Top 5 telehealth billing mistakes that trigger audits

Key Takeaways

• The "established relationship" rule has been clarified. To bill a standard telehealth consult to Medicare, your practice must have provided an in-person, face-to-face service to that patient within the last 24 months. This is a critical compliance point.
• Documenting financial consent is now mandatory. For every privately billed telehealth service, you must now document in the patient's notes that you obtained their verbal informed financial consent for the fee before the consultation began.
• Match the item number to the technology. You cannot bill a "video" telehealth item number if the consultation was only conducted over the phone. Ensure your billing accurately reflects the method of communication used.
• Teledentistry billing is about professional standards. While mostly privately billed, teledentistry requires the same level of informed consent, record-keeping, and privacy considerations as an in-person visit, as outlined by the Dental Board of Australia.
• Your team is your first line of defence. The most common billing errors are simple administrative mistakes. Regular training for your clinical and admin staff on the latest telehealth rules is your best protection against a Medicare audit
• Automate your compliance. Reduce human error by configuring your Practice Management Software (PMS) to automatically flag patient eligibility issues and by using templates to standardise consent documentation.

Introduction: Navigating the new era of telehealth compliance

Telehealth is no longer a temporary workaround; it's a permanent and essential pillar of the Australian healthcare system. Since its widespread introduction, tens of millions of services have been delivered to patients across the country, improving access to care for countless Australians. The Australian Digital Health Agency (ADHA) reports that telehealth now accounts for a significant portion of all GP consultations, cementing its place in modern practice.

However, with this permanence comes increased scrutiny. In 2025, Medicare (Services Australia) and other regulatory bodies have sharpened their focus on ensuring telehealth is delivered and billed correctly, with new clarifications and stricter documentation requirements. For busy GPs, dentists, and their practice managers, staying on top of these evolving rules is not just a matter of good governance; it's essential for avoiding costly billing errors and potential audits. This article provides a practical guide to the key telehealth billing rules you need to know now.

The shift from temporary measure to permanent fixture

The initial telehealth item numbers introduced during the COVID-19 pandemic were designed for emergency use. The system now is a permanent, though more tightly regulated, framework The overarching goal of the new rules is to ensure that telehealth supports, rather than replaces, the continuity of care that is the hallmark of Australian general practice and dentistry. The two most significant recent clarifications for 2025 focus on reinforcing the patient-practitioner relationship and ensuring financial transparency.

Key billing changes for GPs

For GPs, the key changes centre on ensuring telehealth is used for established patients and that billing is transparent.

The "established relationship" rule clarified

To bill most standard GP telehealth services (Levels A, B, C, and D) via Medicare, your practice must have an established relationship with the patient. This has now been clearly defined:

• The patient must have had at least one in-person, face-to-face consultation at your practice in the 24 months prior to the telehealth service.
  
  

This rule is designed to stop new "pop-up" telehealth providers from billing Medicare for patients with whom they have no existing relationship or clinical history.

A realistic scenario: The returning patient

A patient calls your practice for a phone consultation for a simple script renewal. Your receptionist checks their file and sees their last in-person visit was 26 months ago.

• The compliant action: The receptionist politely informs the patient, "Because we haven't seen you in person for over two years, Medicare's new rules mean we can't bill this consult to them. You are welcome to have a private telehealth appointment with the doctor for a fee of $85, or we can book you in for a face-to-face visit next week which would be bulk-billed."
  
  

Mandatory documentation of financial consent

For all privately or mixed-billed telehealth consultations, it is now a mandatory requirement to document in the patient's notes that verbal informed financial consent was obtained. The note should include:

1. That the patient was informed of the fee.
2. That the patient was informed of the expected out-of-pocket cost.
3. That the patient consented to proceed with the consultation.
   
   

This simple note is your primary evidence of compliance in the event of an audit.

Navigating the new landscape of teledentistry

While most teledentistry services in Australia are privately billed, the practice is still subject to the high professional and ethical standards set by the Dental Board of Australia and AHPRA.

The Australian Dental Association (ADA) has provided clear guidance for practitioners. While there are no MBS item numbers to navigate, the key compliance issues are:

• Limitations of remote care: You must ensure that teledentistry is only used for appropriate services (e.g., triage, consultation, post-operative follow-up) and not for procedures that require a physical examination or diagnosis.
• Informed consent: You must obtain and document the patient's informed consent, explaining the limitations of a remote consultation. 
• Record-keeping: Your clinical notes must be just as detailed as for an in-person visit, including the technology used and the information provided.
• Financial consent: The rules of transparency are the same. You must provide a clear quote and obtain financial consent before the service is provided.

Common telehealth billing pitfalls and how to avoid them

Simple administrative errors are the most common cause of non-compliant telehealth billing. Regular training for your whole team can help you avoid these frequent mistakes.

• Mismatching the technology: Billing a video-conference item number (which typically has a higher rebate) for a consultation that was only conducted over the phone.
• Incorrect duration: Failing to accurately document the start and end times of the consultation to justify billing for a longer session (e.g., a Level C or D).
• Ignoring the 24-month rule: Billing a telehealth service for a patient who has not been seen in person within the required 24-month period.
• Forgetting to document consent: Forgetting to add the simple note about obtaining verbal financial consent to the patient's file.

Leveraging technology for seamless compliance

The most effective way to adhere to the new telehealth rules is to build them directly into your daily workflow using technology. Relying on your team's memory alone is a recipe for inconsistent billing and potential compliance failures. Your existing software is a powerful tool for automating these checks and reducing the risk of human error.

• Automate eligibility checks in your PMS. Most modern Practice Management Software (PMS) in Australia can be configured to help you manage the "24-month rule." Work with your IT support or software vendor to create an alert that automatically flags patients at the time of booking who have not had a face-to-face appointment in the last two years. This gives your reception team an immediate, clear signal to discuss the billing implications with the patient.
• Create documentation templates. To make it easy for your clinicians to document financial consent, create a pre-saved template or text shortcut within your clinical software. A simple shortcut that expands to a compliant note like, "Verbal Informed Financial Consent (IFC) obtained for private fee of $85 with est. rebate of $41.40," turns a manual task into a consistent, one-click process.
• Choose a compliant video platform. Using generic consumer video apps like FaceTime or Skype for consultations is a significant medico-legal and privacy risk. Ensure your telehealth video platform is designed for healthcare, is compliant with Australian Privacy Principles, and provides a secure, encrypted connection to protect your patient's sensitive health information.

Conclusion

Telehealth is an invaluable tool that has permanently transformed how healthcare is delivered in Australia. However, its integration into the Medicare system comes with a clear expectation of compliance and accountability. By understanding and implementing these clarified billing rules, you not only protect your practice from the significant financial and professional risks of a Medicare audit but also reinforce a culture of transparency and trust with your patients. Regular team training and the use of clear, consistent protocols are the keys to navigating this new landscape with confidence.