Medicare Billing and Government Initiatives for Mental Healthcare Funding

Definition / Overview

Mental healthcare funding in Australian general practice is underpinned by a suite of Medicare Benefits Schedule (MBS) items, the Better Access initiative, and complementary government programs. GPs are the primary gateway for most patients accessing subsidised mental health services, and accurate billing directly affects patient access, continuity of care, and the GP's medicolegal accountability.

Key programs include:

• Better Access to Mental Health Care (the dominant GP-initiated pathway)
• Mental Health Care Plans (MHCPs) under MBS items 2700 series
• GP Management Plans (GPMPs) and Team Care Arrangements (TCAs) for mental health as a chronic condition
• Headspace and Head to Health centres (youth and adult primary mental health access points)
• MBS psychological therapy items (psychiatrist-referred, distinct from Better Access)
• Chronic Disease Management (CDM) items where mental illness is the chronic condition
• Atsi-specific items including the Aboriginal and Torres Strait Islander health assessment (MBS 715) with its mental health component

The Better Access Initiative: Core Framework

What Better Access Provides

Better Access enables eligible patients to receive Medicare rebates for sessions with psychologists, social workers, and occupational therapists (mental health credentialed). The GP's role is:

1. Conducting a mental health assessment
2. Preparing a Mental Health Treatment Plan (MHTP)
3. Referring to an eligible allied health professional
4. Reviewing the plan at defined intervals

Patients can access up to 10 individual sessions per calendar year under Better Access. As of the post-pandemic settings (from late 2022 back to the standard cap), the annual entitlement returned to 10 sessions following the temporary COVID-era extension to 20. Confirm the current cap at the time of exam, as this has been subject to policy review.

Sessions are split: the first referral covers up to 6 sessions, then a GP review must occur before a further 4 sessions are authorised for that calendar year.

MBS Items for Mental Health Treatment Plans

Item 2700 Series: MHTP Preparation and Review

Key billing rules:

• Item 2701 cannot be billed on the same day as a standard Level B/C/D consultation item (items 23, 36, 44) unless the MHTP is a separate, distinct service.
• The MHTP must include: diagnosis/problem statement, treatment goals, referral details, and review date.
• A GP can bill the MHTP items and the allied health referral on the same day.

Practical Distinction: MHTP vs GPMP/TCA

A patient with severe depression as a chronic condition may benefit from both a MHTP and a GPMP/TCA: the GPMP/TCA enables referral to a broader team (dietitian, exercise physiologist), while the MHTP enables subsidised psychology sessions.

MBS Allied Health Sessions Under Better Access

Eligible Providers

• Clinical psychologists (higher rebate, no specific referral criteria beyond MHTP)
• Registered psychologists (lower rebate)
• Mental health-credentialed social workers
• Mental health-credentialed occupational therapists

Rebate Structure

Clinical psychologists attract a higher MBS rebate than other allied health providers. The out-of-pocket cost to the patient varies by provider. Bulk billing of these sessions is at provider discretion; many clinical psychologists do not bulk bill, creating an affordability barrier.

Session Counting and Calendar Year Reset

• Sessions are counted per calendar year (1 January to 31 December).
• After the 6th session, the GP must conduct a formal review (item 2712) before issuing a new referral for the remaining 4 sessions.
• If a patient has used all 10 sessions and their clinical need is ongoing, options include: review at start of next calendar year, consider psychiatry referral, or explore Head to Health/Headspace where appropriate.

Conducting a Mental Health Assessment: Clinical Standards

A valid MHTP requires a structured mental health assessment. Document:

1. Presenting problem and history (onset, duration, severity, precipitants)
2. Mental state examination (affect, thought, cognition, insight, risk)
3. Validated screening tool results: K10 (Kessler Psychological Distress Scale), PHQ-9, GAD-7, Edinburgh Postnatal Depression Scale (EPDS) as appropriate
4. Risk assessment: suicidality, self-harm, harm to others
5. Diagnosis using DSM-5 or ICD-10 criteria
6. Treatment goals (patient-centred, measurable where possible)
7. Proposed interventions (referral details, medication if applicable)
8. Review plan

The K10 is the most commonly used tool in Australian general practice for screening and monitoring psychological distress:

$$\text{K10 Score Range: } 10\text{-}50$$

Telehealth Billing for Mental Health

Since the COVID-19 pandemic, telehealth has become embedded in GP practice. Mental health telehealth items allow:

• Phone and video consultations for MHTP preparation and review (items 2700, 2710 in particular)
• Allied health providers can also deliver Better Access sessions via telehealth under specific MBS items
• Eligibility criteria for telehealth: established patient relationship (for phone), or any patient for video

Telehealth has improved access for patients in rural and remote areas, those with mobility limitations, and those with anxiety disorders where leaving home is itself a barrier.

