PSR Director's update for January and February 2026

Published date

23 March 2026

A. Section 92 agreements effective in January and February 2026

Two agreements entered into by the Director or an Associate Director and persons under review (under section 92 of the Act) came into effect in January and February 2026.

General practitioner

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

36 (attendance lasting at least 20 minutes)
707 (attendance for a prolonged health assessment lasting at least 60 minutes)
5067 (attendance at a residential aged care facility lasting at least 40 minutes).

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

23 (attendance lasting less than 20 minutes)
36
707
721 (preparation of a general practitioner management plan (GPMP))
723 (coordination of team care arrangements (TCAs))
732 (review of a GPMP or TCA)
5067
91891 (telehealth attendance lasting at least 6 minutes).

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

the practitioner’s record keeping was inadequate, including where they did not record sufficient detail for a service and where the record consisted of templates that were inadequately personalised
the MBS requirements, including minimum time requirements where relevant, were not always met
the practitioner’s records did not always provide clinical reasoning for prescriptions issued to patients
the practitioner did not always provide sufficient clinical input. For example, the clinical records did not always reflect that they provided sufficient clinical recommendations as part of health assessment services, or did not undertake a meaningful review when billing MBS item 732 services.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 36, 707, 721, 723, 732, 5067 and 91891 services. The practitioner agreed to repay $300,000, and to be disqualified from providing MBS item 965, 967, 92029 and 92030 services (being the replacement in-person and telehealth items for MBS items 721, 723 and 732, which have been superseded) for 9 months.

General practitioner

During the review period, the practitioner rendered the largest volume of MBS items 23 services in Australia, and also rendered MBS item 723 and 5020 (after-hours attendance lasting between 6 and 20 minutes) services in excess of 99% of their peers.

An Associate Director reviewed this practitioner’s rendering of MBS item 23, 721, 723, 732 and 5020 services, and the practitioner’s rendering of a prescribed pattern of services (rendering of 80 or more relevant services on each of 20 or more days in a 12‑month period). The Associate Director had no persisting concerns in relation to MBS item 23 services, but had persisting concerns that:

the practitioner rendered 80 or more relevant services on each of 203 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
for some MBS item 5020 services, the practitioner billed the relevant item more than once for a single service to the same patient on the same day
the MBS requirements were not always met for MBS item 721, 723 and 732 services, including where services were provided to patients who were ineligible to receive them or where the practitioner did not consult with at least two other healthcare providers when coordinating or reviewing TCAs. In some cases, the Associate Director was concerned that the practitioner did not attend on the patient when these services were rendered. Most of the reviewed MBS item 721, 723 and 732 services (CDM services) were billed on the day after the patient attended for a consultation when it was likely that the CDM service was conducted on that prior day, in order to avoid the prohibition on billing professional attendances and CDM services on the same day.

The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS item 721, 723, 732 and 5020 services, and in providing services that constituted a prescribed pattern of services. The practitioner agreed to repay $380,000, to be disqualified from providing MBS item 965, 967, 92029 and 92030 services (being the replacement in-person and telehealth items for MBS items 721, 723 and 732, which have been superseded) for 12 months, and will be reprimanded by the Associate Director.

B. No further action decisions

Surgeon

During the review period the practitioner rendered MBS item 55848 (musculoskeletal ultrasound) and 46370 (percutaneous fasciotomy) services in excess of 99% of their peers.

The Director reviewed a random sample of services rendered as MBS items 46336, 46370, 47903, 31350, 46363, 49124 and 55850. After reviewing the practitioner’s records, the 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.

C. PSR Committee final determinations

PSR Committee regarding a radiologist

On 28 January, a final determination came into effect regarding a radiologist. In the final report of the PSR Committee, the practitioner was found to have engaged in inappropriate practice in connection with the following MBS item services provided during the review period:

56625 (CT- scan of extremities)
56412 (CT- scan of pelvis only)
57007 (CT- scan of brain and chest)
61529 (whole body FDG PET study)
61647 (whole body Ga DOTA peptide PET study)

The Determining Authority directed that the practitioner:

be reprimanded
be counselled
repay the amount of $140,000 to the Commonwealth.
- This reflects approximately 100% of the Medicare benefits paid for the MBS item 56625 services, and individual services provided as MBS items 56412, 57007, 61529 and 61647 in connection with which the practitioner was found to have engaged in inappropriate practice.

In relation to the MBS item 56625 services, the Committee made findings based on one or more of the following:

There was often no valid request for a diagnostic CT scan of the extremities.
Many of the services were not clinically indicated based on the patient’s presentation.
The practitioner did not always make a report for each CT scan they billed.

