A referral to PSR is an outcome of the Department of Health's Practitioner Review Program. The Department of Health will notify you if and when you have been referred to PSR.
The PSR process is a peer review scheme which involves examination of services you have provided and for which your patients received a Medicare or PBS benefit. This includes an assessment of your provision of services according to the legal requirements in the MBS and the PBS, including whether there was clinical justification for the service as evidenced by your clinical record for the service. PSR will also assess the adequacy of your clinical records. As such the PSR process can be time-consuming and legally complex. PSR is committed to assisting you to ensure that the impacts of the process are minimised as far as is reasonable.
At the start of the process there are four key steps that you should take:
- We strongly advise you to engage your medical defence organisation or a legal adviser as early as possible to assist you through the process. The PSR Scheme is a legal process that can have some significant impacts on your future (including the option of disqualifying you from providing Medicare or PBS services for up to 3 years, and for up to 5 years in some circumstances). Legal assistance will therefore assist you in protecting your interests. Most medical defence organisations are familiar with the administrative and legal requirements of the PSR process and will be able to provide you with valuable advice and guidance.
- We also suggest that you inform people close to you that you have been referred to PSR. While this will be entirely at your discretion, having someone to discuss the matter with will help you manage any potential stress or concerns that may arise during the process.
- The Request to Review document, which has been sent to you by the Department of Health, will contain information outlining the delegate's concerns, as well as statistics about your practice during the review period. This document contains the reason why you have been referred to PSR.
- As part of his or her Review of your practice, the Director of PSR will send you a Notice requesting the complete and original clinical records of some of your patients who received a service during the review period. It is important that you meet the due dates specified in this Notice (you will be provided with at least 14 days to respond from the date you receive the notice). PSR will allow you a reasonable amount of time to provide the clinical records and, if required, will also provide you with a plastic storage crate with tamper resistant seals for their secure courier transport to and from your practice.
What to do checklist:
- Talk to your medical defence organisation or legal adviser
- Identify and inform your support person or group
- Read and familiarise yourself with the Request to Review document sent by a delegate of the Chief Executive Medicare to the Director of PSR
- Prepare to respond to the Notice requesting complete and original clinical records by the due date
- Read Your_Guide_to_the_PSR_Process_(2018).PDF to assist you in your understanding of, and obligations under, the PSR process.