Headspace and Head to Health

Headspace

• National youth mental health foundation targeting 12-25 year olds
• Services: mental health, physical health, alcohol/other drugs, vocational support
• GPs can refer directly; no MHTP required for initial access
• Headspace centres are co-located in many communities; youth workers, GPs, and mental health clinicians are on-site
• Medicare items still apply when a GP within headspace provides services

Head to Health

• Federal government initiative providing adult primary mental health care
• Designed for people with mild to moderate mental illness
• Services include assessment, care coordination, and referral
• No GP referral required for self-referral; however, GP collaboration improves care coordination
• Relevant for patients who have exhausted Better Access sessions or who need a stepped care approach

Stepped Care Model

Australian mental health policy is framed around a stepped care model: matching intervention intensity to clinical need.

GPs operate primarily at steps 1-4, with step 4 requiring specialist collaboration.

Aboriginal and Torres Strait Islander Mental Health Funding

MBS 715 Health Assessment

The Aboriginal and Torres Strait Islander Health Assessment (MBS item 715) includes a mandatory mental and emotional wellbeing component. This must cover:

• Social and emotional wellbeing screen
• Risk factors: grief, loss, trauma, family stress, substance use
• Screening tools appropriate to ATSI populations (K10 is used but has limitations in some communities; local validated tools may be more appropriate)

Following a 715 assessment, if mental health needs are identified, a MHTP can be initiated (item 2701). The 715 and MHTP can be billed on the same day as they are distinct services.

Close the Gap PBS Co-payment Measure

• Aboriginal and Torres Strait Islander patients eligible for Closing the Gap PBS co-payment subsidies access medications at reduced cost
• Relevant for psychotropic medications (antidepressants, antipsychotics, mood stabilisers)
• GP must confirm eligibility and register the patient; a separate PBS prescription is written with the CTG annotation

Social and Emotional Wellbeing (SEWB) Teams

Many Aboriginal Community Controlled Health Organisations (ACCHOs) employ SEWB workers. GPs working in these settings should integrate SEWB team referrals within care plans. MBS billing for MHTP still applies; SEWB workers may or may not be MBS-credentialed depending on their qualification.

Chronic Disease Management and Mental Health

Where mental illness is a chronic condition (duration $\geq 6$ months, requiring multidisciplinary management), GPs can bill:

• MBS 721: GPMP preparation
• MBS 723: TCA preparation (requires $\geq 2$ collaborating providers; one must be a GP)
• MBS 732: Annual GPMP/TCA review

Under the TCA, up to 5 allied health services per calendar year are subsidised (items in the 10950 series). These are separate from the psychology sessions under Better Access. A patient can receive both Better Access psychology sessions AND allied health services under a TCA (e.g. exercise physiology for depression with comorbid obesity).

Medico-Legal and Billing Compliance Considerations

Documentation Standards

• The MHTP must be documented in the patient record and a copy provided to the patient.
• The referral letter to the allied health provider should reference the MHTP.
• Review documentation (item 2712) must clearly reflect a clinical review, not just administrative sign-off.

Common Compliance Errors

Voluntary Patient Contributions

• GPs and allied health providers can charge above the MBS rebate (gap payments).
• Patients on concession cards or with financial hardship should be identified for bulk billing or reduced-fee services.
• Bulk billing incentive items exist for concession card holders and children under 16 in some MBS streams.

Special Populations and Considerations

Perinatal Mental Health

• EPDS is the recommended screening tool in the antenatal and postnatal period.
• MHTP can be initiated in pregnancy; importantly, obstetric risk assessment should be integrated.
• Item 2701 applies; perinatal mental health is not separately billed but should be flagged in documentation.

Youth (Under 25)

• Headspace is the preferred pathway for mild to moderate illness.
• For more complex presentations, MHTP + Better Access applies from age 12 upward with parental consent considerations (Gillick competence applies).
• The Medicare Safety Net accumulates for families, reducing out-of-pocket costs over time.

Older Adults

• 75+ Health Assessment (MBS 701) includes a cognitive and mental health screen.
• If depression or anxiety is identified at the 75+ check, a MHTP can be initiated at the same visit (distinct service, separately billed).
• Cognitive assessment tools: MMSE, MoCA; separate item MBS 21 for cognitive testing in some contexts.

Practical Exam Tips

• Know the session split: 6 sessions first, review required, then up to 4 more = 10 total per calendar year.
• Know item numbers: 2701 (prepare MHTP), 2712 (review MHTP), 721/723 (GPMP/TCA).
• Stepped care framing: AKT questions often present a clinical scenario and ask for the most appropriate funding pathway; match severity to intervention.
• Same-day billing: MHTP + 715 = permissible; MHTP + standard consult = requires distinct service documentation.
• ATSI-specific: 715 triggers MHTP; CTG co-payment for medications; SEWB integration.
• Telehealth: phone items available for MHTP preparation and review; expands access but requires established patient relationship for phone-only.
• KFP framing: a patient who has used all 10 sessions before December: plan for January restart, consider psychiatry referral, explore Head to Health or Headspace, consider whether GPMP/TCA allied health items remain unused.