clinical notes reflected that only one service was provided
  • for MBS item 721 and 723 services, the patient was not always eligible for the service, the documentation was not sufficiently comprehensive, and the practitioner did not correspond with additional healthcare providers as part of TCAs
• the practitioner’s prescribing was inappropriate, including where the PBS restrictions for prescribing particular medications was not met, or where they did not prescribe according to accepted clinical practice
• the practitioner’s record keeping was inadequate, including that there was no record for some services, and in some cases the clinical records did not contain sufficient detail to support the service billed.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 721, 723, 90043, 91800, 91801, 91853 and 92210 services, and PBS item 1215Y and 8254K services, and in providing services that constituted a prescribed pattern of services. The practitioner agreed to:

• be reprimanded by the Associate Director
• repay $200,000 to the Commonwealth
• be disqualified from providing MBS item 965, 92029 and 91801 services for 12 months
• be disqualified from providing MBS item 90043 and 91853 services for 6 months. 

General practitioner

During the review period, the practitioner rendered a prescribed pattern of services (rendering 30 or more relevant phone services on 20 or more days in a 12-month period), and rendered MBS item 705, 5028, 91890, 91891 and 93700 services in excess of 99% of their peers. 

An Associate Director reviewed this practitioner’s prescribing of PBS item 8865N, and their rendering of the following MBS item services:

• 23 (attendance lasting at least 6 minutes and less than 20 minutes)
• 705 (attendance to perform a health assessment, lasting between 45 and 60 minutes)
• 731
• 5028
• 90035
• 91890 (phone attendance lasting less than 6 minutes)
• 91891
• 93700 (phone attendance for nicotine and smoking cessation advice, lasting less than 20 minutes).

The Associate Director had no persisting concerns in relation to PBS items 8865N or the practitioner’s rendering of a prescribed pattern of services. The Associate Director was satisfied that a Committee might find that exceptional circumstances existed on a sufficient number of days. In relation to the remaining items, the Associate Director had persisting concerns that:

• the practitioner’s record keeping was inadequate because of the use of repetitive and non-personalised templates, and there was not always a contemporaneous record for reviewed services
• the practitioner did not always provide adequate clinical input, including when providing services to patients at RACFs
• the MBS requirements were not always met, including where the service did not meet minimum time requirements or where items were co-billed without the record reflecting two distinct services.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 23, 705, 731, 5028, 90035, 91890, 91891 and 93700 services. The practitioner agreed to:

• be reprimanded by the Associate Director
• be counselled by the Associate Director
• repay $135,000 to the Commonwealth, and
• be disqualified from providing MBS item 731 services for 12 months. 

General practitioner 

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

• 599 (attendance in the unsociable hours for a patient requiring urgent assessment)
• 5040 (after-hours attendance lasting at least 20 minutes)
• 57523 (X-ray knee)
• 57712 (X-ray hip joint)
• 66596
• 66707 (5 or more tests described in item 66695, being quantitation in blood or urine of particular hormones and hormone binding proteins)
• 66833
• 91891.

The Director reviewed this practitioner’s provision of MBS item 36, 599, 721, 723, 5040, 57523, 57712, 66596, 66707, 66833 and 91891 services, and had the following persisting concerns:

• The MBS requirements were not always met, including in the following circumstances:
  • For MBS item 36, 599, 5040 and 91891 services, not all actions taken were clinically indicated, there was not always sufficient clinical input to justify the billed service and the practitioner’s record keeping was inadequate.
  • For MBS item 721 and 723 services, patients were not always eligible for the services, and the chronic disease management (CDM) documentation was not sufficiently comprehensive.
• Diagnostic imaging and pathology services initiated by the practitioner were not always clinically indicated.
• The practitioner prescribed growth hormone and XCell therapy to treat osteoarthritis, XCell therapy to treat a range of conditions including multiple sclerosis, and ivermectin to treat COVID-19, when these were not recognised therapies in Australia during the review period. It was also unclear whether informed patient consent was obtained for human growth hormone treatment and use of ivermectin.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 36, 599, 721, 723, 5040, 57523, 57712, 66596, 66707, 66833 and 91891 services. The practitioner agreed to:

• be counselled by the Director
• repay $230,000 to the Commonwealth
• be disqualified from providing MBS item 965, 967, 92029 and 92030 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:

• 23 
• 721
• 723
• 30029 (repair of wound to skin and subcutaneous tissue or mucous membrane, not on face or neck)
• 30035 (repair of wound to skin and subcutaneous tissue or mucous membrane, on face or neck).

An Associate Director reviewed this practitioner’s provision of MBS item 23, 36, 721, 723, 732, 5020 (after-hours attendance lasting at least 6 minutes and less than 20 minutes), 30029, 30035 and 91891 services and PBS item 1887H (amoxicillin 250 mg/5 mL powder for oral liquid, 100 mL). 

