PSR Director's update for November 2025

A. Section 92 agreements effective in November 2025

Eleven agreements entered into by the Director and persons under review (under section 92 of the Act) came into effect in November 2025:

Psychiatrist 

During the review period, the practitioner was ranked the highest provider nationally of MBS items:

• 348 (attendance by consultant physician between 20 and 45 minutes involving an interview of a person other than the patient in the course of an initial diagnostic evaluation)
• 350 (attendance by consultant physician involving a person other than the patient not less than 45 minutes in the course of initial diagnostic evaluation).

The practitioner was also ranked sixth nationally for rendering MBS item 304 services (attendance by consultant physician between 30 and 45 minutes). The Director reviewed this practitioner’s rendering of MBS item 304, 348 and 350 services, and prescribing of PBS items 1165H (dexamfetamine tablet 5 mg) and 11898F (lisdexamfetamine capsule 40 mg). 

The Director had no persisting concerns in relation to PBS items 1165H and 11898F. For the remaining services, the Director had persisting concerns that:

• minimum time requirements had been met for MBS item 304, 348 and 350 services
• in relation to MBS item 348 and 350 services, the person with whom the practitioner spoke was not always identified in the records, making it impossible to determine whether the person was a relative or close associate as required by the item descriptors
• in relation to MBS item 348 and 350 services, the practitioner’s records did not always reflect that the practitioner had used the interview with the patient’s relative or close associate to determine whether the patient’s presenting problem was focused with the patient or their interactions with the person being interviewed
• the practitioner sometimes rendered MBS item 348 and 350 services more than a month after the initial consultation, which did not meet the MBS requirements of being in the course of initial diagnostic evaluation of the patient
• the practitioner failed to provide adequate safety netting for vulnerable patients, including not establishing risk mitigations or crisis planning
• the practitioner’s record-keeping was inadequate, including instances where there was not always a separate entry for each attendance, and sometimes no progress notes on the date the service was billed to Medicare.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering services as MBS items 304, 348 and 350. The practitioner agreed to: 

• repay $225,000 to the Commonwealth
• be disqualified from providing MBS item 343, 345, 347, 349, 91875, 91876, 91877, 91878, 91883 and 91884 services for 12 months
• be reprimanded by the Director. 

In this case, the MBS items under review, being MBS items 304, 348 and 350 had been removed from the MBS before the section 92 agreement was entered into. The disqualification is for the equivalent items now applicable and their telehealth equivalents.

General practitioner

During the review period, the practitioner provided the following MBS item services 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)
• 11610 (measurement of ankle: brachial indices and arterial waveform analysis)
• 11707 (twelve-lead electrocardiography, trace only)

An Associate Director reviewed this practitioner’s provision of MBS item 36 (consultation lasting at least 20 minutes), 707, 721, 723, 732, 2713 (attendance in relation to a mental health disorder, lasting at least 20 minutes), 11610 and 11707 services. 

The Associate Director had persisting concerns that:

• the MBS requirements were not always met, including that the minimum time requirements had been met
• some patients for whom MBS item 707 services were provided by the practitioner did not appear to be eligible for a health assessment service
• in relation to MBS item 707, 721, 723 and 732 services, the documentation was not comprehensive and did not always indicate that the practitioner had contributed to the documents in a meaningful way
• there was no clear indication for diagnostic investigations provided as MBS item 11610 and 11707 services
• the practitioner’s record keeping was inadequate, including that notes were copied and pasted across several services without adequate personalisation to explain the service. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 36, 707, 721, 723, 732, 2713, 11610 and 11707. The practitioner agreed to: 

• repay $230,000 to the Commonwealth
• be disqualified from providing MBS item 2713 services for 12 months
• be reprimanded by the Associate Director
• be counselled by the Associate Director.

General practitioner

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

MBS items:

• 743 (organise and coordinate a GP case conference of at least 40 minutes)
• 30192 (premalignant skin lesions)
• 90035 (attendance at a residential aged care facility (RACF) of at least 6 minutes and less than 20 minutes)
• 91891 (phone attendance lasting at least 6 minutes)

PBS items:

• 1215Y (paracetamol + codeine tablet, 500mg + 30 mg)
• 2089Y (temazepam tablet, 5 mg)
• 3162K (diazepam tablet, 5 mg)

The practitioner was also ranked ninth nationally for MBS item 743 (organise and coordinate a case conference of at least 40 minutes) compared to all other providers. 

