Articles and Case Studies

If It Sounds Too Good to be True

01 Dec 2017

Checking the accounts

Most jobs in medicine are highly regulated and therefore adhere to the numerous codes and guidelines in place to protect the public.
Despite strict regulatory frameworks, doctors occasionally find themselves on the receiving end of an AHPRA complaint or Medicare investigation due to unscrupulous employers offering profitable positions which can leave the doctor at risk, both financially and professionally.
There has been significant media interest1 in “free” screening programs, which involve the bulk billing of tests for otherwise healthy individuals, assessing the risk for conditions such as stroke or heart disease. Doctors should be aware that unless specified, Medicare benefits are not payable for health screening services. The concern for doctors is that billing for screening is usually billed to Medicare using a doctor’s provider number, for which they are financially responsible. Even though doctors may only derive a set fee per consultation, or receive a percentage of the billings, they can be responsible for 100 per cent of the repayment if Medicare deems the service to have no clinical basis.
Another area of concern is cosmetic injectables. A substantial increase in the number of facilities offering Botox and fillers has seen an increase in the need for doctors to prescribe the drugs for the clinics to inject. Again, this may seem like easy money. However, you need to be aware of the dangers involved in prescribing Schedule 4 drugs outside of your usual practice. If you undertake any practice outside your usual field of practice, you should check whether you are covered under your Professional Indemnity Policy. 
AHPRA released Guidelines for Registered Medical Practitioners who Perform Cosmetic Medical and Surgical Procedures2 in October 2016. The guidelines state that while doctors can prescribe Schedule 4 “prescription only” cosmetic injectables after a video consultation, they cannot prescribe cosmetic injectables by phone or email. Doctors must not prescribe Schedule 4 cosmetic injectables unless they have had a consultation with the patient, either in person or by video.

Helpful Tips
If you are approached with an offer that sounds too good to be true, here are some tips:
  • Do your homework on the organisation offering the job. A quick Google search may turn up valuable information about the company offering the position, or other companies with a similar structure.
  • Don’t assume that an agency is  responsible for doing due diligence in relation to the legalities around the job being offered.
  • Each individual doctor is responsible for ensuring they are appropriately trained and registered for the role they accept, and for assessing whether the tasks within the role are clinically indicated for the purposes of billing to Medicare.
  • Don’t accept any role which requires you to hand your provider number over to an organisation so they can bulk bill screening services, or any other services which are not clinically indicated or do not meet the MBS descriptor.
  • Regardless of where you work, each doctor should know exactly what is being billed to their provider number.3


  1.  Medew J, Spooner R. Doctors Sound Alarm on Controversial ‘Strokecheck’ Results
  2.  Medical Board of Australia. Guidelines for Registered Medical Practitioners Who Perform Cosmetic Medical and Surgical Procedures
  3.  Ferrie N. Staying on the Right Side of Medicare.
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