The Associate Director had no persisting concerns in relation to MBS item 23 and PBS item 1887H. In relation to the remaining items, the Associate Director had persisting concerns that:

• the MBS requirements were not met, including in the following circumstances:
  • the minimum time requirements were not always met for MBS item 36, 5020 and 91891 services
  • MBS item 30029 and 30035 services were billed where the record did not reflect a repair of deeper tissue
  • the practitioner’s documentation was not sufficiently comprehensive for CDM services and it was also unclear whether the practitioner collaborated with 2 or more health providers prior to billing MBS item 723, and whether services billed as MBS item 732 involved a review
• CDM services were rendered opportunistically where there was no clinical indication, including where the patient did not appear to have a chronic medical condition
• the practitioner co-billed professional attendance items with therapeutic procedures where the clinical records did not reflect that an attendance was provided separately to the procedure and its associated clinical input
• the practitioner’s record keeping was inadequate, including when notes for services were composed of generic templates with minimal or no unique detail to explain what occurred during a consultation.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 36, 721, 723, 732, 5020, 30029, 30035 and 91891 services. The practitioner agreed to:

• be reprimanded by the Associate Director
• be counselled by the Associate Director
• repay $325,000 to the Commonwealth
• be disqualified from providing MBS item 965, 967, 30029, 30035, 92029 and 92030 services for 12 months.

General practitioner

During the review period, the practitioner rendered MBS item 23, 5020 and 5040 services in excess of 99% of their peers. An Associate Director reviewed this practitioner’s provision of MBS item 23, 36, 721, 723, 5020 and 5040 services, and PBS item 1889K (amoxicillin 500 mg capsule, 20), and had persisting concerns that:

• the MBS item requirements were not always met, including that
  • the minimum time requirements where relevant
  • relevant clinical actions were not always undertaken
  • CDM plans were not always comprehensive and there did not always appear to be collaboration with 2 or more other healthcare providers
• the practitioner prescribed PBS item 1889K where the patient’s presentation was not consistent with a bacterial infection
• the practitioner’s record keeping was inadequate, including that the records did not contain sufficient clinical detail to support the item claimed
• CDM services provided by the practitioner were not always clinically indicated
• the practitioner’s clinical management of patients was not always appropriate, including that they prescribed medications despite contraindications.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 23, 36, 721, 723, 5020 and 5040 services and PBS item 1889K. The practitioner agreed to:

• be reprimanded by the Associate Director
• be counselled by the Associate Director
• repay $150,000 to the Commonwealth
• be disqualified from providing MBS item 965 and 92029 services for 6 months.

General practitioner

During the review period, the practitioner rendered MBS item 23, 721, 723, 2715 (attendance lasting between 20 and 40 minutes for the preparation of a GP mental health treatment plan), 5020 and 91891 services in excess of 99% of their peers. 

An Associate Director reviewed this practitioner’s rendering of MBS item 23, 36, 721, 723, 2715, 5020 and 91891 services, and had no persisting concerns in relation to MBS items 23, 2715, 5020 and 91891. The Associate Director had persisting concerns in relation to the remaining items that:

• the MBS requirements were not always met, for one or more of the following reasons:
  • The minimum time requirements were not always met.
  • CDM services were provided to patients who were not eligible.
  • The practitioner’s documentation for MBS item 721 and 723 services was not comprehensive or personalised to the patient
  • The record did not always reflect that there was two-way communication with 2 additional healthcare providers prior to billing MBS item 723.
• The practitioner’s record keeping was not always adequate, including when they did not record sufficient clinical information to explain the service.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 36, 721 and 723 services. The practitioner agreed to be reprimanded by the Associate Director and to repay $10,000 to the Commonwealth.

General practitioner

During the review period, the practitioner rendered third highest volume nationally of MBS item 92210 services, and the seventh highest volume nationally of MBS item 91800 services. The practitioner also prescribed 15 PBS items in excess of 99% of their peers. 

An Associate Director reviewed this practitioner’s rendering of MBS item 91800, 91891, 92210 and 93716 (phone attendance lasting at least 20 minutes to determine eligibility for COVID-19 antiviral treatment) services and their prescribing of PBS items 1887H, 1889K, 3119E (cefalexin 500 mg capsule, 20) and 8254K. The Associate Director had no concerns in relation to the practitioner’s prescribing of PBS item 3119E, but had persisting concerns in relation to the remaining items that:

• the MBS requirements were not always met, including that it did not appear that the practitioner attended on the patient on the date of service, the practitioner did not meet the minimum time requirements and did not undertake clinically relevant actions
• the practitioner did not always properly assess patient eligibility for MBS item 93716 services
• the practitioner’s clinical input when prescribing was not always adequate, including when they issued delayed prescriptions without providing advice to the patient regarding when they should be filled and taken.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS item 91800, 91891, 92210 and 93716 services and PBS items 1887H, 1889K and 8254K. The practitioner agreed to:

• be reprimanded by the Associate Director
• be counselled by the Associate Director
• repay $4,500 to the Commonwealth.

B. No further action decisions

C. PSR Committee final determinations

D. Federal Court

There was one Federal Court decision handed down in June 2026:

On 28 February 2025, Dr Reece filed an application for judicial review seeking to challenge the Committee’s final report which made findings that he had engaged in inappropriate practice. The substantive matter has not yet been heard.

Following orders made for discovery on 20 March 2026, Dr Reece brought an interlocutory application seeking to amend these orders as they related to documents that the Director said were subject to the immunity in section 106F of the Act (that Committee members have the same protection and immunity as a Justice of the High Court), or that were clerical or administrative in nature.

Rangiah J handed down his decision on the interlocutory application on 10 June 2026. His Honour reiterated previous judicial authority that the immunity under section 106F meant that an order for discovery could not extend to documents that would reveal ‘any aspect of the decision‑making process’. The Director is therefore not required to list or produce documents that would be subject to the immunity in section 106F. The Director was required, however, to discover and produce documents considered to be clerical or administrative in nature.

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

One matter was referred to the major non-compliance (fraud) division in June 2026.

F. Referrals to AHPRA (106XA/B)

No matters were referred to Ahpra in June 2026.