An Associate Director reviewed this practitioner’s provision of MBS item 743, 30192, 90035 and 91891 services, and PBS items 1215Y, 2089Y and 3162K. The Associate Director had persisting concerns that:

• MBS requirements were not always met, including that the practitioner’s records lacked sufficient details and did not always reflect that the requirements for each service were met
• the practitioner’s prescribing and clinical management of patients was inappropriate, including that the indication, monitoring and management of medications was often unclear
• the practitioner’s record-keeping was inadequate, with a significant number of non-contemporaneous entries made in patient records up to years after the date the service was claimed to have been provided.  

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 743, 30192, 90035 and 91891 services, and prescribing PBS items 1215Y, 2089Y and 3162K. The practitioner agreed to: 

• repay $236,327 to the Commonwealth
• be disqualified from providing MBS item 743 services for 24 months and MBS item 91891 and 30192 services for 12 months
• be reprimanded by the Associate Director
• be counselled by the Associate Director.

Radiologist (Diagnostic radiologist)

During the review period, the practitioner ranked first nationally among active radiologists for the following MBS items: 

• 105 (attendance by specialist after initial attendance)
• 18222 (continuous infusion or injection by catheter of a therapeutic substance)
• 57341 (computed tomography, in conjunction with a surgical procedure using interventional techniques)

The practitioner was also ranked second nationally among active radiologists for MBS item 104 (initial attendance by specialist). 

The Director reviewed this practitioner’s rendering of MBS items 104, 105, 18222 and 57341 and an MRI class of services that consisted of MBS items 63322, 63325, 63328 and 63331 where co‑billed with at least one other MRI item in Group I5 from within MBS range 63001 to 64995 inclusive, in respect of the same patient and for the same day. The Director had persisting concerns that:

• the practitioner had not performed a separate consultation service when billing MBS item 104 and 105 which were co-billed with a diagnostic imaging or procedural service and these services did not meet the Medicare requirements as there was no valid referral from a practitioner for a separate consultation to the procedure performed
• the MBS requirements were not met for MBS item 18222 because the item was used for administering a local anaesthetic rather than the continuous infusion or injection by catheter to maintain regional anaesthesia or analgesia
• MBS item 57341 was co‑billed with other attendance or procedural items (including MBS item 18222) where the requirements for the co‑billed item were not met
• multiple MRI items were co‑billed where not all services were requested or completely performed
• some reports back to the referring practitioner were not able to be located. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 104, 105, 18222, 57341 and items 63322, 63325, 63328 and 63331 when co-billed with at least one other item in the class. The practitioner agreed to repay $59,000 and be counselled by the Director. 

Diagnostic radiologist and nuclear medicine specialist 

During the review period, the practitioner was ranked first nationally for rendering the following MBS items:

• 56623 (computed tomography lower limb + contrast)
• 56801 (computed tomography chest, abdomen and pelvis)

The practitioner was also ranked second nationally for MBS item 56807 (computed tomography chest, abdomen and pelvis + contrast) compared to all other providers. The Director reviewed this practitioner’s rendering of MBS items 56623, 56801, 56807 and 61563 services. The Director had no persisting concerns in relation to MBS items 61563. 

For the remaining services, the Director had persisting concerns that:

• the practitioner rendered MBS item 56623, 56801 and 56807 services when they were not always clinically indicated
• the MBS requirements were not always met for each service, including the requests were not always for diagnostic computed tomography
• the practitioner’s clinical input was not always adequate as patients were sometimes exposed to additional radiation doses where it was not necessary. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 56623, 56801 and 56807. The practitioner agreed to repay $420,000 and be counselled by the Director. 

General practitioner

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

• 721
• 723
• 732
• 91891

An Associate Director reviewed this practitioner’s rendering of MBS items 721, 723, 732 and 91891. The Associate Director had persisting concerns that:

• the MBS requirements were not always met, including where minimum time requirements were not met, and there not always being a record of attendance or engagement with the patient for phone services
• the chronic disease management services did not always meet the MBS requirements because the documentation lacked comprehensive plans, did not demonstrate active collaboration with other health providers when required, and the reviews did not provide adequate progress updates
• the practitioner’s records were inadequate as they consisted of both illegible handwritten notes and digital entries that often lacked sufficient clinical information to explain the service. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 721, 723, 732 and 91891. The practitioner agreed to: 

• repay $220,000 to the Commonwealth
• be disqualified from providing any MBS item services for a period of 36 months
• be reprimanded by the Associate Director.

