Definition / Overview
- Chronic pain and opioid dependence represent two distinct but frequently overlapping clinical presentations in Australian general practice.
- Effective management requires not only clinical skill but also fluency with the Medicare Benefits Schedule (MBS) and Pharmaceutical Benefits Scheme (PBS) frameworks that fund this care.
- Under-utilisation of available billing items disadvantages patients by limiting access to multidisciplinary support, and exposes GPs to medico-legal risk by failing to document the structured care these patients require.
For billing purposes, the key distinction is:
- Chronic non-cancer pain (CNCP): persistent pain lasting beyond three months, not primarily driven by active malignancy
- Opioid dependence: a substance use disorder characterised by compulsive use, tolerance, and withdrawal, often managed through opioid substitution therapy (OST)
Both conditions qualify for a range of MBS-funded structured care items, and opioid dependence also involves specific PBS authorities and state-based prescribing authorities.
MBS Items for Chronic Pain Management
GP Chronic Condition Management Plans
The cornerstone of chronic disease management in general practice applies equally to chronic pain:
| MBS Item | Description | Key Requirements |
|---|---|---|
| Item 965 | GP chronic condition management plan (GPCCMP) | Patient with chronic condition(s) likely to benefit from structured care; documented written plan |
| Item 967 | Review of the GPCCMP | Available every 3 months if clinically relevant; clinical review of progress against goals |
| Items 44 / 123 | Longer GP consultation (level D, at least 40 minutes; level E, at least 60 minutes) | Appropriate when complexity warrants extended time |
Practical tips:
- A GPCCMP (965) can be prepared directly, with allied health referred at the same visit; a separate team care arrangement is not required
- For chronic pain, the GPCCMP enables direct referral of up to five allied health sessions per calendar year (items 10950-10970) to providers such as physiotherapists, psychologists, and exercise physiologists
- Document the specific functional goals in the plan, not just the diagnosis; vague plans are poor medico-legal practice
- Item 967 review should assess progress against documented goals, adjust the plan, and confirm ongoing eligibility
Chronic Disease Management Allied Health Items
Under a GPCCMP, patients with chronic pain access:
| MBS Item | Allied Health Provider |
|---|---|
| 10950 | Aboriginal and Torres Strait Islander health worker |
| 10952 | Audiologist |
| 10951 | Diabetes educator |
| 10954 | Dietitian |
| 10953 | Exercise physiologist |
| 10956 | Mental health worker |
| 10958 | Occupational therapist |
| 10960 | Physiotherapist |
| 10962 | Podiatrist |
| 10968 | Psychologist (general) |
- Up to five sessions per calendar year across all allied health types combined.
- Patients may access additional psychology sessions via the Better Access pathway (see below) concurrently, but the clinical need must be documented separately.
Mental Health Treatment Plans for Co-morbid Depression/Anxiety
Chronic pain is strongly associated with depression, anxiety, and PTSD. The Better Access scheme applies when a diagnosable mental health condition is present:
| MBS Item | Description |
|---|---|
| Item 2700 | Mental Health Treatment Plan (MHTP) by GP |
| General attendance | Review of MHTP (time-tiered) |
| Items 2721/2723/2725/2727 | GP-provided focussed psychological strategies (FPS) |
- Under the Better Access scheme, patients can access up to 10 individual psychology sessions per calendar year (six initially, then review for further four).
- For complex conditions including chronic pain with significant mental health burden, this is often insufficient; document clearly and advocate for patients needing additional care.
Prolonged Consultation Items
Complex chronic pain patients frequently require extended consultations for medication review, opioid tapering discussions, or care coordination:
| MBS Item | Duration | Notes |
|---|---|---|
| Item 23 | Standard consultation up to 20 min | Routine review |
| Item 36 | Consultation 20-40 min | Medication review, opioid tapering |
| Item 44 | Consultation ≥40 min | Complex management; multiple comorbidities |
| Item 2199 | Home visit ≥40 min | Homebound patients with severe chronic pain |
Do not time-truncate consultations to bill a lower item: bill for the time and complexity actually delivered, with documentation to match.
MBS Items for Opioid Dependence
Opioid Treatment Programs and Structured Care
- Opioid dependence is classified as a chronic condition and qualifies for a GPCCMP in the same way as other chronic diseases.
- However, it also involves specific state-regulated frameworks for OST prescribing (methadone, buprenorphine, buprenorphine-naloxone).
