PSR Director's update for September 2026
A. Section 92 agreements effective in September 2026
The Chief Executive Medicare (Medicare) referred the following persons to PSR for review. The Director or an Associate Director entered into 18 agreements with persons under review under s 92 of the Act that came into effect in September 2026:
Medical practitioner
The Director reviewed this practitioner’s rendering of a prescribed pattern of services and their rendering of the following MBS item services:
- 23 (professional attendance lasting at least 6 minutes and less than 20 minutes)
- 721 (preparation of a general practitioner management plan (GPMP)
- 5023 (afterhours professional attendance lasting at least 6 minutes and less than 20 minutes, usually home visit)
- 30071 (skin biopsy)
- 31363 (malignant skin lesion excision)
- 45201 (single stage local flap)
- 91800 (video attendance lasting at least 6 minutes and less than 20 minutes)
- 91891 (phone attendance lasting at least 6 minutes)
- 92210 (video attendance in unsociable hours)
The Director had no persisting concerns in relation to the practitioner’s rendering of MBS item 5023, 31363, 45201 and 91891 services. In relation to the remaining items, the Director had persisting concerns that:
- the practitioner rendered 30 or more relevant phone services on each of 25 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 for services billed by the practitioner, including when the practitioner did not meet the minimum time requirement
- the practitioner did not always provide appropriate clinical management
- For example, on several occasions the practitioner ordered a biopsy where their peers would not have considered this clinically necessary to characterise the presenting lesion.
- the practitioner’s record keeping was not always adequate, including failing to keep progress notes and contemporaneous medical records for some MBS item 92210 and 91800 services.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23, 721, 30071, 91800 and 92210 and in providing services that constituted a prescribed pattern of services. The practitioner agreed to:
- be counselled by the Director
- repay $22,000 to the Commonwealth
- be disqualified from providing MBS item 599 (attendance for urgent assessment in unsociable hours) and 92210 services for 9 months.
General practitioner
An Associate Director reviewed this practitioner’s rendering of a prescribed pattern of services and their rendering of the following MBS item services:
- 36 (professional attendance lasting at least 20 minutes
- 721
- 723 (coordination of team care arrangements (TCAs))
- 2713 (professional attendance in relation to a mental health disorder lasting at least 20 minutes)
- 91891
- 93716 (phone attendance lasting at least 20 minutes to assess for COVID‑19 antiviral treatment)
The Associate Director had no persisting concerns in relation to the practitioner’s rendering of MBS item 91891 services. In relation to the remaining items, the Associate Director had persisting concerns that:
- the practitioner rendered 30 or more relevant phone services on each of 23 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
- the relevant MBS item requirements for services rendered by the practitioner, including minimum time requirements, were not always met
- the practitioner’s records were not always adequate, including where their notes were brief or based largely on auto-filled templates and not adequately individualised to each patient’s presentation
- the practitioner did not always provide adequate clinical input, including when rendering chronic disease management (CDM) services and prescribing oral COVID-19 antiviral medications.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 36, 721, 723, 2713 and 93716 and providing services that constituted a prescribed pattern of services. The practitioner agreed to:
- be reprimanded by the Associate Director
- be counselled by the Associate Director
- repay $132,000 to the Commonwealth
- be disqualified from providing MBS item 965 (prepare a GP chronic condition management plan), 967 (review a GP chronic condition management plan), 92029 and 92030 (video equivalents for 965 and 967) services for 12 months.
Obstetrician and gynaecologist
The Director reviewed this practitioner’s rendering of MBS item 91822 (initial video attendance more than 5 minutes) and 91823 (subsequent video attendance more than 5 minutes) services.
The Director had persisting concerns in relation to these services that:
- the practitioner sometimes billed these items to persons who were present during a consultation with the patient, where services were not always provided to or clinically indicated for the person other than the patient
- the practitioner’s clinical management was often inadequate, as they did not always correspond with referring practitioners during the review period as would be expected
- patients may have been charged an additional fee for services that were otherwise bulk-billed, contrary to legislative requirements.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 91822 and 91823. The practitioner agreed to:
- be reprimanded by the Director
- be counselled by the Director
- repay $160,000 to the Commonwealth.