Obstetrician - gynaecologist

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

• 35503 (introduction of an intra-uterine device)
• 55278 (duplex scanning)
• 55700 (pregnancy related or pregnancy complication ultrasound scan)

The Director reviewed this practitioner’s rendering of MBS items 104, 35503, 55278 and 55700. The Director had no persisting concerns in relation to MBS items 35503 and 55700. For the remaining services, the Director had persisting concerns that:

• there was not always a valid referral for a consultation in relation to MBS item 104
• the MBS requirements were not met for many MBS item 55278 services, including instances where they were not clinically indicated or specifically requested.

The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS Items 104 and 55278. The practitioner agreed to repay $320,000 to the Commonwealth and be counselled by the Director. 

General practitioner

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

MBS items:

• 91890 (phone attendance lasting less than 6 minutes)

PBS items:

• 3162K
• 1215Y
• 2089Y
• 2335X (pregabalin 75 mg) 

An Associate Director reviewed this practitioner’s 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 also reviewed the practitioner’s rendering of MBS item 91890 and 91891 services, and prescribing of PBS items 1215Y, 2089Y, 2335X and 3162K. 

The Associate Director had no persisting concerns in relation to MBS items 91890, and PBS item 2335X. For the remaining services, the Associate Director had persisting concerns that:

• the practitioner rendered 30 or more relevant phone services on each of 50 days in the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
• the practitioner did not provide sufficient clinical management and did not adequately determine clinical indication before prescribing PBS items 1215Y, 2089Y and 3162K
• the practitioner’s record-keeping was inadequate for MBS item 91891 services as there was not always sufficient clinical information recorded to explain the service. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 91891 services and prescribing PBS items 1215Y, 2089Y and 3162K and in providing services that constituted a prescribed pattern of services. The practitioner agreed to repay $10,000 to the Commonwealth, and will be reprimanded by the Associate Director.

Physician (general medicine)

During the review period, the practitioner ranked first nationally for MBS item 161 services (attendance lasting between 2 and 3 hours on a patient in imminent danger of death), ranked second for MBS item 162 services (attendance lasting between 3 and 4 hours on a patient in imminent danger of death) and rendered the following MBS items at volumes in excess of 99% of their peers:

• 132 (attendance by consultant physician lasting at least 45 minutes)
• 133 (attendance by consultant physician lasting at least 20 minutes)
• 834 (attendance by physician to organise discharge case conference)

The Director reviewed this practitioner’s rendering of MBS items 132, 133, 161, 162 and 834. The Director had persisting concerns that:

• in relation to MBS item 132 and 133 services, the patients did not always appear to have 2 morbidities, as required by the MBS descriptors
• it was not always clear that the practitioner personally attended the patient for the required time periods or that the patient was in imminent danger for MBS item 161 and 162 services
• the MBS item 834 services did not always reflect that discharge case conferences had occurred, nor did they meet the other MBS requirements
• the practitioner’s record-keeping was inadequate, including where their notes were not always contemporaneous and lacked sufficient clinical detail and input.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 132, 133, 161, 162 and 834. The practitioner agreed to repay $131,500 to the Commonwealth and to be counselled by the Director. 

Medical practitioner

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

• 23 (attendance lasting between 6 and 20 minutes)
• 36
• 91891 

The Director reviewed this practitioner’s rendering of MBS item 23, 36 and 91891 services, and provision of a prescribed pattern of services (rendering of 80 or more relevant attendance services on 20 or more days in a 12-month period). The Director had persisting concerns that:

• the practitioner rendered 80 or more professional attendance services on each of 30 days in the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
• the MBS requirements for MBS item 36 and 91891 services were not always met, including all clinically relevant tasks not being undertaken or that the minimum time requirement was met
• the practitioner’s record-keeping was inadequate because there was not always sufficient clinical information to explain the service, or where multiple services across a patient’s record were near identical. 

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 23, 36 and 91891 services, and in providing services that constituted a prescribed pattern of services. 

