17/06/2026
An interesting read on the reality of bulk billing patients.
When Government Policy Meets Clinical Reality: The Hidden Cost of the July 2026 Assignment of Benefit Changes
From 1 July 2026, changes to the Assignment of Benefit (AoB) requirements took effect across Australian healthcare. The policy intent is sound: greater integrity, transparency and auditability in Medicare claiming. The operational consequence, however, lands squarely on the practices already carrying the heaviest load.
To be clear, AoB itself is not new. What has changed is how patient agreement must be obtained and evidenced before a bulk-billed Medicare claim is lodged.
What AoB Is, and Who It Affects
AoB applies whenever a clinician bulk bills a patient. This includes GPs, allied health professionals and non-GP specialists. Of these groups, non-GP specialists have generally been the most consistent in meeting the formal requirements for years: notifying patients before the consult, obtaining informed consent, confirming by email, then completing billing.
General practice workflows, by contrast, evolved around convenience. In many clinics, patients were waved past reception and billed without a properly completed AoB, whether verbal, manual or electronic. Aged care followed a similar pattern, with GPs attending facilities and returning with a list of services for administrative staff to process later, often with no valid assignment completed at the point of care.
Allied health has tended to sit somewhere in the middle. In many cases, patients were charged a "gap" of $20 to $80, with the remainder bulk billed. The problem is twofold. If that gap has not been properly disclosed to Medicare and linked to a valid service, it may not count toward the patient's safety net in the way patients assume. And the AoB requirements may still not have been met appropriately.
Many compliant clinics, ours included, adopted reception-based workflows where the patient accepted the AoB via an EFTPOS terminal, a process accepted by the department for over a decade and still reflected in published guidance. That operational reality is now changing.
What the Changes Actually Require
The substantive shift is straightforward to state, but far-reaching in practice:
Verbal consent is no longer permitted, including for telehealth.
An electronic or physical signature is now required from the patient, or a responsible person, on the AoB agreement. The signature must be identifiable, auditable and compliant with the Electronic Transactions Act 1999.
Patients may assign a benefit before or after the service, provided the agreement is made prior to the claim being lodged.
Practitioners must retain a copy of each completed AoB agreement for two years and provide it to the patient on request.
The headline issue is the collection and proof of consent now sitting clearly with the practice claiming the service. For a high-volume clinic, that is not a minor adjustment. It is a structural change to daily workflow.
What We Are Seeing on the Ground
The most acute concern is in aged care and vulnerable patient settings. The practical question doctors are asking is simple: how does a patient with dementia, palliative care needs, or impaired capacity sign an AoB? In many cases, they legally cannot. That obligation then shifts to locating a family member or nominated responsible person (notably, not a paid carer or facility worker) to verify the assignment, before a routine claim can proceed.
In policy terms this sounds manageable. In real-world care delivery, it introduces friction, delay and clinical-administrative risk into services that are already stretched.
The frustration is leading to genuine talk of withdrawal. Some practitioners are weighing reduced aged care commitments, a return to standard in-clinic consults, or a move toward private billing, simply to avoid the burden. To date, none of these workarounds resolve the underlying problem, and the policy position is not expected to soften in the near term.
The Financial Reality: Modelling a Typical MM1 Clinic
For clinics that were already compliant, the change still imposes a substantial new cost. Printing, scanning and storing evidence of an AoB for every bulk-billed service is a meaningful increase in administrative labour, and one not adequately accounted for in the bulk-billing incentives introduced from November 2025, including the 12.5% Bulk Billing Practice Incentive Program (BBPIP) loading.
Consider a representative high-volume bulk-billing clinic in a metropolitan (MM1) location:
5 doctors
Each seeing 7 patients per hour
Operating 9 hours per day
Across a 6-day week
This equates to:
315 patient services per day (lets assume all leve B high volume clinic)
At an estimated 2 minutes of additional admin per patient to speak with the patient, confirm the amount, print the reciept, scan it, save it - offer a copy to the patient- that is 630 extra minutes, or 10.5 additional admin hours per day
Across six days, approximately 63 additional admin hours per week
Staffing the additional burden
A single full-time employee nominally works around 38 hours per week. Once annual leave, personal leave, public holidays, training and rostering realities are accounted for, no individual reliably delivers 38 productive hours every week of the year. To sustainably cover 63 additional admin hours per week, particularly with Saturday loadings, a clinic is realistically looking at approximately two full-time equivalent (FTE) staff.
At an indicative employment cost of $32 per hour before on-costs:
63 hours × $32 = $2,016 per week
Annualised: approximately $104,832 per year before superannuation, leave loading, workers' compensation and payroll overheads
Once those on-costs are applied, the true annual figure climbs well beyond that base, plausibly approaching $180,000 in larger operations once full leave coverage and contingency are built in.
What Does a Bulk-Billed Level B Consult Actually Generate?