General practitioner
An Associate Director reviewed this practitioner’s rendering of a prescribed pattern of services, and their rendering of MBS item 23, 36, 721, 723, 2715 (preparation of a GP mental health treatment plan lasting at least 20 minutes and less than 40 minutes), 91891, and 92028 (video attendance to review a GPMP or coordinate review of TCA) services.
The Associate Director had persisting concerns that:
- the practitioner rendered 30 or more relevant phone services on each of 25 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
- the MBS item requirements for these services were not always met, including where the practitioner did not always perform clinically relevant tasks or meet the minimum time requirements
- GP management plans, team care arrangements, and mental health treatment plans were often inadequate, insufficiently comprehensive, and not personalised to the particular patient, nor were patients always eligible for these services. Some of these services were also co-billed with services provided by a practice nurse where there was no separate nurse task assigned or carried out
- the practitioner’s records were not always adequate, including where their clinical notes were disorganised or unintelligible
- the practitioner’s clinical management was not always adequate, including where unnecessary blood tests were ordered or clinically relevant examinations were not carried out.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23, 36, 721, 723, 2715, 91891 and 92028, and in providing services that constituted a prescribed pattern of services. The practitioner agreed to:
- be reprimanded by the Associate Director
- repay $328,000 to the Commonwealth
- be disqualified from providing MBS item 965, 967, 92029 and 92030 services for 12 months
- be disqualified from providing MBS item 36, 91801 and 91900 services for 6 months.
Otolaryngologist
The Director reviewed this practitioner’s rendering of the following MBS item services:
- 104 (initial attendance in single course of treatment)
- 41693 (septal surgery)
- 41703 (functional sinus surgery)
- 41764 (nasendoscopy or sinoscopy or fibreoptic examination of nasopharynx and larynx)
The Director had no persisting concerns in relation to MBS item 104 services rendered by the practitioner. In relation to the remaining items, the Director had persisting concerns that:
- the practitioner’s clinical records were often inadequate, being insufficiently individualised to the patient and lacking relevant details of operations performed
- the reviewed records did not always reflect that all MBS item 41693 and 41703 services rendered by the practitioner were clinically indicated
- for some reviewed MBS item 47164 services, there were no clinical records to support that a service was performed.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 41693, 41703 and 41764. The practitioner agreed to:
- be reprimanded by the Director
- be counselled by the Director
- repay $229,500 to the Commonwealth.
General Practitioner
An Associate Director reviewed this practitioner’s rendering of a prescribed pattern of services, and their rendering of MBS item 91891 and 92210 services.
The Associate Director had persisting concerns in relation to the reviewed services that:
- the practitioner rendered 30 or more relevant phone services on each of 24 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
- the MBS requirements for these services were not always met, including:
- minimum time requirements
- requirements for phone attendances for MBS item 91891 services were not met
- requirements relating to urgency and timing of consultations relevant to MBS item 92210 services were not always met
- the practitioner did not always provide adequate clinical input and assessments, including not always following relevant clinical guidelines
- the practitioner’s records were often inadequate, with clinical notes that were heavily based on templates and did not contain sufficient personalised information relating to patients or clinical actions taken.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 91891 and 92210 and in providing services that constituted a prescribed pattern of services. The practitioner agreed to:
- be reprimanded by the Acting Director
- be counselled by the Acting Director
- repay $150,000 to the Commonwealth.
Medical practitioner
The Director reviewed this practitioner’s rendering of MBS item 23 and 92211 (video attendance in unsociable hours) services.
The Director had persisting concerns that:
- for services billed as MBS item 92211 the clinical records did not support that the patient’s presenting medical issues required urgent assessment
- the minimum time requirement for some MBS item 23 services was not met.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23 and 92211. The practitioner agreed to:
- be counselled by the Director
- repay $169,000 to the Commonwealth
- be disqualified from providing MBS item 92211 services for 12 months.