In relation to MBS item 57007, 56412, 61529 and 61647 services, the Committee made findings based on one or more of the following:

There was no valid request for the diagnostic CT scans of the brain and chest and of the pelvis as requests were for PET-CT scans with diagnostic CT scans being prepopulated onto the request form as ‘+/- diagnostic CT scan’.
For many services, the services were not clinically relevant or required, including many services where a PET-CT scan was requested that covered the pelvis, brain and chest, and a diagnostic CT scan over the same area was also performed.
The practitioner rendered services to patients whose medical record suggested that they did not meet the eligibility criteria for the scans for which they were billed.

PSR Committee regarding a medical practitioner

On 2 January 2026, 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 PBS items 1115Q (betamethasone (as dipropionate) 0.05% cream) and 8254K (amoxicillin 875mg and clavulanic acid 125mg tablet), and the following MBS item services provided during the review period:

54 (attendance between 25 and 45 minutes)
721
723
732
2713 (attendance in relation to mental disorder lasting at least 20 minutes)
2715 (preparation of GP mental health treatment plan lasting between 20 and 40 minutes)
5020
5040 (afterhours attendance lasting at least 20 minutes)
91804 (COVID-19 video attendance lasting between 25 and 45 minutes)
91812 (COVID-19 phone attendance lasting between 5 to 25 minutes)
91813 (COVID-19 phone attendance lasting between 25 to 45 minutes)

The practitioner was directed to:

be reprimanded
be counselled
repay $630,000 to the Commonwealth
- This reflects approximately 90% of the Medicare benefits paid for the class of MBS items 54, 721, 723, 732, 2713, 2715, 2717, 5020 and 5040 services in connection with which the practitioner was found to have engaged in inappropriate practice during the review period.
be disqualified from rendering the following items for 12 months:
- 37, 5040, 5043, 90043 (and telehealth equivalents 91801 and 91900)
- 44, 47, 5060, 5043, 90051, 90054 (and telehealth equivalents 91802 and 91910)
- 123, 124, 5071, 5076 (and telehealth equivalent 91920)
- 2713 (and telehealth equivalents 92115 and 92127)
- 965 (and telehealth equivalent 92029)
- 967 (and telehealth equivalent 92030)
- 2700, 2715 (and its telehealth equivalents 92112, 92116)
- 2701, 2717 (and its telehealth equivalents 92113, 92117).

In relation to MBS item 54, 2713, 5020 and 5040 services, the Committee made findings based on one or more of the following:

Many consultations where MBS item 54 was claimed did not meet the minimum time requirement of 25 minutes and records were often inadequate, not appropriately individualised to the patient and had insufficient clinical information to justify the length of the consultation.
The practitioner’s clinical input was insufficient, including where the practitioner undertook a tick-box mental health history and did not always take an individualised history or use any type of examination tool.
Many services billed under items 5020 and 5040 did not meet the MBS requirements for after-hours billing, as they were provided after 6:00pm as opposed to after 8:00pm. The records also lacked clinical information to justify the billing of a Level B attendance in the case of item 5020 or meet the minimum time requirement of 20 minutes in the case of item 5040.
For MBS item 2713 services, the Committee did not accept that the services would have met the minimum time requirement of at least 20 minutes, as there was little documentary evidence that the practitioner had provided talk-therapy, or had made or reviewed a management plan.

In relation to MBS item 721, 723 and 732 services, the Committee made findings based on one or more of the following:

For many services, there was no relevant documentation included in the patient record to support the provision of a GPMP or TCA.
Where located, none of the GPMPs or TCAs were comprehensive and did not always include the required information, including:
- some had no diagnosed medical conditions recorded
- listed goals were generic and not individualised to the patient
- there were often no baseline assessments of the patient’s condition
- numerous plans were duplicates of previous plans
- actions for the plans were rarely included
- for some TCAs, there were not 2 other providers listed and there was little indication that the practitioner collaborated with the other providers.

In relation to MBS item 2715 and 2717 services, the Committee made findings based on one or more of the following:

The written plans and record entries did not include an adequate assessment of the patient’s mental disorder. Rather, there was a tick-box indication of symptoms.
Patients’ treatment goals were often generic and identical across patients, and were incapable of being measured.

In relation to MBS item 91804, 91812 and 91813 services, the Committee made findings based on one or more of the following:

There was often a lack of clinical information in the entry for service to reflect that each attendance met the minimum time requirements.
Many of the records did not indicate that the service was a telephone consultation.

In relation to PBS items 1115Q and 8254K, the Committee made findings based on one or more of the following:

The practitioner’s records often lacked adequate clinical information to provide a clinical indication for the prescription given on the date of service, including that the records did not often include sufficient patient history relating to the PBS item being prescribed.

