Telehealth and the MBS: compliance for providers in 2026

Telehealth on the Medicare Benefits Schedule (MBS) lets eligible practitioners deliver and bill Medicare-rebatable consultations by video or telephone, rather than face to face. In 2026 these items are a permanent part of the MBS, but they are not open-ended: to attract a rebate, the practitioner generally must meet the eligible telehealth practitioner requirement (formerly the "established clinical relationship" requirement), the service must be clinically appropriate for the modality, and it must satisfy the relevant MBS item descriptor. The core compliance question for any provider is therefore not "can I do telehealth?" but "does this specific service, with this patient, on this day, meet the item rules?"

This is the obligation tracked at /obligations/telehealth-mbs. The primary source is the *Health Insurance Act 1973* and its regulations, administered by the Department of Health, Disability and Ageing, with item-level detail published on MBS Online.

What telehealth MBS means in 2026

Telehealth MBS items mirror many in-person attendance items but are claimed when the service is delivered remotely. Following the COVID-era expansion, telehealth was made a permanent MBS feature, and the schedule has continued to evolve, including new chronic condition management items introduced from 1 July 2025 that replaced the previous GP Management Plan and Team Care Arrangement structure.

In practical terms, three things must line up for a compliant claim:

• The practitioner is eligible to provide the service by telehealth.
• The service is one for which a telehealth item exists and is clinically appropriate to deliver remotely.
• The billing matches the item descriptor (modality, duration, provider type and any patient-eligibility conditions).

Always confirm the current item descriptor on MBS Online before billing, because descriptors and eligibility conditions change.

Who this applies to

The telehealth MBS rules apply to any provider claiming Medicare benefits for remote consultations, including:

• General practitioners and other medical practitioners
• Specialists and consultant physicians
• Nurse practitioners and eligible nursing/allied health providers (subject to their own item conditions)
• Practice managers and billing staff who submit claims on a provider's behalf

The legal liability for an incorrect claim sits with the provider whose number is used, even where a staff member entered the claim. Practices should treat telehealth billing as a shared-responsibility control, not a back-office task.

The eligible telehealth practitioner requirement

The central eligibility control is the requirement previously known as the "established clinical relationship" rule, renamed the eligible telehealth practitioner requirement from 1 November 2025. The terminology shifted the framing from the patient relationship to the practitioner's eligibility, but the substance is broadly similar.

In general, to bill most GP telehealth attendances the patient must have had a face-to-face MBS service with the same practitioner or practice within the previous 12 months — commonly referred to as the 12-month rule — or be registered with the practice under MyMedicare. MyMedicare registration provides an exemption from the 12-month face-to-face condition.

Several patient groups are exempt from the requirement, which has historically included (verify current scope on MBS Online before relying on any exemption):

• Patients experiencing homelessness
• Patients of Aboriginal Community Controlled Health Services
• Certain other groups specified in the item conditions or AskMBS advisories

Note that eligibility settings for some provider types are still changing — for example, nurse practitioner telehealth items are scheduled to be brought under the same eligibility conditions from late 2026. Confirm the position for your provider type on the date of service.

The Department publishes plain-language clarifications through its AskMBS advisories, which are the authoritative reference when an item's wording is ambiguous.

Video versus phone items

The MBS treats video and telephone consultations differently. Video is the default expectation for many telehealth services; telephone items are more tightly constrained, both in which services qualify and in how much phone-only work a provider can bill relative to their overall consultation volume.

Where a clinical assessment genuinely requires visual examination, a phone item may not be appropriate even if one nominally exists. Document why the chosen modality was clinically suitable.

AHPRA standards sit alongside the MBS

Meeting the MBS item rules is necessary but not sufficient. Registered health practitioners must also comply with their National Board's professional standards, including the Ahpra and National Boards telehealth guidance, which has applied since September 2023. This is the obligation at /obligations/ahpra-cpd-registration.

Two points are particularly relevant to compliance:

• The Medical Board's position is that prescribing or providing healthcare without a real-time direct consultation (in person, by video or by telephone) is not good practice. Asynchronous, questionnaire-only prescribing models are specifically called out as not supported.
• Telehealth is regarded as most appropriate within a continuing clinical relationship that also involves in-person care where needed.

A service can therefore be technically MBS-billable yet still expose a practitioner to regulatory action if it falls short of professional standards. Both frameworks must be satisfied.

What providers should do

Build telehealth compliance into the workflow rather than checking it after the fact:

• Verify eligibility before the consult. Confirm the patient meets the 12-month rule, holds MyMedicare registration, or qualifies for a recognised exemption.
• Match the item to the modality and duration. Check the descriptor on MBS Online on the day, including any phone-volume conditions.
• Document the clinical justification. Record why telehealth (and the specific modality) was appropriate for the presentation.
• Keep records that withstand audit. Note consent, the platform used, who was present, and the clinical content — the same standard as an in-person record.
• Brief billing staff. Make sure anyone submitting claims understands the eligibility conditions, not just the item numbers.
• Track changes. Subscribe to AskMBS advisories and review item conditions when the schedule updates (typically each March, July and November).

For practitioners, also confirm currency of registration and continuing professional development obligations as part of the same governance loop.

Common compliance pitfalls

The errors that most often surface in Medicare compliance reviews and Professional Services Review processes include:

• Billing a telehealth item without an eligible relationship — no face-to-face service in the prior 12 months and no valid exemption or MyMedicare registration.
• Using a phone item where video or in-person was required, or exceeding phone-only proportion limits.
• Assuming exemptions are permanent. Exemption categories and provider-type conditions change; relying on a superseded advisory is a recurring problem.
• Questionnaire-only prescribing that fails the real-time consultation standard, regardless of any item billed.
• Thin documentation that cannot demonstrate clinical appropriateness or the modality used.
• Treating MBS compliance and AHPRA standards as the same test. They are separate, and both apply.

Incorrect claiming can lead to repayment of benefits, administrative penalties and referral to the Professional Services Review scheme; conduct concerns can be referred to Ahpra. Because item conditions are detailed and change regularly, the safest approach is to confirm the current rules against MBS Online and the relevant AskMBS advisory for every telehealth service you intend to bill.