General practitioner
An Associate Director reviewed this practitioner’s rendering of a prescribed pattern of services, and their rendering of the following MBS item services:
- 36
- 5040 (afterhours attendance lasting at least 20 minutes)
- 91801 (video attendance lasting at least 20 minutes)
- 91802 (video attendance lasting at least 40 minutes)
- 91891
The Associate Director had persisting concerns in relation to the reviewed services that:
- the practitioner rendered 30 or more relevant phone services on each of 56 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
- the practitioner claimed services, including some in-person services, while not in Australia
- the practitioner did not provide all services billed, including where there were no corresponding records for services billed to Medicare
- the practitioner’s records were not always adequate, as some records could not be located for billed services or were otherwise non-contemporaneous and poor quality
- the MBS requirements for these services, including minimum time requirements and personal attendance requirement, were not always met.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 36, 5040, 91801, 91802 and 91891, and in providing services that constituted a prescribed pattern of services. The practitioner agreed to:
- be reprimanded by the Associate Director
- repay $183,718 to the Commonwealth
- be disqualified from providing MBS item 36, 5040, 91801, 91802 and 91891 services for 36 months.
General practitioner
An Associate Director reviewed this practitioner’s rendering of the following MBS item services:
- 24 (professional attendance lasting at least 6 minutes and less than 20 minutes, usually home visit)
- 707 (prolonged health assessment lasting at least 60 minutes)
- 721
- 731 (contribution by a GP to a multidisciplinary care plan for a patient in a residential aged care facility (RACF))
- 903 (participation by a GP in a medication management review for a RACF patient)
- 90035 (professional attendance at a RACF lasting at least 6 minutes and less than 20 minutes)
- 90043 (professional attendance at a RACF lasting at least 20 minutes)
An Associate Director also reviewed the practitioner’s prescribing of PBS items:
- 2622B (oxycodone hydrochloride 5 mg tablet, 20)
- 3132W (oxazepam 15 mg tablet, 25)
- 8867Q (buprenorphine 20 microgram/hour patch, 2).
The Associate Director had no persisting concerns in relation to the practitioner’s rendering of MBS item 721 and 903 services and their prescribing of PBS items 2622B, 3132W and 8867Q. In relation to the remaining items, the Associate Director had persisting concerns that:
- the MBS requirements were not always met, including where the practitioner did not attend to some patients, provide sufficient clinical input to meet the minimum time requirements, or perform relevant clinical actions required by the item descriptor
- the practitioner’s records were not always adequate, including where handwritten records were illegible or difficult to interpret.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 24, 707, 731, 90035 and 90043. The practitioner agreed to:
- be reprimanded by the Associate Director
- repay $245,000 to the Commonwealth
- be disqualified from providing MBS item 707 services for 12 months
- be disqualified from providing MBS item 90043, 91801 and 91900 (phone attendance lasting at least 20 minutes for a patient registered with MyMedicare) services for 3 months.
General practitioner
An Associate Director reviewed this practitioner’s rendering of a prescribed pattern of services and their rendering of MBS item 23, 36, 721, 723, 732 (review or coordinate a review of a GPMP or TCA), 2713 and 10997 (service provided by a nurse or Aboriginal or Torres Strait Islander health practitioner to patient with a chronic condition consistent with a GPMP or TCA) services.
The Associate Director was satisfied that exceptional circumstances existed that applied to the practitioner’s provision of services that formed the prescribed pattern of services. In relation to the specified MBS item services reviewed, the Associate Director had persisting concerns that:
- the practitioner’s records were not always adequate, with clinical entries containing insufficient information to explain the services provided
- the MBS item requirements were not always met, including:
- the records did not reflect that relevant minimum time requirements were met. For some services, the documentation indicated that the relevant service was provided by a nurse and that the practitioner did not personally attend to the patient
- the records for MBS item 10997 services did not always reflect that a separate service was provided by a practice nurse or Aboriginal or Torres Strait Islander health practitioner
- the records for MBS item 2713 services did not always reflect that the primary reason for the service was in relation to a mental health condition
- the documentation for MBS item 721, 723, and 732 services often lacked personalised and measurable goals, was not comprehensive, and did not evidence collaboration with two other providers where relevant to items 723 and 732.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23, 36, 721, 723, 732, 2713 and 10997. The practitioner agreed to:
- be reprimanded by the Associate Director
- be counselled by the Associate Director
- repay $750,000 to the Commonwealth
- be disqualified from providing MBS item 36 services for 6 months
- be disqualified from providing MBS item 965, 967, 92029 and 92030 services for 3 months.