PSR Committee regarding a general practitioner

On 9 January 2026, 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 practice in connection with the following MBS items provided during the review period:

36
707
721
723
732
31363 (excision of malignant skin lesion)
31367 (excision of malignant skin lesion)
41647 (ear toilet)
45201 (skin flap to close excision of malignant or non-malignant skin lesion)
90043 (attendance at RACF lasting at least 20 minutes)

The practitioner was directed to:

be reprimanded
be counselled
repay $400,000 to the Commonwealth
- this reflects approximately 100% of the Medicare benefits paid for the class of MBS items 36, 707, 721, 723, 732, 31363, 31367, 41647, 45201 and 90043 services in connection with which the practitioner was found to have engaged in inappropriate practice during the review period
be disqualified from rendering the following MBS items for 6 months
- 36 (and telehealth equivalent 91801 and 91810)
- 31363
- 31367
be disqualified from rendering the following MBS items for 12 months
- 707
- 965
- 967
- 92029
- 92030.

In relation to MBS item 36 and 90043 services, the Committee made findings based on one or more of the following:

The practitioner failed to keep adequate and contemporaneous records, including where notes were very brief and often did not include a detailed history, details of clinically relevant actions, management plans or preventative health advice, and some services did not include any clinical notes.
The practitioner’s clinical input was sometimes inadequate because he did not undertake clinical actions that his peers would expect to be undertaken.
The MBS requirements were not always met, including where the service provided was for a straightforward presentation which would not have required at least 20 minutes of clinical input.

In relation to MBS item 707 services, the Committee made findings based on one or more of the following:

There was insufficient clinical input to reflect that the health assessments lasted at least 60 minutes even accounting for the time spent by the nurse as well as the practitioner.
When the practitioner billed this item for nursing home patients, there were minimal or no records of an attendance by the practitioner, suggesting that the health assessments were conducted by the RACF staff with little or no input from the practitioner.
The MBS requirements were not always met as the practitioner did not always provide a comprehensive health assessment or management plan.
The practitioner’s clinical input was inadequate, or the record failed to reflect that they had provided adequate clinical input.

In relation to MBS item 721, 723 and 732 services, the Committee made findings based on one or more of the following:

The MBS requirements were not always met, including where the documentation (GPMPs and TCAs) were not comprehensive written plans but were templated and not individualised to the patient, and the TCAs often did not include evidence of two-way communication with other health care providers.
The practitioner’s clinical input was not adequate because the GPMP and TCA goals and plans were often generic and not specific to the patient, the practitioner did not consult with other health care professionals for TCAs, and there was little or no change made to the GPMPs or TCAs when a review was done.
The practitioner’s record keeping was inadequate, and the records do not indicate that the practitioner discussed the patient’s goals or plans with them.

In relation to MBS item 31363, 31367 and 45201 services, the Committee made findings based on one or more of the following:

The practitioner often co-billed the skin lesion items with attendance items despite no separate clinical input being provided other than the excision of the lesions.
The practitioner’s clinical input was inadequate, including where the practitioner did not appear to follow up with the patient when appropriate after biopsy results were received or margins were not clear, or when the practitioner prescribed amoxicillin to prevent infection when it is not indicated for this purpose.
The practitioner’s record keeping was inadequate because there was often no record that the practitioner sufficiently explained the procedure to the patient, or there are no details of the lesion which was excised including size, location or description.

In relation to MBS item 41647 services, the Committee made findings based on one or more of the following:

The MBS requirements were not met, because the practitioner did not use an operating microscope or undertake a microscopic inspection of the patient’s tympanic membrane.
Services were often co-billed with MBS item 23 where there was no clinical input other than the ear toilet procedure to justify billing this item.
The practitioner’s record keeping was inadequate because there was an insufficient explanation about the procedure, the equipment and process used for the ear toilet in the medical record, and no record of an inspection of the tympanic membrane.

PSR Committee regarding a general practitioner

On 28 January, 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 practice in connection with the following MBS items provided during the review period:

23
197 (acupuncture attendance lasting at least 20 minutes)
721
723
5020

The practitioner was directed to:

be reprimanded
be counselled
repay $580,000 to the Commonwealth
- this reflects nearly 100% of the Medicare benefits paid for the class of MBS items 23, 197, 721, 723 and 5020 services in connection with which the practitioner was found to have engaged in inappropriate practice during the review period
be disqualified from rendering the following MBS items for 36 months:
- 193
- 195
- 197
- 199
be disqualified from rendering the following MBS items for 12 months:
- 965
- 967
- 5020
- 92029
- 92030
- 92060
- 92061.

