Retract care plan nudge letters until item descriptors are fixed: RACGP

The nudge letters sent to 600 GPs who co-claimed care plan and practice nurse MBS items should be rescinded until the Medicare ambiguity is cleared up, says the RACGP.

The compliance campaign targeted GPs who had claimed MBS item 721 or 723 for a GP care plan on the same day as item 10997 for practice nurse chronic disease care, giving them until 17 March to review their billing and repay any inappropriate claims.

This was despite the MBS item descriptors saying nothing about co-claiming and whether it was banned, and the nudge letter merely stating that GPs should not claim the items on the same day “routinely”.

RACGP president Dr Nicole Higgins has now written to the federal Minister for Health and Aged Care calling for him to intervene.

“We realise the letters have now been sent, and it is not customary for the department to rescind these; however, the circumstances in this case warrant your intervention,” said Dr Higgins’ letter, which the RACGP published.

She said the department should instead give GPs an explanation of when the items should and should not be co-claimed, addressing the current ambiguity (see below).

Former RACGP SA/NT faculty chair Dr Danny Byrne called out Mark Butler over the nudge letters last month during a radio interview.

Dr Byrne told Australian Doctor that after receiving one of the letters, he stopped co-claiming the items and increased gap fees for concession patients from $15 to $25 to cover his losses.

“I don’t want the department hassling me and threatening me,” he said.

“I had heard of these letters and how they make people feel, but until you get one, you don’t understand.”

In her letter to Mr Butler, Dr Higgins said the nudge letters should not have a deadline for reviewing claims and should instead tell GPs it was a voluntary opportunity to “self-reflect” on their billing.

“Using language such as ‘you must repay’ is unhelpful and leads to fear and anxiety,” Dr Higgins wrote.

“There is a significant risk that this compliance campaign will cause GPs to distance themselves from co-ordinated chronic disease care through the MBS,” she continued.

“In the medium- to longer-term, this will cost our communities greatly by placing a greater demand on secondary and tertiary health providers.”

Examples of MBS complexity, according to the RACGP.

The letter that has been sent to GPs states that item 10997 can be claimed if the patient has an existing GP management plan (GPMP), team care arrangement (TCA) or multidisciplinary care plan in place.

However, the AskMBS Advisory on GP services (page 5) states that it would not be expected that item 10997 would be routinely claimed on the same day as item 721 or item 723.

This indicates there are circumstances in which item 721/723 and 10997 can be co-claimed.

It could also be interpreted to mean that you can only bill both items for a patient on the same day if they visit the practice for two separate attendances.

The letter contradicts itself by stating that item 10997 should not be claimed for assistance provided to a GP to prepare or review a GPMP/TCA but that claiming these items on the same day is not restricted.

While co-claiming is not restricted, the letter does not explain under what circumstances it would be appropriate to do so.

Source: RACGP open letter to Mark Butler

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More information: RACGP: Open letter; 3 Mar 2023.