General practitioner
An Associate Director reviewed this practitioner’s rendering of MBS item 707, 731, 5028 (afterhours attendance at a RACF lasting at least 6 minutes and less than 20 minutes), 5049 (afterhours attendance at a RACF lasting at least 20 minutes), 90035, and 90043 services and prescribing of PBS item 5061J (apixaban 2.5 mg tablet, 60).
The Director had persisting concerns in relation to the reviewed MBS and PBS item services that:
- the MBS item requirements were not always met, including:
- the practitioner did not always attend on the patient
- the minimum time requirements were not met where relevant, including when multiple services were co-billed for a patient
- the practitioner did not always undertake clinically relevant actions required by the MBS descriptor for item 707, 5028, 5049, 90035 and 90043 services
- the practitioner did not always contribute towards a care plan or conduct a review as required when MBS item 731 was billed
- the practitioner’s prescribing of PBS item 5061J was inappropriate as the PBS requirement that this medication only be prescribed to patients undergoing a total hip replacement was not always met and the prescribing of this medication was not always clinically indicated or relevant
- the practitioner’s records were not always adequate, including where the reviewed clinical notes did not contain sufficient information to explain the service.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 707, 731, 5028, 5049, 90035 and 90043 and PBS item 5061J. The practitioner agreed to:
- be reprimanded by the Associate Director
- be counselled by the Associate Director
- repay $200,000 to the Commonwealth
- be disqualified from providing MBS item 707, 731, 5049, 91900 and 92027 services for 12 months.
General practitioner
An Associate Director reviewed this practitioner’s provision of MBS item 23, 36, 721, 723, 732, 66596 (iron studies), and 91891 services.
The Associate Director had persisting concerns in relation to the reviewed services that:
- the MBS item requirements were not always met, including minimum time requirements, and eligibility for CDM services where services were billed for issues that were not chronic or terminal
- pathology services initiated by the practitioner were not always clinically indicated or appropriate
- the practitioner did not always provide sufficient clinical input based on the patient’s presentation, such as performing clinically relevant examinations that would be expected by peers
- the practitioner’s clinical records were not always adequate, consisting of unmodified, poorly personalised templates and did not contain sufficient information to explain the relevant service.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23, 36, 721, 723, 732, 66596 and 91891. The practitioner agreed to:
- be reprimanded by the Associate Director
- repay $360,000 to the Commonwealth
- be disqualified from providing MBS item 36, 91900, and 91801 services for 3 months
- be disqualified from providing MBS item 965, 967, 92029, and 92030 services for 6 months.
General practitioner
An Associate Director reviewed this practitioner’s provision of MBS item 23, 705 (long health assessment lasting at least 45 minutes and less than 60 minutes), 721, 723, 732, 900 (participation in a medication management review), and 10997 services.
The Director had persisting concerns in relation to the reviewed services that:
- the MBS item requirements were not always met, including:
- some attendance services did not meet time requirements, and the practitioner did not undertake all clinically required tasks. In some cases, the patients may not have been in attendance
- documentation for MBS item 705, 721, 723 and 732 services lacked comprehensive detail and personalisation to each patient with some documents closely resembling previous assessments and plans
- the practitioner did not always engage other providers on MBS item 723 services.
- at times, the practitioner co-billed services with attendance items in circumstances where both services were not clinically relevant, and billed item 10997 with health assessments and CDM services where a practice nurse performed tasks related to the assessments or CDM services
- the practitioner’s records were not always adequate, with the clinical notes containing insufficient information to explain or justify the service billed.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23, 705, 721, 723, 732, 900 and 10997. The practitioner agreed to:
- be reprimanded by the Director
- repay $290,000 to the Commonwealth
- be disqualified from providing MBS item 965 and 92029 services for 3 months
- be disqualified from providing MBS item 967 and 92030 services for 6 months
- be disqualified from providing MBS item 900 and 10997 services for 12 months.
