MBS Review

The Medicare Benefits Schedule Review is the major policy issue facing the medical profession since its announcement in April 2015. The MBS Review Taskforce is considering how the more than 5,700 items on the MBS can be aligned with contemporary clinical evidence and practice and improve health outcomes for patients. The review is clinician-led and there are no targets for savings attached to the review.

The AACP is responding to consultation documents and closely monitoring particular areas of concern, and will update members through our normal communication channels. If you wish to provide comments on the review please email secretariat@aacp.org.au.

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Following are AACP updates for our members on the MBS Review.

The taskforce completed its work on 30 June 2020.

As at July 2021, the Australian Government has:

  • agreed to 811 taskforce recommendations
  • implemented more than 580 recommendations, involving changes to over 3,000 MBS items.
The MBS Review Taskforce recently released its final report that was submitted to the Minister. This was an additional report that the Taskforce itself decided to present and was in addition to the many reports of each of the MBS Review Clinical Committees. The Taskforce report set out recommendations on wide-ranging matters including:
  • the future role of consumers in review of the MBS, supporting consumers in gaining a better understanding of diagnosis, treatment options and risks and benefits of treatment
  • the role of the Expanded Medicare Safety Net
  • establishment of a Medical Fee Complaints Tribunal
  • informed financial consent
  • continuous review of the MBS (including audit, integrity and appropriate use monitoring)
  • introduction of mandatory training and assessment in the use of the MBS
  • introduction of standardised health outcome and
The AACP had two meetings with the Chair of the Taskforce to discuss this report and recommendations and the AACP’s submission on the recommendations.
A copy of the Taskforce Report is available here; a copy of the AACP’s initial response is available here. The AACP anticipates making a further follow up response on the Taskforce’s recommendations.
With the arrival of 2020, the MBS Review is now in its fifth year. As you may recall the AACP’s response to the Specialist and Consultant Physician Consultations Clinical Committee (SCPCCC) report was considerable concern about the proposed blanket time tiering of all attendance items, with no evidence provided by the Review that such a radical change would be of benefit to the system.
The AACP has recently written to the Minister for Health about these issues and at the same time has pointed out that the recommendations of the recent Psychiatry Clinical Committee (PCC) if implemented would introduce a raft of new anomalies into the MBS. The whole approach is lacking in consistency and, in the case of psychiatric services, appearing to ignore the fact that consultant paediatricians in particular provide many services that are comparable to those considered by the PCC, but which are now proposed to be treated differently. The MBS Review has said a lot about equality across specialties for the same services and yet its own recommendations are now ignoring this concept.

The MBS Review’s Specialist and Consultant Physician Consultations Clinical Committee (SCPCCC) Report has now been released for review and consultation with the profession. >Download a PDF of the Report.

The major concerns of the AACP are the recommendations to remove the most commonly used consultant physician attendance and assessment items (e.g. 110, 116, 119, 132, 133, 141, 143) and replace them with a time-tiered item structure. The AACP remains committed to the retention of the current item structure where complexity has been factored into the item structure. There are a number of other issues in the report already identified that require responses.

There are a number of other MBS Review reports currently open for consultation; if you wish to see these, please click hereto be directed to the MBS Review website.

Submissions to the SCPCCC Report have been extended to 28 June 2019.

The Government’s MBS Review Taskforce has recently established the main committee of interest to the AACP, namely the Specialist and Consultant Physician Consultations Clinical Committee (SCPCCC).  The committee’s membership includes Dr Katie Ellard, who is also a member of the AACP Council. It should be noted that members of MBS Review committees are not appointed on the basis of organisational representation but for their individual expertise.

The Taskforce is expecting a report from the SCPCCC well before the end of this year so this means consideration of attendance items will be undertaken in a very short period of time compared with many of the other clinical committees. This means we will be responding to short time frames for submissions and feedback.

The AACP sought input from the AACP members on the following matters:

MBS telehealth items currently have a 50% loading to recognise the additional time and professional complexity associated with providing telehealth services. There are some views that as telehealth is now well-established a loading is no longer appropriate.

The matter of referrals is being discussed and one of the issues that has been raised is that of indefinite referrals.

The matter of making all attendance items time based is raised in all MBS reviews. The AACP does not support routine time-tiering as it does not consider this represents best practice.

The AACP will address issues on which it has previously made submissions to government, including:

  • Increased access to item 133 (the longer follow up item)
  • A longer attendance item
  • The need for access by patients of general physicians to the geriatric assessment items, particularly in rural and regional areas where there are few geriatricians
  • Being able to directly refer a patient to an allied health provider after an item 132 attendance
  • Specialist referrals being valid for six months (not three months)

The other MBS Review matter that may be of interest to members is the Oncology Clinical Committee (OCC) Report.