Items applicable to opioid dependence management:
| MBS Item | Application |
|---|---|
| 965 / 967 | GPCCMP and review, as above |
| 2700 series | MHTP if co-morbid mental health condition |
| 36 / 44 | Extended consultations for complex case management |
| Item 3 (or 23) | Initial assessment of a new patient presenting with opioid dependence |
Opioid Substitution Therapy: Prescribing Authority
OST in Australia is regulated at both Commonwealth (PBS) and state/territory level. GPs must hold specific authority to prescribe OST in their jurisdiction:
- State/territory authority: varies by state; most require completion of an accredited training program and a permit or authority to prescribe Schedule 8 opioid treatment medications
- PBS authority prescriptions: methadone and buprenorphine-naloxone (Suboxone) and buprenorphine (Subutex, Sublocade) require PBS Authority approval
- Streamlined vs telephone authority: buprenorphine-naloxone maintenance has a streamlined authority (write on script); initiation of new patients or dose changes above threshold often require telephone or online authority
Key OST PBS considerations:
| Drug | Form | Authority Type | Key Notes |
|---|---|---|---|
| Methadone | Oral liquid | Telephone/written authority; state permit | Daily supervised dosing initially; dose stabilisation over weeks |
| Buprenorphine-naloxone (Suboxone) | Sublingual film/tablet | Streamlined for maintenance | Standard first-line; naloxone component deters injection |
| Buprenorphine (Sublocade) | Monthly SC injection | Authority required | Improves adherence; reduces diversion risk |
| Buprenorphine (Buvidal) | Weekly or monthly SC injection | Authority required | Long-acting depot; useful in unstable housing |
Initiating OST in general practice:
- Confirm opioid dependence (ICD-10 criteria; COWS score if in mild withdrawal)
- Complete state-mandated training and hold relevant prescribing authority
- Discuss and document informed consent including risks, supervised consumption requirements, and urine drug screening
- Start buprenorphine-naloxone at 4-8 mg (sublingual) once mild-moderate withdrawal confirmed (COWS ≥8) to avoid precipitated withdrawal
- Stabilise dose over days to weeks; usual maintenance 8-24 mg/day
- Arrange supervised dispensing through community pharmacy; document takeaway dose progression
Medication Reviews in Opioid Dependence
Home Medicines Review (HMR) and Residential Medication Management Review (RMMR):
- Initiated by GP referral to an accredited pharmacist
- Relevant when patient is on complex polypharmacy (OST plus benzodiazepines, antidepressants, antipsychotics)
- GP receives written report and conducts a follow-up consultation (item 900, 903)
| MBS Item | Description |
|---|---|
| Item 900 | GP consultation after HMR report |
| Item 903 | GP consultation after RMMR |
PBS Considerations for Chronic Pain Medications
Opioid Analgesics: Authority Requirements
Strong opioids for chronic non-cancer pain require PBS authority prescriptions in most cases:
| Drug | PBS Status | Key Condition |
|---|---|---|
| Oxycodone CR | Authority required | Documented failure of non-opioid therapy; ongoing specialist input recommended |
| Morphine SR | Authority required | As above |
| Fentanyl patch | Authority required | Typically for patients unable to take oral medications |
| Buprenorphine patch (Norspan) | Streamlined authority | For chronic non-malignant pain; $\leq 20\,\mu\text{g/hr}$ patch |
| Tramadol | General benefit | No authority required up to standard dosing |
| Codeine (OTC removed 2018) | Now prescription only | Rescheduled; prescription required |
Authority prescribing principles for CNCP:
- Document the indication, failed alternatives, functional goals, and risk assessment (including PDMP check)
- Prescriptions for Schedule 8 drugs must comply with state regulations: handwritten or approved electronic format, patient's name/address, prescriber details, quantity, and repeats as permitted
- Most states require a Prescription Drug Monitoring Program (PDMP) check (e.g. SafeScript in Victoria, NarxCare in other states) before issuing Schedule 8 prescriptions
Non-Opioid PBS Items Relevant to Chronic Pain
| Drug Class | Examples | Relevance |
|---|---|---|
| Antidepressants (TCAs) | Amitriptyline | Neuropathic pain; no authority; low PBS cost |
| SNRIs | Duloxetine | Neuropathic pain; authority for diabetic peripheral neuropathy |
| Anticonvulsants | Pregabalin, gabapentin | Neuropathic pain; authority required for specific indications |
| Topical agents | Lignocaine patches, capsaicin | Limited PBS listing; may be private script |
| NSAIDs | Celecoxib, naproxen | PBS listed; caution in elderly and renal impairment |
75+ Health Assessment and Chronic Pain/Opioid Dependence
Older patients with chronic pain or long-term opioid use warrant specific considerations in the 75+ Health Assessment (MBS item 703):
- Screen for falls risk: opioids increase falls risk significantly
- Assess cognitive function (MMSE/GPCOG): opioid-related cognitive impairment
