PSR Director's update for October 2024
A. Director’s Section 92 agreements effective in October 2024
19 agreements entered into by the Director and persons under review (in accordance with s 92 of the Act) came into effect in October:
An agreement with a General Practitioner.
During the review period, the practitioner rendered MBS item 3 (level A consultation) and 30064 (removal of subcutaneous foreign body requiring incision, exploration and closure of wound) services and prescribed PBS items 1215Y (paracetamol + codeine), 3162K (diazepam) and 2622B (oxycodone) in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 3, 23 (level B consultation), 721 (GP Management Plan (GPMP)), 723 (Team Care Arrangement (TCA)), 732 (review of GPMP or TCA), 30064 and 90035 (attendance on a patient in a residential aged care facility (RACF)), and PBS items 1215Y, 2622B and 3162K, The Director had persisting concerns that:
- The practitioner did not always attend patients for services billed as MBS items 3, 23 and 90035
- MBS requirements were not always met. For example, the practitioner rendered MBS item 30064 for removal of skin lesions which did not involve incision, exploration or removal of a foreign body and rendered chronic disease management (CDM) services to patients who did not have an eligible chronic condition
- the practitioner’s record keeping was inadequate. The practitioner’s notes were often brief, and lacked relevant clinical information
- PBS items were prescribed at times without clinical indication or adequate clinical input and management.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 3, 23, 721, 723, 732, 30064 and 90035 and prescribing PBS items 1215Y, 2622B and 3162K. The practitioner agreed to repay $190,000, to be disqualified from providing MBS item 721, 30064 and 92024 services for 12 months, and will be reprimanded and counselled by the Director.
An agreement with a General Practitioner.
During the review period, the practitioner rendered MBS item 2713 (attendance in relation to a mental disorder) in excess of 96 % of their peers and on each occasion rendered other professional attendance items in association, and rendered 80 or more attendance services on each of 27 days in breach of the prescribed pattern of services ‘80/20’ rule. The practitioner also prescribed PBS items 1215Y, 2348N (pregabalin 25mg), 2622B, 8865N (buprenorphine), 2335X (pregabalin 75mg) and 8814X (paracetamol) in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 707 (health assessment lasting at least 60 minutes), 731 (contribution by a general practitioner to a multidisciplinary care plan), 2713, 5028 and 91891 (telehealth consultation lasting at least 6 minutes), PBS items 1215Y, 2622B, 3162K and 8865N, and their provision of a prescribed pattern of services. The Director had persisting concerns that:
- the practitioner rendered a prescribed pattern of services and exceptional circumstances were not present on any of the 27 days
- the practitioner did not always attend patients for services billed as MBS items 23, 707, 5028 and 91891
- the practitioner’s record keeping was inadequate. The practitioner’s record entries were brief, appeared to be template-based and not always appropriately individualised for the patient,
- MBS requirements were not always met, including minimum time requirements where relevant, and
- the practitioner did not adequately manage patients to whom they prescribed under the PBS and the practitioner’s prescribing of PBS item 3162K and 8865N was not always clinically indicated.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23, 707, 731, 2713, 5028 and 91891, prescribing PBS items 1215Y, 2622B, 3162K and 8865N, and in rendering a prescribed pattern of services. The practitioner agreed to repay $251,500 and will be counselled by the Director.
An agreement with a General Practitioner.
During the review period, the practitioner rendered MBS items 36, 44 (level C consultation), and 90043 (attendance on a patient in a RACF lasting at least 20 minutes) excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 36, 44, 699 (health assessment lasting between 30 and 45 minutes), 703 (health assessment lasting between 30 and 45 minutes), 705 (health assessment lasting between 45 and 60 minutes), 721, 723, 732, 90043 and 91891, and had no concerns in relation to MBS item 91891. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate. The practitioner used template plan documents that were not sufficiently comprehensive or individualised to their patients, and
- MBS requirements were not always met, including not performing tasks specified in the item descriptor for MBS item 36, 44 and 90043 where it was clinically relevant to do so.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 36, 44, 699, 703, 705, 721, 723, 732 and 90043. The practitioner agreed to repay $289,000, to be disqualified from providing MBS item 703, 705, 732 and 92028 services for 12 months, and will be reprimanded by the Director.
An agreement with a General Practitioner.