Following is an AACP update on the Federal Government reviews that are currently underway. Three are particularly relevant to consultant physicians:

(i)    the MBS Review, which is being overseen by a Taskforce, chaired by Prof Bruce Robinson, Dean of Medicine at the Sydney University Medical School;

(ii)    the Primary Health Care Advisory Group (PHCAG), chaired by Dr Steve Hambleton, which is undertaking a review inter alia to “investigate options to provide better care for people with chronic and complex illness and innovative care and funding models”, and

(iii)   a review of Medicare compliance rules and benchmarks which will also commence shortly. (The other reviews include a national approach to mental health, e-health, a review of practice incentive payments for GPs, the role of private health insurers and the reform of Federation discussions.)

Each of these Reviews is likely to have a significant impact on clinical practice, both in terms of the ongoing review of MBS items, but also the proposition that funding arrangements may change away from the traditional fee for service to different funding models. The AACP is concerned that the ability of consultant physicians and consultant paediatricians to provide the best quality care for their patients is maintained.

AACP involvement in these Reviews

Overall, it will be important for the AACP to have close involvement in both the MBS Review and the PHCAG’s consultations. There are a number of issues that potentially affect consultant physician and consultant paediatrician (CPP) practice, not the least of which is the proposition that MBS items may be “bundled” and the concept of the “health care home” for those with chronic and complex conditions that would see greater oversight for GPs in the delivery of services to those patients whose care needs are more complex and may be more appropriately managed by a consultant physician or paediatrician.

The AACP strongly supports the concept of team care arrangements where they can assist in improving patient care. However, they are but one option in the appropriate management of patient care.

In relation to the “discipline group” process, the AACP has already put forward a number of names of possible “discipline group” members at the Adelaide MBS Review Forum and will seek further discussions with the Taskforce about its consideration of the wide range of items that relate to services provided by consultant physicians and paediatricians.

The AACP would welcome input from the consultant physician / consultant paediatrician specialty societies about specific issues that need to be addressed.

Please keep in touch with the AACP about the MBS Review: email the AACP at secretariat@aacp.org.au to contact the Secretariat or Dr Bill Heddle, the Chair of the AACP’s MBS Review Committee.

Following on from a series of MBS Review Forums, the AMA convened its own Forum on 19 August 2015 to provide an opportunity for discussion about concerns about the Review and also for the Taskforce Chair, Professor Bruce Robinson, to provide an update and answer questions. The Australian Association of Consultant Physicians was represented by a senior member of AACP Board, Dr Richard Whiting, a consultant geriatrician.

The following summary from the meeting on the 19th sets out a number of the concerns about the Review and includes points from the presentation by Professor Bruce Robinson.

The AACP will be making submissions to both the MBS Review and the Primary Health Care Advisory Group’s consultations and will be seeking ongoing involvement in relevant discipline groups concerning consultant physician and consultant paediatrician services.

We invite you to contact the AACP on matter concerning the Review.

Key points and concerns raised in presentations and by specialty society / college participants about the MBS Review, its rationale and the process to date, included:

  • the lack of detailed explanation for the Review and the exclusion of matters that could usefully be included such as the relationship between the public and private sectors and the interaction with primary care providers (see Table 1 at the end of this document which sets out what is “in scope” and what is “not in scope” for the MBS Review)
  • as has been widely discussed, Government is concerned about increased Medicare outlays and the sustainability of health costs (although it was noted that Australia’s expenditure is average compared with OECD countries)
  • whether there will be adequate resources within the Department of Health to conduct this Review in an efficient and effective manner
  • the fact that the lack of new and amended MBS items in recent years (and the difficulty of the current process of achieving change in item descriptors or securing funding for new services) that has exacerbated the problem of the Schedule being out of date
  • the significant role of up to 100 discipline group reviews of all MBS items and many aspects of that process, including the involvement of individuals in the discipline group reviews at the expense of input from specialty societies and associations (although Prof Robinson sought to allay these concerns by indicating that discipline group members could consult with their organisations where they found difficulty in the material being considered, and also when there are draft recommendations for consideration), and whether discipline group membership will be sufficiently representative of practising specialists
  • the promotion of the Ontario Rapid Review Model for use by the discipline group reviews which will rely on the availability of high level evidence that is not routinely available – and further, where there is no appropriate literature, the review process can shift away from a “clinical review” model to a “policy” or “compliance” review (see summary of the Health Quality Ontario Model for Rapid Reviews at the end of this document that is to form the basis for the “quick reviews” of the entire MBS)
  • some of the possible mechanisms for putting a limit on Medicare outlays that will be investigated and possibly implemented, such as:
    • limits on services and Medicare rebates where they are provided more than once within a designated time period and the potential impact on the end provider (i.e. the DI or pathology provider where they deliver a service but then discover that it is a repeat service when the patient’s claim for a rebate is rejected)
    • billing for follow up specialist consultations
    • where GPs perform the same surgical procedure as specialists, should the rebate be lower, or should it be the same
    • whether referrals between medical professionals should continue
    • whether assistance in surgery will continue to be eligible for Medicare rebate
  • a push to task substitution (primarily GPs taking on specialist roles) and pitting one specialty against another will be divisive and needs to be avoided
  • an increased focus on specialisation as opposed to generalism that will detrimentally affect rural practice
  • the lack of a clear methodology for quantifying potential savings, and the lack of a clear indication of how any such savings might be applied
  • the lack of a clear indication of how the Review’s output will be implemented and what, if any, role MSAC will have in relation to the Review (coupled with the concern that if MSAC then has to review recommendations, the timeframe will extend well beyond two years, and finally
  • that much of what has been discussed concerns “taking away” and not about modernising or adding items the Schedule.