General practitioner
An Associate Director reviewed this practitioner’s provision of the following MBS item services:
- 23
- 699 (heart health assessment lasting at least 20 minutes)
- 705
- 721
- 723
- 732
- 2713
- 57341 (computed tomography with surgery)
- 66596
- 91891
- 92024 (video attendance to prepare a GPMP)
- 92025 (video attendance to coordinate a TCA)
- 92028
The Associate Director had no persisting concerns in relation to the practitioner’s initiation of MBS item 57341 and 66596 services. In relation to the remaining items, the Associate Director had persisting concerns that:
- The MBS requirements were not always met, including:
- minimum time requirements were not met
- the practitioner did not undertake all clinically relevant actions required by the item descriptor
- the documentation for CDM services was not sufficiently comprehensive or individualised to the patient, and the practitioner did not consult with other practitioners where required
- the practitioner provided services that were not always clinically indicated, including rendering health assessment services opportunistically when a patient presented for other reasons, irrespective of whether they were required
- the practitioner’s clinical input was sometimes inadequate, including where they failed to address serious conditions patients presented with
- the practitioner’s records were not always adequate, including where records were frequently copied across multiple patients, files, and services, and where the practitioner failed to record sufficient information to explain what occurred at each service.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23, 699, 705, 721, 723, 732, 2713, 91891, 92024, 92025 and 92028. The practitioner agreed to:
- be reprimanded by the Associate Director
- be counselled by the Associate Director
- repay $350,000 to the Commonwealth
- be disqualified from providing MBS item 967 and 92030 services for 12 months
- be disqualified from providing MBS item 91891 services for 3 months.
General practitioner
An Associate Director reviewed this practitioner’s rendering of MBS item 23, 36, 707, 721, 723, 732, 14221 (long-term implanted device), 30192 (cryotherapy of 10 or more premalignant skin lesions), and 31367 (excision of malignant skin lesion) services.
The Associate Director had no persisting concerns in relation to the practitioner’s provision of MBS item 30192 and 31367 services. In relation to the remaining items, the Associate Director had persisting concerns that:
- the MBS requirements were not always met, including minimum time requirements for attendances
- In some instances, there was insufficient evidence that the claimed services were provided.
- For CDM services, documentation lacked comprehensive detail, patient specific goals, metrics, or managements plans.
- the practitioner’s clinical management of patients was not always appropriate, including failing to conduct relevant examinations and assessments where peers would consider such tasks clinically necessary
- the practitioner’s records did not always support that attendance items billed in association with procedural items were clinically relevant as a separate service
- the practitioner’s billing of MBS item 14221 was incorrect where the service was for the insertion of Zoladex implants
- the practitioner’s records were not always adequate, including where the clinical records did not contain sufficient detail to explain the billed service, and where records were non-contemporaneous.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23, 36, 707, 721, 723, 732 and 14221. The practitioner agreed to:
- be reprimanded by the Associate Director
- repay $390,000 to the Commonwealth
- be disqualified from providing MBS item 965, 967, 92029, 92030 and 14221 services for 12 months.
General practitioner
An Associate Director reviewed this practitioner’s provision of the following MBS item services:
- 36
- 707
- 721
- 723
- 732
- 11610 (measurement of ankle – brachial indices and arterial waveform analysis)
- 11707 (twelve-lead electrocardiography)
- 30071
- 66596
- 91891
The Associate Director had persisting concerns in relation to the reviewed services that:
- the MBS requirements were not always met, including:
- minimum time requirements
- in some cases, services may not have been provided by the practitioner, but rather a practice nurse
- documentation for health assessments and CDM services was insufficiently comprehensive and personalised, with unclear patient goals
- requirements to collaborate with other health provides were not always met.