The practitioner agreed to: 

• repay $340,000 to the Commonwealth
• be disqualified from providing MBS item 91891 services for 12 months
• be reprimanded by the Director
• be counselled by the Director.

Medical practitioner

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

• 5040 (after-hours attendance lasting at least 20 minutes)
• 91801 (telehealth attendance lasting at least 20 minutes)
• 91891

The Director reviewed this practitioner’s 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) and MBS item 5040, 91801 and 91891 services. The Director had persisting concerns that:

• the practitioner rendered 30 or more relevant phone services on each of 43 days in 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
• the practitioner’s clinical management was not always appropriate and prescribing in some services was not indicated
• the practitioner’s record‑keeping was not always adequate because many entries contained insufficient clinical information, and entries could not be located for some services.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 5040, 91801 and 91891 and in providing services that constituted a prescribed pattern of services. The practitioner agreed to: 

• repay $262,500 to the Commonwealth
• be disqualified from providing MBS item 91891 services for 12 months
• be counselled by the Director.

B. No further action decisions

General practitioner

An Associate Director commenced reviewing services rendered by the practitioner during the review period. During the Associate Director’s review, the practitioner passed away. The Associate Director decided under paragraph 91(1)(b) of the Health Insurance Act 1973 that it would be impossible for a PSR Committee to conduct a proper investigation in relation to this matter.

C. PSR Committee final determinations

PSR Committee 1557

On 14 November 2025, a final determination came into effect regarding a medical practitioner. In the final report of the PSR Committee, the practitioner was found to have engaged in inappropriate practice in connection with MBS item 44 (attendance lasting at least 40 minutes), 591 (urgent after-hours attendance), 599 (urgent attendance unsocial after-hours attendance) and 5040 services. 

The practitioner was directed to:

• be reprimanded
• repay the amount of $230,000 to the Commonwealth
  • this amounts to approximately 100% of the Medicare benefits that were paid for the MBS item 44, 591, 599 and 5040 services in connection with which the practitioner was found to have engaged in inappropriate practice
• be fully disqualified from rendering MBS item services for a period of 3 years 

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

• The MBS requirements were not met because:
  • the service performed was not an in-rooms consultation
  • the minimum time requirement of at least 40 minutes was not met.
• Clinical input was inadequate including no reasonable assessment or management of the patient the medical record was inadequate, lacking sufficient patient history, examination findings and clinical reasoning including details of medications prescribed.

In relation to MBS item 5040, the Committee made findings based on one or more of the following:

• The MBS requirements were not met, because:
  • services were not performed within the relevant after-hours period
  • the minimum time requirement of at least 40 minutes was not met.
• Clinical input was inadequate as there was no reasonable assessment or management of the patient.
• The medical record was inadequate, lacking sufficient history, examination findings and clinical reasoning including details of medications.

In relation to MBS item 591, the Committee made findings based on one or more of the following:

• The MBS requirements were not always met, as the patient’s presenting condition did not require urgent assessment.
• Clinical input was inadequate including no reasonable assessment or management of the patient and prescribing of medications contrary to PBS requirements and therapeutic guidelines.
• The medical record was inadequate, lacking sufficient history, examination findings and clinical reasoning including details of medications.

In relation to MBS item 599, the Committee made findings based on one or more of the following: 

• The MBS requirements were not met, as services did not take place in unsociable hours and the patient’s presenting condition did not require urgent assessment.
• The medical record was inadequate, lacking sufficient history, examination findings and clinical reasoning including details of medications.
• The practitioner’s clinical input was inadequate including no reasonable assessment or management and prescribing of medications contrary to PBS requirements and therapeutic guidelines.

D. Federal Court

Yoong v Director, Professional Services Review [2025] HCADisp 266 B25/2025

The outcome of Dr Yoong’s Federal Court matter was previously reported in the July 2025 case outcomes. In August 2025, the outcome of Dr Yoong’s stay application to stay the operation of the notice to produce, which was the subject of the court proceedings, was reported in the case outcomes.

Dr Yoong had applied to the High Court for special leave to appeal against the decision of the Full Federal Court in Director, Professional Services Review v Yoong (No 2) [2025] FCAFC 106. On 6 November 2025, the High Court dismissed the special leave application on the basis that it lacked sufficient prospects of success.

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

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

F. Referrals to AHPRA (sections 106XA & XB)

One matter was referred to Ahpra in each of October and November 2025.