Telehealth is now a permanent part of Australian Allied Health, yet the billing rules still trip people up, right across physiotherapy, occupational therapy, speech pathology, psychology, and beyond.
Even after a successful telehealth session, it’s not uncommon for practitioners to pause at the billing screen with questions like “Which item number applies?” Can I bulk bill this session?” “Will their private health fund pay a rebate on top of a Medicare claim?”
The trouble usually isn't a lack of knowledge. It's the way Medicare eligibility, referral pathways like Chronic Disease Management plans and Mental Health Care Plans, and insurer policies interact, often differently by discipline. That's where errors and missed revenue quietly creep in.
This guide gives you a clear, practical framework for Medicare, bulk billing, and private health rebates, so you can bill telehealth with confidence and stay compliant.
How telehealth billing works for Allied Health in Australia
Telehealth billing for Allied Health in Australia runs through three distinct pathways: Medicare (via the Medicare Benefits Schedule), bulk billing, and private health insurance. Each has its own rules, and understanding how they interact is what separates a clean claim from a rejected one. Here are the foundational mechanics.
Medicare (MBS): When a client is eligible, Medicare pays a set benefit for a specified telehealth item number. That benefit is a fixed dollar amount tied to the item, not a percentage of your fee. You can charge above the benefit and the client pays the difference, or you can accept the benefit as full payment.
Bulk billing (assignment of benefit): Assignment of benefit means the client assigns their Medicare rebate directly to you, and you accept that rebate as full payment for the service. The client pays nothing. You claim the benefit from Services Australia. In practice, the client agrees to the assignment (electronically or on a signed form), you submit the claim, and Medicare pays you directly. No gap fee, no invoice to the client.
Private health insurance: Private health rebates sit entirely separately from Medicare. A client with the right level of extras cover can claim a rebate on your fee through their fund. This operates independently of any Medicare claim, which matters because a single service cannot be claimed against both Medicare and a private fund at the same time.
Consider a psychologist delivering a telehealth session under a Mental Health Care Plan. The session attracts a specific MBS item number. The psychologist can bulk bill it (client pays nothing, Medicare pays the benefit), or charge a fee and bill Medicare so the client receives the rebate and pays the gap. If the client has no Medicare referral, they might instead claim a rebate through their private health fund's extras cover. The pathway you use is determined by the referral, the client's eligibility, and your fee policy.
Understanding which MBS telehealth item numbers apply to your discipline
The MBS telehealth item numbers you use depend on your discipline, the referral pathway, and whether the consultation was delivered by video or phone. Video consultations generally attract a higher rebate than phone consultations. Some items are video-only. Telehealth items became a permanent part of the MBS from January 1, 2022 [5], so this is no longer a temporary COVID-era arrangement. It's legislated and ongoing.
The two primary referral pathways
Most Medicare-eligible Allied Health telehealth runs through one of two GP-initiated pathways:
Chronic Disease Management (CDM) plan: A GP prepares the plan and refers the client for Allied Health services. This covers physiotherapy, occupational therapy, speech pathology, dietetics, and other eligible disciplines. Clients can access up to five Medicare-rebated Allied Health services per calendar year across all disciplines combined under this pathway [4]. But remember, that's five sessions total, not five per discipline.
Mental Health Care Plan (MHCP):A GP prepares the plan and refers the client to a psychologist or other eligible mental health provider, for up to 10 individual and 10 group sessions rebated per calendar year. [7]
Yes, patients need a GP referral to access Medicare rebates for Allied Health telehealth. Without a valid referral under one of these pathways, there’s no rebate. And that’s non-negotiable.
Discipline-by-discipline reference
- Psychology: Items for MHCP-referred sessions have separate numbers for video and phone. Video consults attract the higher rebate. Focussed psychological strategies items apply to other eligible providers delivering mental health services.
- Physiotherapy:The MBS item numbers physiotherapists use for telehealth are CDM-referred, with distinct video and phone numbers depending on how the consult was delivered.
- Occupational therapy: Yes, occupational therapists can claim Medicare for telehealth under a CDM plan, using the OT telehealth items (video and phone variants).
- Speech pathology: CDM-referred telehealth items apply, with the same video-versus-phone split.
- Dietetics: CDM-referred telehealth items apply for eligible dietetic services.
Always confirm current item numbers on the MBS Online site before billing, as descriptors and benefit amounts are reviewed periodically. The safest habit is checking the exact item against the referral pathway and the modality you actually delivered.
Bulk billing telehealth for Allied Health: eligibility, rules, and when it applies
Yes, Allied Health practitioners can bulk bill telehealth appointments. And yes, occupational therapists, speech pathologists, and psychologists can all bulk bill telehealth when the service is Medicare-eligible.
Bulk billing eligibility for Allied Health telehealth is tied to three things: the referral pathway (a valid CDM plan or MHCP), the client's circumstances, and the specific MBS item you're billing. When those line up, you can choose to bulk bill.
Bulk billing Is opt-in
Bulk billing for Allied Health is not mandatory in most circumstances. You decide whether to accept the Medicare benefit as full payment or charge a fee and let the client claim the rebate. Plenty of practices bulk bill concession card holders and children while charging a gap fee for everyone else.
When you bulk bill, you accept the Medicare benefit as full payment. You cannot charge the client a co-payment or gap fee on top of a bulk-billed service [1]. Trying to do both is a compliance breach, and it's exactly the sort of thing an audit picks up.