- the practitioner’s records were not always adequate, including where notes were based on generic templates insufficiently individualised to the patient, did not adequately explain what occurred during services, and in some cases contained inconsistent information
- services provided were not always clinically indicated or relevant, including biopsies and pathology investigations
- the practitioner’s clinical management of patients was not always appropriate in circumstances where they did not adequately investigate the patient’s presenting condition.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 36, 707, 721, 723, 732, 11610, 11707, 30071, 66596 and 91891. The practitioner agreed to:
- be reprimanded by the Associate Director
- be counselled by the Associate Director
- repay $405,000 to the Commonwealth
- be disqualified from providing MBS item 707, 965, 967, 30071, 92029 and 92030 services for 6 months
- be disqualified from providing MBS item 36, 91801 and 91900 services for 12 months.
General practitioner
An Associate Director reviewed this practitioner’s rendering of a prescribed pattern of services and their rendering of MBS item 23, 91800, 91801, 91891, and 92734 (sexual health phone attendance) services.
The Associate Director had no persisting concerns in relation to the practitioner’s rendering of MBS item 23 services. In relation to the remaining items, the Associate Director had persisting concerns that:
- the practitioner rendered 30 or more relevant phone services on each of 33 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 in the following circumstances:
- the practitioner rendered telehealth services in circumstances where they were not the patient’s usual medical practitioner
- the minimum time requirements were not always met
- the practitioner did not attend the patient by telehealth when rendering MBS item 91801 services
- services rendered by the practitioner as MBS item 92734 did not always relate to blood borne viruses, sexual or reproductive health.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 91800, 91801, 91891 and 92734, and in providing services that constituted a prescribed pattern of services. The practitioner agreed to:
- be reprimanded by the Associate Director
- be counselled by the Associate Director
- repay $40,000 to the Commonwealth.
General practitioner
An Associate Director reviewed this practitioner’s rendering of a prescribed pattern of services and their rendering of MBS item 23, 5020 (afterhours attendance of at least 6 minutes and less than 20 minutes), 91800, and 91891 services.
The Associate Director had no persisting concerns regarding the practitioner’s rendering of MBS item 5020 services. In relation to the remaining services reviewed, the Associate Director had persisting concerns that:
- the practitioner rendered 30 or more relevant phone services on each of 30 days during the review period, and exceptional circumstances did not exist that affected the rendering of services on those days
- the MBS requirements, including the respective minimum time requirements were not always met
- the practitioner at times inappropriately billed telephone and video services interchangeably despite the service provided
- the practitioner’s records were not always adequate, including that for some reviewed services no clinical records could be located, and in other cases the records were not sufficiently detailed to explain the service provided
- the practitioner’s clinical management of patients was not always appropriate, including providing treatments where they were not clinically indicated and cryotherapy services that did not meet clinical standards.
The practitioner acknowledged having engaged in inappropriate practice in connection with providing MBS items 23, 91800 and 91891, and in providing services that constituted a prescribed pattern of services. The practitioner agreed to:
- be reprimanded by the Associate Director
- be counselled by the Associate Director
- repay $115,000 to the Commonwealth.
B. No further action decisions
There were no decisions to take no further action in relation to a review in September 2026.
C. PSR Committee final determinations
On 18 September 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 rendering of MBS item 36, 44 (professional attendance lasting at least 40 minutes), 703 (standard health assessment lasting at least 30 minutes and less than 45 minutes), 721, 723, 2715, and 10660 (professional attendance more than 10 minutes for in‑depth advice on COVID-19 vaccination) services during the review period. The practitioner was also found to have engaged in inappropriate practice in prescribing PBS item 1916W (prednisolone 25 mg tablet, 30)
The Determining Authority directed that the practitioner:
- be reprimanded
- repay $300,000 to the Commonwealth, which reflects approximately 90% of the Medicare benefits paid for the services in connection with which the practitioner was found to have engaged in inappropriate practice during the review period
- be disqualified from rendering MBS items 703, 965, 967, 92029, 92030, 2715 and 92116 (video attendance to prepare a GP mental health treatment plan lasting at least 20 minutes and less than 40 minutes) for 18 months
- be disqualified from rendering MBS items 36 and 44 for 6 months.