In relation to MBS item 23 and 5020 services, the Committee made findings based on one or more of the following:

The entries for the item 23 and 5020 services did not provide enough information to indicate that the practitioner took a patient's relevant history, examined the patient, implemented a management plan, or provided preventative health care advice as required by the MBS item descriptors.
The insufficient clinical information noted in the practitioner’s records did not meet the level of clinical input expected for an MBS item 23 service.
The practitioner’s management of prescribing drugs of dependence during these services was not always acceptable to peer expectations in terms of undertaking and recording actions clinically relevant in the circumstances of the presentation.

In relation to MBS item 197, the Committee made findings based on one or more of the following:

The MBS requirements were not always met including where the practitioner did not record an adequate history of the patient’s presenting complaint or there was no examination or exploration of symptoms recorded.
The practitioner did not include sufficient clinical information to reflect the minimum time requirements and the clinical input expected.
There was often no clinical basis for acupuncture services, and it was not always evident that the practitioner had the patient’s consent to perform acupuncture services.

In relation to MBS item 721 and 723 services, the Committee made findings based on one or more of the following:

The practitioner’s GPMPs and TCAs were not comprehensive plans for managing chronic disease as they did not include specific, measurable and achievable goals or were not sufficiently individualised to the patient.
The practitioner’s approach to MBS item 721 and 723 services lacked the clinical input expected by peers.
The MBS requirements were not always met including two-way collaboration with other health care providers for MBS item 723 services.

PSR Committee regarding a general practitioner

On 12 January 2026, 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 practice in connection with the following MBS items provided during the review period:

23
36
10660 (in depth clinical advice on COVID-19 vaccine)
91891
92024 (telehealth attendance for preparation of GPMP)
92025 (telehealth attendance to coordinate the development of TCA)
92028 (telehealth attendance to review GPMP or TCA)

The practitioner was directed to:

be reprimanded
be counselled
repay $575,000 to the Commonwealth
- this reflects approximately 100% of the Medicare benefits paid for the class of MBS items 23, 36, 10660, 91891, 92024, 92025 and 92028 services in connection with which the practitioner was found to have engaged in inappropriate practice during the review period
be disqualified from rendering the following MBS items for 12 months:
- 36, 44, 5040, 5060, 91801, 91802, 91900 and 91910
be disqualified from rendering the following MBS items for 24 months:
- 965, 92029, 967 and 92030.

In relation to MBS item 23, 36 and 91891 services, the Committee made findings based on one or more of the following:

The practitioner did not meet the MBS requirements, including failing to take the patient’s history where clinically relevant, perform clinically relevant examinations, arrange clinically relevant investigations, and provide adequate management plans.
The practitioner’s clinical management was also inadequate including failing to address a patient’s significant medical history, failing to provide a patient with available test results, prescribing medication without a current clinical indication, failing to check a patient’s allergies prior to prescribing medication, and failing to take a sufficient history and perform an examination before deciding not to prescribe antibiotics.
The practitioner failed to keep adequate and contemporaneous records for each service, with the content of records often being substantially identical to the record from previous services.
There was insufficient clinical input to meet the relevant MBS time requirements for MBS item 36 and 91891 services.

In relation to MBS item 10660 services, the Committee made findings based on one or more of the following:

For a number of services, the record did not show that the practitioner personally attended on the patient and that a nurse undertook the service.
If the practitioner did perform any of these services and for most of the remaining services, the patient did not require in-depth clinical advice regarding the COVID-19 vaccine in line with the requirement set out in the MBS item descriptor.
If the patient did require such advice, the practitioner did not attend the patient for the required time and did not provide the requisite advice.

In relation to MBS item 92024, 92025 and 92028 services, the Committee made findings based on one or more of the following:

The MBS requirements were not always met as the practitioner did not always appear to speak with the patient on the telephone on the date of service.
Without speaking with the patient, it was not possible for the GPMP goals to be agreed with the patient and the patient to participate in creating the plans, the TCA goals and targets to be agreed with the patient and the patient consent to releasing information to relevant providers, and for the patient’s progress against goals and achievement of tasks to be assessed.
The GPMP documents were not comprehensive care plans as not all of the patient’s relevant conditions and needs were addressed.
There was not always two-way communication with at least 2 other healthcare providers
The TCA documents were generic and did not always describe the specific treatment and service goals for the patient and the specific treatment and services that collaborating providers were to provide to the patient.

The original GPMP and TCA documents were not sufficiently amended to reflect that the practitioner had undertaken a meaningful review.

D. Federal Court

There were no federal court decisions handed down in January or February 2026.

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

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

F. Referrals to Ahpra (106XA/B)

One matter was referred to Ahpra in January and February 2026.