During the review period, the practitioner rendered MBS item 707 , 731, 732, 5028, 91800 (telehealth consultation lasting between 6 and 20 minutes) and 93680 (nicotine and smoking cessation counselling) in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 36, 707, 721, 723, 731, 732, 5028, 45201 (muscle, myocutaneous or skin flap repair of surgical excision), 91800, 91891 and 93680, and had no concerns in relation to MBS items 721 and 723. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate. For example, for MBS item 23 and 36 services, their notes were often composed primarily of shortcut-based lists of negative observations which were mostly irrelevant to the consultation,
- MBS requirements were not always met, including minimum time requirements where relevant and MBS item 732 services for review of TCAs did not involve the required two-way communication with collaborating providers, and
- the practitioner did not always provide sufficient clinical input to justify billing other item services that were co-billed with professional attendance items.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23, 36, 707, 731, 732, 5028, 45201, 91800, 91891 and 93680. The practitioner agreed to repay $275,000, to be disqualified from providing MBS item 707, 732, 45201 and 92028 services for 12 months, and will be counselled by the Director.
An agreement with a Radiologist.
During the review period, the practitioner billed MBS items 12306, 12320 and 12322 (bone densitometry diagnostic investigation items) in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 12306, 12320, 12322, 57933 (full mouth X-Ray) and 57963 (orthopantamography). The Director had persisting concerns that:
- MBS requirements were not always met, including where the practitioner did not provide the requested diagnostic imaging but instead accepted images that had been both requested by and performed by the requesting provider without any feedback as to appropriateness or adequacy of the images.
- the practitioner did not always provide adequate clinical input. For example, they did not always provide appropriate clinical comments on notable features in scans or engage with questions from referrers, and
- the practitioner did not always determine whether MBS item 57933 and 57963 services were clinically relevant.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 12306, 12320, 12322, 57933 and 57963. The practitioner agreed to repay $200,000 and will be counselled by the Director.
An agreement with a general practitioner.
During the review period, the practitioner rendered MBS items 705, 5028 and 90035 and prescribed PBS items 8865N, 10096J in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 705, 5020 (level B consultation afterhours), 5028 and 90035, and prescribing of PBS items 8865N (buprenorphine) and 10096J (tapentadol), and had no concerns in relation to MBS items 23 and 5020. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate including that for some services there was no entry in the record for the date on which the service was billed
- MBS requirements were not always met, and it was not always clear whether the practitioner provided sufficient clinical input to justify the billing of a level B consultation or a long health assessment, and
- the practitioner provided inadequate clinical management of patients to whom they prescribed drugs of addiction and dependence.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 705, 5028 and 90035 and prescribing PBS items 8865N and 10096J. The practitioner agreed to repay $87,000, to be disqualified from providing MBS item 705 services for 12 months, and to be counselled by the Director.
An agreement with a general practitioner.
During the review period, the practitioner was nationally ranked 1st for rendering MBS item 732, 2nd for rendering MBS item 723 and 3rd for rendering MBS item 721. They also initiated MBS item 69480 (COVID-19 pathology test), and prescribed PBS items 1215Y and 2622B in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 36, 721, 723, 732, 5020 and 91891, initiation of MBS item 69480 and prescribing of PBS items 1215Y and 2622B. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate. The practitioner’s record entries frequently failed to include sufficient clinical information to explain what occurred during consultations and another practitioner would not be able to effectively continue care for patients in reliance of the records,
- MBS requirements were not met, including minimum time requirements where relevant. It was also not always clear that the practitioner personally attended patients for chronic disease management (CDM) services, and
- the practitioner did not provide adequate clinical input when prescribing medication, initiating pathology or providing CDM services.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23, 36, 721, 723, 732, 5020 91891, initiating MBS item 69480 and prescribing PBS items 1215Y and 2622B. The practitioner agreed to repay $625,000, to be disqualified from providing MBS item 723, 732, 92025, 92028 services for 12 months, and to be counselled by the Director.
An agreement with a general practitioner.
During the review period, the practitioner rendered MBS items 705, 721, 723, 732, 2712 (review of GP mental health treatment plan), 45201 and in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 36, 705, 721, 723, 732, 2712, 45201 and 90043. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate. The practitioner’s record entries did not always include sufficient clinical information to explain what occurred during consultations,
- MBS requirements were not always met, including minimum time requirements where relevant, and
- it was unclear whether therapeutic procedures were clinically indicated from the practitioner’s records.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23, 36, 705, 721, 723, 732, 2712, 45201 and 90043. The practitioner agreed to repay $395,000, to be disqualified from providing MBS item 36, 705, 723, 732, 90043, 91801, 91900, 92025, 92028 services for 12 months, and to be counselled by the Director.
An agreement with a general practitioner.