Where the Committee made findings of inappropriate practice, its reasons included that the practitioner’s medical records were inadequate, including that:
- The practitioner relied heavily on templates and failed to adequately personalise each entry for the specific patient and service.
- The practitioner’s notes for the date of service often did not accurately represent what occurred in the service, as parts of the template had not been removed or changed to suit the specific service provided.
- The practitioner would often inaccurately record basic patient metrics, such as rounding up for blood pressure readings.
The Committee also found that:
- The practitioner sometimes inappropriately billed an attendance item as well as another item, such as a chronic disease management item, on consecutive days when only one service was provided.
- The practitioner billed attendance items when performing skin lesion excisions and for each occasion of routine aftercare and billed a procedural item on the day sutures were removed.
In relation to MBS item 36 and 44 services, the Committee made findings based on one or more of the following:
- The practitioner did not meet all the MBS requirements, including the relevant time requirements for many of the services.
- The practitioner’s clinical input for each of the services was not always adequate, including that they did not perform clinically relevant physical examinations or assessments of the patient’s mental state, and medications were prescribed where they were not clinically indicated.
- If the practitioner had met the minimum time requirements or had undertaken all clinically relevant actions, the record failed to reflect this.
In relation to MBS item 703 services, the Committee made findings based on one or more of the following reasons:
- The practitioner billed MBS item 703 when conducting diabetes risk assessments or dementia assessments.
- The minimum time requirement of 30 minutes was not met.
- The practitioner sometimes billed MBS item 703 when a patient was not eligible for a health assessment.
- The practitioner did not satisfy all the MBS requirements, as there was often no detailed information collection, no adequate assessment of the patient’s medical condition/s and physical, psychological and social function, or no preventative health care management plan individualised for the patient.
- If the practitioner had met the MBS requirements and provided sufficient clinical input, the medical record is inadequate for failing to reflect it.
In relation to MBS item 721 and 723 services, the Committee made findings based on one or more of the following:
- For all services, the MBS requirements were not met because the general practitioner management plans (GPMPs) and team care arrangements (TCAs) were generic templates not adequately individualised for the patient, did not include what the practitioner’s role was as the patient’s regular GP in managing the patient’s chronic condition, and there was no two-way communication between the practitioner and other health care providers for MBS item 723.
- For some services, the patient did not appear to personally attend on the date of service.
- For some services, the services were not clinically relevant as there were no individualised goals or actions to manage the chronic condition, or any details about how other health care providers would assist with managing the patient’s chronic condition/s.
For MBS item 2715 services, the Committee made findings based on one or more of the following:
- The practitioner did not meet the relevant MBS requirements, including the minimum time requirement of 20 minutes, the general practitioner mental health treatment plans were generic templates with no meaningful information specific to the patient, and the treatment options included in the plan were often generic and did not include details of how the patient was to access the treatment.
- The practitioner’s clinical input was inadequate, including where the practitioner had noted clinically inaccurate matters with no relevant history or without further explanation of the symptoms.
- The practitioner sometimes billed 2 MBS items for the one service.
For MBS item 10660 services, the Committee made findings based on one or more of the following:
- For all of the services reviewed, there was no clinical need to provide an MBS item 10660 service because the co‑billed vaccination item sufficiently accounted for the service that was provided.
- The practitioner incorrectly co-billed vaccination items based on whether it was the first or subsequent dose of the vaccine.
For PBS item 1916W services, the Committee made findings based on the practitioner’s clinical input being inadequate for the patient’s presentation and the prescribing of prednisolone, and that the prednisolone was not clinically indicated. If the practitioner had provided adequate clinical input, the medical record is inadequate for failing to reflect it.
D. Federal Court
There were no Federal Court decisions relating to PSR matters in September 2026.
E. Referrals to the major non-compliance (fraud) division (89A & 106N)
No matters were referred to the major non-compliance (fraud) division in September 2026.
F. Referrals to Ahpra (106XA/B)
No matters were referred to Ahpra in September 2026.