Presentation on the MBS Review by Professor Bruce Robinson, Taskforce Chair

N.B. This presentation included material about the Review that is already in the public domain and can be found at Review’s website, together with information about membership of the Taskforce and the Primary Health Care Advisory Group and its consultations.


The following points raised by Professor Robinson expand on some of the information already available.

Review Working Group Principles

Review Working Group teams will comprise

  • Chair (selected by Taskforce)
  • No one with “major conflict of interest”
  • <50% of members from main in-scope discipline
  • Remaining members from adjacent or other clinical fields
  • Decisions will be made using a 60% majority of the group (consensus not required
  • All decisions and dissenting positions to be minuted
  • Meetings by teleconference

(The Committees will use a review mechanism developed in Ontario – the Health Quality Ontario model for rapid reviews a description of which is set out at the end of this update – to rapidly review the items.)

“Priority Review Items”

A number of specialty groups have already proposed possible priority review items, which include:  bone densitometry, imaging for pulmonary embolism and acute DVT, knee imaging;  adenoidectomy, tonsillectomy and grommets; blood transfusion services, iron studies and coagulation studies; obstetrics; sleep studies, respiratory function tests; upper and lower GI endoscopy and colonoscopy; and Rules and Regulations.

The Taskforce is currently seeking nominations for membership of the clinical committees and review working groups, to nominate items for review and prioritise them for early review; provide feedback and suggestions on planned approach; provide feedback and suggestions on draft recommendations as generated.  He also highlighted the importance of the specialty societies and other organisations in commenting on the material generated during the Review.

In other areas of the Review, e.g. where literature reviews are carried out, if there is disagreement the reviews can be critiqued by the relevant specialty group and where flaws are identified, then an “appeal” can be lodged by the specialty group.

It was noted that issues will arise during the Review that need to resolved, e.g. where one specialty group’s item groups are used by different specialists (procedures involving hand surgery were particularly highlighted as an issue).  It has been accepted that there will need to be a defined process to deal with cross specialty issues.

Cleary there will be ongoing issues to be addressed for the duration of this Review and the AACP will take a close interest in all aspects of the Review in order to best represent consultant physicians and paediatricians.

Table 1
The Taskforce / Government have defined what is “in scope” in the MBS Review and what is not, as shown in the following table:

  • all current MBS items and the services they provide
  • increasing the value derived from services
  • concern about safety, clinically unnecessary service provision and concurrence with guidelines
  • evidence for services, appropriateness, best practice options, levels and frequency of support
  • legislation and rules that underpin the MBS
  • division of responsibilities between Federal and State Governments
  • innovative funding models for chronic and complex disease – which is the responsibility of the Primary Health Care Advisory Group (i.e. not the MBS Review Taskforce – the PHCAG reports to the Taskforce)
  • introduction of new MBS services – Medical Services Advisory Committee
  • no savings target – scope for reinvestment

The Taskforce has indicated that the following are likely to initiate a review of existing MBS items:

  • obsolescence
  • indication creep
  • inappropriate frequency intensity
  • pricing failure
  • bundling unbundling

Rapid Review Methodology that will be used by the Discipline / Clinical Review Groups

Review groups will look at the macro issues, using the Health Quality Ontario model for rapid reviews. This model is described thus:

  • rapid reviews are completed in 2–4-week time frames
  • clinical questions are developed by the Evidence Development and Standards branch at Health Quality Ontario, in consultation with experts, end users, and/or applicants in the topic area
  • a systematic literature search is then conducted to identify relevant systematic reviews, health technology assessments, and meta-analyses
  • the methods prioritise systematic reviews, which, if found, are rated by AMSTAR to determine the methodological quality of the review. If the systematic review has evaluated the included primary studies using the GRADE Working Group criteria.
  • http://www.gradeworkinggroup.org/index.html, the results are reported and the rapid review process is complete
  • if the systematic review has not evaluated the primary studies using GRADE, the primary studies in the systematic review are retrieved and the GRADE criteria are applied to two outcomes
  • if no systematic review is found, then RCTs or observational studies are included, and their risk of bias is assessed. All rapid reviews are developed and finalised in consultation with experts.