During the review period, the practitioner rendered MBS item 585 (urgent afterhours attendance), 705 and 5028 initiated MBS item 66596 (iron studies), and prescribed PBS items 8865N and 2622B in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 585,705, 5028, 90035 and 91891, initiating of MBS item 66596, prescribing of PBS items 2622B and 8865N, and provision of a prescribed pattern of services (the 80/20 rule). The Director had persisting concerns that:
- there were not exceptional circumstances that affected the rendering of 80 or more services on each of 20 days,
- the practitioner’s record keeping was inadequate. Records did not always include adequate documentation of history, examination and management plan.
- MBS requirements were not met, including minimum time requirements where relevant
- initiated pathology services were not always clinically indicated, and were often rendered as part of a routine suite of screening tests, and
- the practitioner’s management of patients to whom they prescribed drugs of addiction was inadequate.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23, 585, 705, 5028, 90035 and 91891, initiating MBS item 66596, prescribing PBS items 2622B and 8865N, and the prescribed pattern of services. The practitioner agreed to repay $110,000, and to be counselled by the Director.
An agreement with a rheumatologist.
During the review period, the practitioner was nationally ranked 1st for initiating MBS item 12315, 6th for MBS item 12312 (bone densitometry diagnostic investigation items), 2nd for rendering MBS item 12306 and 4th for MBS items 12320, 12321 and 12322. The practitioner was also nationally ranked 1st for prescribing PBS items 11373N (golimumab), and 7250N (methotrexate) and 3rd for PBS items 11675L (tofacitinib), and 12624K (upadacitinib). The Director reviewed this practitioner’s rendering of MBS items 110 (initial attendance by a consultant physician), 116 attendance by consultant physician subsequent to initial attendance), initiation of MBS items 12306, 12312, 12315, 12320, 12321 and 12322, and prescribing of PBS items 7250N, 10899P (secukinumab), 11373N (golimumab), 11375Q (golimumab), 11443G (baricitinib), 11675L (tofacitinib), and 12624K and had no concerns in relation to MBS items 110 and 116 and PBS items 11443G and 11675L. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate. The practitioner’s records were at times vague and included incorrect details about the patient’s presentation and management,
- MBS requirements were not always met, including eligibility requirements for bone densitometry services,
- PBS requirements were not always met, and the practitioner did not provide adequate clinical input when prescribing, and
- the practitioner did always provide adequate clinical input into services. For example, the practitioner did not personally determine whether each bone densitometry procedure was clinically indicated and sometimes failed to include clinically relevant information in their reports.
The practitioner acknowledged having engaged in inappropriate practice in connection with initiating MBS items 12306, 12315 and 12322 and prescribing PBS items 7250N, 10899P, 11373N, 11375Q and 12624K. The practitioner agreed to be reprimanded by the Director.
An agreement with a general practitioner.
During the review period, the practitioner rendered MBS items 23, 36, 44, 707, 5020, 5040 (level C consultation afterhours), 31358 (excision of malignant lesion larger than 6mm), 31363 (excision of malignant lesion 14mm or larger), in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 36, 44, 707, 5020, 5040, 31358 and 31363. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate. Entries in the records often did not include sufficient clinical information to explain what occurred at consultations,
- MBS requirements were not always met, including minimum time requirements where relevant, and
- the practitioner’s clinical input and management was inadequate. Skin lesions were removed without appropriate assessment including using a dermatoscope or biopsy and discussion of alternatives to surgery with patients.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23, 36, 44, 707, 5020, 5040, 31358 and 31363. The practitioner agreed to repay $300,000, and to be counselled by the Director.
An agreement with a general practitioner.
During the review period, the practitioner rendered MBS items 36 and 5040 in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 36, 5040 and 91891. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate. The practitioner’s record entries relied on template wording that was not sufficiently individualised to the patient’s presentation and another practitioner would not be able to effectively continue care for patients in reliance of the records,
- MBS requirements were not met, including minimum time requirements where relevant.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 23, 36, 5040 and 91891. The practitioner agreed to repay $275,000, to be disqualified from providing MBS item 5040 and 91801 services for 12 months, and to be counselled by the Director.