This is where the economics become difficult. To assess viability, we need the correct, complete revenue attached to a standard bulk-billed consultation in MM1.
For a Level B GP consultation (MBS Item 23) bulk billed in a metropolitan (MM1) location, the revenue is built from three components:
For a Level B GP consultation (MBS Item 23) bulk billed in a metropolitan (MM1) location, the revenue is built from three components:
A note on each line of the corrected calculation:
Item 23 ($43.90) is the current schedule fee for a standard Level B GP attendance, in consulting rooms, lasting at least 6 and less than 20 minutes.
Item 75870 ($21.85) is the fixed metropolitan (MM1) bulk-billing incentive co-claimed with a bulk-billed Level B attendance. This is the correct incentive item for Level B (and Level C–E face-to-face) GP consultations in an MM1 location, and it is applied as a fixed amount rather than a proportion of the attendance fee.
The 6.25% BBPIP share ($4.11) follows from the way the Bulk Billing Practice Incentive Program operates. The BBPIP applies a 12.5% loading on eligible bulk-billed MBS benefits, paid quarterly in arrears to participating practices. As that loading is split 50/50 between the GP and the practice, the practice retains effectively 6.25%. The correct base for this loading is the combined eligible benefit — that is, Item 23 plus Item 75870, or $43.90 + $21.85 = $65.75. Applied to that $65.75 subtotal, the practice's share is $4.11.
This produces a corrected total of $69.86 per bulk-billed Level B consult in MM1. The earlier draft, which arrived at $54.24, did not reconcile against its own inputs once the fixed incentive was inserted, and the figure must be revised upward accordingly.
Reconciling revenue against the new admin cost
Now apply the practice's actual retained share. Under a common arrangement where doctors retain 70% of billings and the practice retains 30%, the practice's share of each bulk-billed Level B consult is:
30% × $69.86 = approximately $20.96 per consult to the practice
Against an additional administrative cost of roughly $104,832 per year (before on-costs), the practice must generate:
$104,832 ÷ $20.96 = approximately 5,002 additional bulk-billed Level B consults per year simply to fund the new AoB administration
Spread across the clinic's actual available working days — accounting for 10 public holidays and an average of 6 weeks of leave per doctor (inclusive of public holidays) — each of the 5 doctors works approximately 230 days per year. At the clinic level, with 5 doctors, that equates to roughly 1,150 doctor-days per year, or approximately 192 clinic trading days where a full complement of doctors is available.
Set against that capacity, the requirement of approximately 5,002 additional consults represents the throughput the clinic must sustain each year purely to recover the new administrative cost, before any net contribution flows to the practice.
Using the clinic-level trading days as the basis, the 5,002 additional consults needed to cover the AoB administration cost spread across approximately 192 full-capacity trading days equates to roughly 26.05 additional consults per day across the clinic. Distributed across 5 doctors, that represents an additional 5.2 consults per doctor per actual working day — purely to offset the compliance overhead, before a single dollar contributes to existing operating costs or margin.
To put that in practical terms: a clinic currently running at 7 patients per hour — that is, a 9-minute consultation — would need to shift to approximately 8 patients per hour, or a 7.5-minute consultation, just to absorb the cost of the new compliance requirement. That is not a rounding adjustment. A 7.5-minute consultation rhythm, sustained across a 9-hour day, is a gruelling pace by any clinical standard. It leaves almost no margin for complexity, patient distress, documentation, or the ordinary variation that defines general practice. On a workforce already operating at capacity, that figure is not achievable through ordinary scheduling without a direct and measurable impact on the quality of patient care.
Even allowing for the full BBPIP loading and the incentive payment, the conclusion holds: the revenue attached to a standard bulk-billed consult is modest, and the volume required to absorb the new administrative burden is not realistically achievable within existing capacity.
A Transfer of Burden, Not a Tidy-Up
This is not, in practical terms, a documentation refinement. It is a transfer of administrative responsibility from government policy into frontline clinical operations, unaccompanied by funding calibrated to the real workload it creates.
For high-volume bulk-billing clinics, aged care providers and practices serving patients who cannot readily sign, these changes introduce genuine operational risk: additional wage cost, workflow delay, and in some settings, a real threat to service viability.
If the policy objective is integrity and transparency, that is a legitimate and defensible aim. But where the implementation burden falls hardest on practices already delivering complex, high-volume, low-margin care, the foreseeable outcome is not improved access. It is reduced access, in precisely the settings that can least afford to lose it.
Add in the cost of paper? The impact on the environment for additional waste, cost of removing the waste, time for staff to remove the waste........ and you an see that the economics do not add up.
(Figures cited reflect MBS schedule fees and bulk-billing incentive arrangements current at the time of writing. Practices should confirm item values and BBPIP eligibility against current MBS Online listings and conduct their own assessment based on their specific circumstances, location and billing mix.)(