- Medication reconciliation: polypharmacy with opioids, benzodiazepines, gabapentinoids is a high-risk combination
- Document functional status and pain impact on activities of daily living
- Review appropriateness of ongoing opioid prescribing; opioid tapering may be appropriate with adequate non-pharmacological support
Item 703 can be complemented by:
- Item 900 (after HMR): to rationalise polypharmacy
- Item 965: to coordinate multidisciplinary pain or addiction care via direct allied health referral
Complications and Special Considerations
Medico-Legal and Prescribing Safety
- Informed consent documentation: for long-term opioid therapy, document the risks (dependence, overdose, cognitive effects, hormonal effects), the opioid treatment agreement, and patient goals
- Opioid treatment agreements: not mandatory but strongly recommended; document expectation of urine drug screening, single prescriber policy, and conditions for dose change
- Concurrent prescribing of opioids and benzodiazepines: the combination is the leading cause of prescription opioid overdose death in Australia; if prescribing both, document clinical justification explicitly
- Safe storage counselling: advise all patients receiving opioids on safe storage; document this advice
- Naloxone co-prescribing: PBS-subsidised naloxone (Prenoxad or Nyxoid) should be offered to all patients on high-dose opioids or OST; document the offer and patient education provided
Aboriginal and Torres Strait Islander Patients
- Access to PBS medicines under the Closing the Gap PBS Co-payment (CTG PBS) for eligible patients: reduces out-of-pocket costs for PBS medicines to zero or minimal co-payment
- Requires registration with the practice's Indigenous health program and consent
- For OST, ensure cultural safety in supervised dosing arrangements; consider liaison with Aboriginal Community Controlled Health Services (ACCHS)
- The Practice Incentive Program (PIP) Indigenous Health Incentive supports practices providing best-practice care; relevant when managing chronic pain in this population
Refugee and Migrant Health
- Newly arrived refugees may have undertreated chronic pain from prior trauma or conflict-related injuries
- Initial health assessment: MBS item 701 (refugee health assessment) within 12 months of arrival
- Interpreter services: Medicare funds interpreter use; document interpreter-assisted consultations
Long-Term Care and Monitoring Framework
Structured Review Schedule for Chronic Pain
| Review Frequency | Activity | MBS Item |
|---|---|---|
| Every 3 months, if clinically relevant | GPCCMP review; pain score; functional assessment; medication reconciliation | 967 |
| Every 6 months | Urine drug screen (if on Schedule 8); PDMP check; allied health progress review | 36/44 |
| Annually | GPCCMP renewal; 75+ assessment if eligible; HMR if complex polypharmacy | 965/703/900 |
| As needed | Mental health review; MHTP if comorbid condition deteriorates | 2700/2701 |
Structured Review Schedule for Opioid Dependence (OST)
- Weekly to monthly GP reviews during dose stabilisation: bill item 23/36/44 as appropriate
- Pharmacy supervised dosing records should be available and reviewed
- Urine drug screens: document findings and clinical response; do not discharge patients solely for positive screens without clinical assessment
- Gradual reduction in supervised dosing frequency (takeaway doses) as stability is demonstrated; document decision-making
- Annual GPCCMP, with direct referral to social work and psychology, and coordination with addiction medicine
When to Refer
- Pain specialist/anaesthetist-led pain clinic: persistent CNCP not responding to multimodal management; consideration of interventional procedures
- Addiction medicine specialist: complex OST initiation, high-risk polydrug use, psychiatric comorbidity requiring integrated care
- Psychiatrist: significant co-morbid mental illness; risk of self-harm
- Emergency department: signs of opioid toxicity (respiratory rate <12/min, pinpoint pupils, reduced GCS); administer naloxone and call 000
Quick-Reference Summary Table
| Clinical Scenario | Key MBS Items | Key PBS/Authority Considerations |
|---|---|---|
| New CNCP patient, establishing care | 965, then 10950-10970 series | Authority scripts for strong opioids; PDMP check |
| Ongoing CNCP, 3-monthly review | 967, 36/44 | Review authority; opioid treatment agreement |
| Co-morbid depression/anxiety | 2700, 2701 | Nil specific PBS authority for antidepressants |
| Opioid dependence, initiating OST | 965, 36/44 | State permit; PBS authority for buprenorphine-naloxone or methadone |
| OST maintenance, stable patient | 967, 23/36 | Streamlined authority for buprenorphine-naloxone maintenance |
| Complex polypharmacy review | 900 (after HMR referral) | Pharmacist referral; GP review of HMR report |
| Older patient with chronic pain | 703, 965, 900 | Falls risk; cognitive screen; dose appropriateness |
| Aboriginal/Torres Strait Islander | 965, PIP Indigenous Health Incentive | CTG PBS co-payment registration |
| Refugee with chronic pain | 701 (initial assessment), then 965 | Interpreter funded; GPCCMP once established |