An agreement with a medical practitioner
During the review period, the practitioner rendered MBS item 53 (attendance between 5 and 25 minutes by a medical practitioner who is not a general practitioner), MBS item 54 (attendance between 25 and 45 minutes by a medical practitioner who is not a general practitioner) and MBS item 5203 (attendance between 25 and 45 minutes by a medical practitioner who is not a general practitioner afterhours) in excess of 99% of their peers. The practitioner also prescribed PBS items 7530H (codeine) and 8214H (atorvastatin), in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 53, 54, 229 (preparation of a GPMP by a medical practitioner who is not a general practitioner) and 5203, initiation of MBS item 66833 (vitamin D quantification), and prescribing of PBS items 7530H and 8214H, and had no concerns in relation to PBS items 8214H. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate, as their records were often illegible and would not have allowed another practitioner to effectively take over patient care in reliance of the record,
- MBS requirements were not met, including minimum time requirements where relevant
- pathology services were initiated without clinical indication,
- the practitioner’s clinical management of patients to whom they prescribed PBS item 7530H was inadequate.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS items 53, 54, 229 and 5203, initiation of MBS item 66833 and prescribing PBS item 7530H. The practitioner agreed to repay $157,500, and to be counselled by the Director.
An agreement with a Medical Practitioner.
During the review period, the practitioner rendered MBS items 53 and 224 (brief health assessment) in excess of 99% of their peers. The practitioner also prescribed PBS items 2335X, 26622B and 3162K in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 53 and 224, and prescribing of PBS items 2335X, 2622B and 3162K, and had no concerns in relation to PBS items 2335X. The Director had persisting concerns that:
- MBS requirements were not met including minimum time requirements where relevant.
- the practitioners record keeping was inadequate. For MBS item 224 services, the patient’s recorded visual acuity was at times inaccurate or inconsistent with other documented medical information contained in the patient record.
- the practitioner’s clinical management of patients to whom they prescribed PBS items 2622B and 3162K was inappropriate
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 53 and 224 and prescribing PBS Items 2622B and 3162K. The practitioner agreed to no repayment and to be counselled by the Director.
An agreement with a General Practitioner.
During the review period, the practitioner rendered MBS item 91891 in excess of 99% of their peers. The practitioner also prescribed PBS items 03162K, 03133X and 08525Q in excess of 99% of their peers and rendered 30 or more telephone attendance items on each of 30 days in breach of the prescribed pattern of services ‘30/20’ rule. The Director reviewed this practitioner’s rendering of MBS items 91891, and prescribing of PBS items 3133X, 3162K and 8525Q. In respect of the prescribed pattern of services, the Director considered exceptional circumstances existed on each of the 30 days on which the practitioner rendered 30 or more relevant phone attendances. The Director had persisting concerns that:
- the practitioner’s record keeping was inadequate. For example, entries did not always include adequate history or examination where relevant.
- MBS requirements were not always met. For example, there was not always a record of an attendance on a patient and actions required by the item descriptor where clinically relevant were not always undertaken.
- the practitioner prescribed drugs of addiction at times without clinical indication or adequate management.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 91891 and prescribing PBS Items 3133X, 3162K and 8525Q. The practitioner agreed to repay $53,000 and to be counselled by the Director.
An agreement with a General Practitioner.
During the review period, the practitioner’s rate of rendering MBS items 23, 5020 and 91891 (level B consultations) in excess of 99% of their peers, the practitioner’s total MBS services rendered and high daily servicing raised concern as to whether each service was clinically relevant and met all MBS requirements. The Director reviewed this practitioner’s rendering of MBS items 23, 36, 721, 723, 5020 and 91891. The Director had persisting concerns that:
- the practitioner’s records were not always adequate and often lacked sufficient clinical information to explain what occurred during consultations.
- The practitioner did not always provide adequate clinical input for services by not addressing all of a patient’s presenting complaints,
- MBS requirements were not met including minimum time requirements where relevant.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 23, 36, 721, 723, 5020 and 91891. The practitioner agreed to repay $250,000 and be counselled by the Director.
An agreement with a General Practitioner.
During the review period, the practitioner rendered MBS items 23, 5020 and 91890 in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 5020 and 91890. The Director had persisting concerns that:
- the practitioner did not always meet the MBS requirements when rendering attendance items. For example, services did not always involve sufficient complexity to justify the MBS item requirements and actions required by the item descriptor where clinically relevant were not always undertaken.
- the practitioner’s record keeping was inadequate. Entries in the records failed to include sufficient clinical information to explain what happened during consultations and lacked other clinically necessary detail.
- the practitioner did not always provide sufficient clinical input. For example and the practitioner did not adequately address abnormal test results or prescription alerts with a patient.
- the practitioner did not always provide appropriate clinical management for patients for whom medications were prescribed.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 23, 5020 and 91890. The practitioner agreed to repay $39,000 and be counselled by the Director.
An agreement with a General Practitioner.