The 80/20 rule and compliance
The 80/20 rule flags practitioners who provide 80 or more services on each of 20 or more days in a 12-month period [8]. Cross that threshold and you trigger a review, so high-volume telehealth practices should keep an eye on their daily service counts.
Let's look at a practical example. A psychologist sees a pensioner under a Mental Health Care Plan by video. She bulk bills the session, so the client pays nothing and Medicare pays the benefit directly to the practice. For a self-funded client under the same plan, she charges her full fee, bills Medicare for the rebate, and the client pays the gap.
Private health rebates for telehealth: How funds and HICAPS work
Private health rebates for telehealth apply in Australia, but fund policies vary and not all funds cover all modalities equally. Some rebate video consultations but not phone. Coverage depends on the client's level of extras cover, and this is where you'll spend the most time fielding client questions.
Private health telehealth rebates operate entirely independently of Medicare. They're not subject to MBS rules, but you must still meet each fund's provider registration and service requirements. A client cannot claim the same service against both Medicare and their private fund.
How HICAPS Works for telehealth
HICAPS has partnered with all Australian private health insurers to facilitate easier processing of telehealth claims [2]. Because there's no physical card terminal in a telehealth session, you process the claim through a HICAPS-enabled function in your practice management software. The client's rebate is calculated instantly, and they pay only the gap.
To process telehealth claims correctly, your software needs HICAPS integration configured with your provider numbers and the correct service items mapped to each discipline. Once that's set up, claiming a telehealth session takes the same few clicks as an in-clinic appointment.
From the client's perspective, the gap fee is your full fee minus the fund rebate. Out-of-pocket costs vary by fund and cover level, so it pays to set clear fee expectations before the session rather than after.
Telehealth compliance requirements Allied Health practitioners should know
Telehealth billing compliance comes down to a handful of non-negotiable rules. Get these done right and audits become a formality rather than a threat.
- Patient location: The client must be physically located in Australia at the time of the telehealth service. A client dialling in from a holiday overseas is not eligible for a Medicare-rebated telehealth consultation. Worth asking the question if something seems off.
- Provider location: You, as the provider, deliver the service under the standard MBS provider requirements. Document where the service was delivered from.
- Clinical appropriateness: Telehealth must be clinically appropriate for that client and that service. Record why telehealth suited the presentation, because ‘clinically appropriate’ is a genuine billing requirement, not just a box to be ticked.
- Consent and documentation: Obtain and record the client's consent to the telehealth service, and note the referral details, the item billed, and the modality used.
Video versus phone consultations
Video and phone consultations carry different item numbers and different rebates. If a video connection drops and you finish the session by phone, you must bill the phone item, not the video item. Billing a video item when only audio was used is one of the most common triggers for a Medicare audit. So is failing to document why telehealth was clinically appropriate. Both are avoidable with consistent record-keeping.
Common telehealth billing mistakes Allied Health practitioners make
These are operational gaps, not clinical failures. Every one of them is preventable with the right system in place.
- Wrong item for the modality: Billing a video item when the session ran by phone. It's an easy slip when the connection changes mid-session, and it's a frequent audit flag.
- Missed referral expiry: CDM plans and Mental Health Care Plans have limits and renewal points. Bill against a lapsed referral or an exhausted session count and you're looking at rejected claims and unpaid work.
- Unconfirmed eligibility: Delivering a session before confirming the client's remaining rebated sessions for the calendar year. Only 22.5% of Australians had a telehealth consultation in 2024-25 [6], so a lot of clients are still learning how their entitlements work. That makes the upfront check worth the minute it takes.
- Unreconciled private health claims: Processing a HICAPS claim but never reconciling it against payment, so shortfalls go unnoticed.
A practice management system that tracks referrals, session counts, and item numbers removes most of these risks before they ever reach the billing screen.
How practice management software streamlines telehealth billing
The right practice management software turns telehealth billing from a source of second-guessing into a repeatable workflow. It cuts both the admin load and the compliance risk.
splose brings the pieces together: item number suggestions based on discipline and referral pathway, integrated HICAPS claiming for private health rebates, Medicare bulk billing workflows, and audit-ready documentation stored against every appointment.
Here's how it plays out. An occupational therapist finishes a telehealth session under a CDM plan. She writes her progress note, and from the same screen selects the correct telehealth item, confirms the client's remaining rebated sessions, and submits the Medicare claim. The whole billing step takes a couple of minutes, and the referral details and consent record sit on file if an audit ever comes knocking.
That's the point of good software: it handles the operational detail so you spend your time on care, not on chasing the right item number. As telehealth settles in as a permanent fixture, a system that makes billing effortless is what lets your practice grow without the admin growing with it.
Telehealth billing does not have to be complicated
Telehealth is here to stay. Your billing can be just as steady. Once you know which MBS item numbers apply to your discipline, when you can bulk bill, and how private health rebates interact with Medicare claims, telehealth billing turns into a repeatable workflow. Knowledge is only the foundation. The right system is what makes it stick.
Here's a practical next step: pull up your last ten telehealth sessions and check them against what you've read here. Did each one use the correct item number? Was consent recorded? Were referral details on file? A quick audit like this often surfaces the small gaps where revenue quietly slips away.
If that review shows your current setup is creating more admin than it should, it might be time to look at software that handles the operational detail for you. Practice management tools like splose take the friction out of billing so it becomes a background task rather than a source of stress.