During the review period, the practitioner rendered a volume of total and daily services (including services per patient) disproportionately to peers. The practitioner also prescribed PBS item 8254K in excess of 99% of their peers. The Director reviewed this practitioner’s rendering of MBS items 23, 721, 723, 732 and 91891, and prescribing of PBS item 8254K, The Director had persisting concerns that:
- the MBS requirements were not always met for the services. For example, actions required by the item descriptor where clinically relevant were not always undertaken,
- the record keeping was inadequate. For example, many entries in the records did not include sufficient clinical detail to explain what occurred during the service,
- The practitioner did not provide adequate clinical input in respect of CDM services,
- PBS item 8254K was prescribed where it was not always clinically indicated or clear that PBS requirements were met.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 23, 721, 723, 732 and 91891 and prescribing PBS Items 8254K. The practitioner agreed to repay $460,000, to be disqualified from providing MBS item 721, 723, 732, 91800, 91891, 92024, 92025 and 92028 services for 12 months, and will be reprimanded and counselled by the Director.
An agreement with a General Practitioner.
During the review period, the practitioner rendered a volume of total and daily services (including services per patient) disproportionately to peers. The Director reviewed this practitioner’s rendering of MBS items 23, 732, 5020, 91890 and 91891, and had no concerns in relation to MBS items 23, and 5020. The Director had persisting concerns that:
- MBS requirements were not always met including minimum time requirements where relevant.
- for MBS item 732 services, the records did not provide clear indication of the GP management plan being reviewed by the practitioner, or that there was collaboration with 2 or more providers, as per the item descriptor, where a team care arrangement was reviewed.
- For MBS item 91890, the records did not always reflect that a phone attendance with a patient occurred.
The practitioner acknowledged having engaged in inappropriate practice in connection with rendering MBS Items 732 and 91890. The practitioner agreed to repay $49,500, and to be disqualified from providing MBS item 732, the telehealth equivalent MBS item 92028 services for 12 months and be counselled by the Director.
B. No further action decisions
There were no decisions to take no further action in September 2024.
C. PSR Committee final determinations
PSR Committee 1494
On 10 October 2024 a final determination came into effect regarding an opthalmologist. The practitioner was found to have engaged in inappropriate practice in a final report of a PSR Committee in connection with MBS items 104, 42702 (lens extraction and insertion of intraocular lens) and 42788 (laser capsulotomy) services during the review period.
The practitioner was directed to:
- be reprimanded
- be counselled
- repay the amount of $360,000 to the Commonwealth in respect of MBS item 104, 47202 and 42788 services in connection with which the practitioner was found to have engaged in inappropriate practice.
- The practitioner be disqualified from rendering:
- MBS item 104 services for 6 months, and
- MBS item 47202 and 42788 services for 18 months,
- The MBS requirements were not met, including that the practitioner did not have any input into the consultation on the date of service or did not provide sufficient clinical input to justify rendering an MBS item 104 service (separate from co-billed items), the service was a subsequent attendance in a single course of treatment and/or there was no referral for the service, as required,
- The treatment was not indicated and therefore not clinically relevant,
- The practitioner’s clinical input into the service was insufficient or inadequate,
- The practitioner’s clinical management was inadequate,
- The medical record was inadequate, including in relation to the history taken, examination findings and informed patient consent, as well as the absence of any correspondence, or adequate correspondence, back to the referring practitioner.
In relation to the MBS item 42702 services the Committee made findings based on one or more of the following:
- The service was not clinically indicated,
- The practitioner’s clinical input into the service was insufficient or inadequate, including in relation to the reasons for performing the service and their post-operative management of the patient,
- The practitioner did not obtain properly informed patient consent for the service,
- The medical record was inadequate, misleading and/or inaccurate, including in relation to the practitioner’s clinical input, the patient’s diagnosis, informed patient consent and the content of correspondence back to the referring practitioner.
In relation to the MBS item 42788 services the Committee made findings based on one or more of the following:
- The service was not clinically indicated, including that there was no clinical basis for performing bilateral laser capsulotomies over consecutive days. The Committee considered this was done in the practitioner’s financial interests to maximise the Medicare rebate available, and was not in the patient’s best interests.
- The practitioner’s clinical input into the service was insufficient or inadequate, including in relation to the reasons for performing the service, obtaining informed patient consent, the excessive total energy levels used to perform the capsulotomy service and their post-operative management of the patient.
- The medical record was inadequate, misleading and/or inaccurate, including in relation to the practitioner’s clinical input, patient consent and the content of correspondence back to the referring practitioner.
D. Federal Court
No final decisions concerning PSR were handed down in October 2024.
E. Referrals to the major non-compliance (fraud) division (89A & 106N)
No matters were referred to the major non-compliance (fraud) division in October 2024.
F. Referrals to AHPRA (106XA/XB)
2 matters were referred to AHPRA in October 2024.