Administrative Position Statements (APS)
About Administrative Position Statements
Medicare Australia is focused on making it easier for providers to do business with us. You have told us that clear, accurate, consistent and timely information is key to ‘getting it right’ in meeting your obligations.
In response to your needs, we have introduced Administrative Position Statements (APS)—enabling the articulation of a single and consistent Medicare Australia position on matters requiring administrative interpretation.
What is an APS?
An Administrative Position Statement (APS) is an authorised and documented position held by Medicare Australia in relation to the interpretation of a specific Medicare Benefit Schedule (MBS) item or in relation to the administration of the MBS, Pharmaceutical Benefits Scheme (PBS) or associated government program, in particular, where there is ambiguity.
The APS process takes issues that are currently ambiguous or questions that cannot be answered using existing knowledge base resources and, through a consultative approach, formulates a definitive response taking into account any legal, clinical or assessing issues.
The process does not involve consideration of health policy matters, but is aimed at the interpretation of administrative issues. The process includes seeking advice from the Department of Health and Ageing (DoHA) and health professions where required. Exposure drafts will also be released for public review prior to finalisation of each APS.
An APS will state Medicare Australia’s definitive position to be applied by Medicare Australia staff and will contain:
- the issue/question being resolved
- associated item numbers
- the position taken
- background information that was relevant to the position taken
- a review date.
Health policy and legislation can change and so all Administrative Position Statements are reviewed at least once a year to ensure they are current and accurate.
What is the purpose of an APS?
The purpose of an APS is to provide an informed position on Medicare Australia’s interpretation and to:
- provide support with the resolution of interpretive issues
- improve access and quality of information to both Medicare Australia staff and the community
- provide a sound basis for compliance interventions
- provide health professionals with accurate and consistent information to enable them to comply with program requirements.
Administrative Position Statements are Medicare Australia’s authorised view on a particular issue and the core of Medicare Australia’s answers to questions from both internal and external stakeholders. Stakeholders will have confidence in the content of APS as they are necessary for determining claims for benefits. APS also set the framework by which we assess compliance by providers.
An APS is prospective in nature and as a general rule the date of application will correspond with the date of publication.
How do I dispute an APS?
Providers or patients may disagree with a claim assessment that has been assessed in accordance with an APS. Anyone wishing to dispute a claim assessment may do so by consultation with Medicare Australia through existing claims administration channels:
Call
General Medicare enquiries for practitioners 132 150*
General Medicare enquiries for public 132 011*
Email
medicare.prov@medicareaustralia.gov.au
Mail
Medicare Australia
GPO Box 9822
In your capital city
All other contact details are available on our contact page.
Providers may disagree with an audit finding that has been assessed in accordance with an APS. Disputes regarding an audit finding should be directed in writing to:
Director, National Compliance Operations
PO Box 9822
In your capital city.
Disputes regarding repayment of Medicare benefits following issue of a debt advisory notice* should be directed in writing to:
Manager, National Accounting Support Services
PO Box 9288
Sydney NSW 2001
or by email to NSW.FIN.BRS.Enquiries@medicareaustralia.gov.au
* Providers should quote the six digit customer number from the top right hand corner of Medicare Australia’s letter advising of the debt and their full name, address and provider number.
Topics under consideration
Draft Administrative Position Statements
Draft Administrative Position Statements for public comment
Final Administrative Position Statements
Final Administrative Position Statements
APS archive list
This section contains details of APS which have been archived. Reasons for archiving are provided below for each APS.
| APS Reference number | APS Question | Reason for archive | Date of archive |
|---|---|---|---|
| DPM 01/08 | How many times can MBS item 11600 be billed in any one day? |
MBS item descriptor for 11600 has been changed to clarify the number of times this item can be billed by a provider. As a result of this change, APS (MBS) 01/08 is no longer required. The legislation (item descriptor) has been amended since the exposure draft was first released on 11 December 2008. |
13/07/2009 |
Frequently Asked Questions (FAQs)
Frequently Asked Questions (FAQs) [PDF, 38Kb]
Frequently Asked Questions (FAQs) [RTF, 274Kb]
Feedback
Medicare Australia welcomes all feedback in order to further refine its processes.
If you would like to provide feedback on any aspect of the APS process please email—APS.Feedback@medicareaustralia.gov.au
The information collected will be used by Medicare Australia to assess feedback from providers. The collection of this information is authorised by the Health Insurance Act 1973. If the matters raised cannot be addressed by Medicare Australia then the information provided will be forwarded to the appropriate agency in a manner compliant with Section 14 of the Privacy Act 1988.
Request an APS
Health professionals are welcome to suggest APS topics for potential consideration.
In general, an issue will be eligible for the development of an APS if the following criteria are satisfied.
1. There is a need
- the issue relates to the administration of programs Medicare Australia is responsible for and is not an issue of health policy and /or
- there is inconsistency between the statutory instructions and advisory instructions (e.g. between the Health Insurance Regulations and the MBS) and /or
- health professionals/suppliers are unsure how to comply because the issue is ambiguous or lacks clarity and /or
- national inconsistency exists in administration and/or information provided by Medicare Australia because the issue is ambiguous or lacks clarity and /or
- clarification of the issue will assist in addressing a risk to Medicare Australia program and /or
- information currently held by Medicare Australia is insufficient to address the issue.
2. Broad coverage (not individual case)
- The issue is relevant to a significant number of users or members of a health professional group and is not specific to an individual case.
3. Benefits
- Clarification of the issue affects the amount of benefits and or volume of services.
4. Able to be implemented
- Medicare Australia resources enable APS to be implemented.
- The APS is consistent with Australian Public Service values.
5. Nothing to prevent (agency/govt perspective)
- Development of an APS on the issue does not conflict with Medicare Australia’s or Government’s priorities e.g. policy changes or Budget measures.
All requests are subject to an approval process. Each request is assessed against the APS criteria and considered in regard to Medicare Australia resources and priorities.
If the request for an APS is approved, the matter will be progressed and the topic will be listed on the website at Topic under consideration. Time period from receipt of request to time of listing will be approximately three months.
APS development process
The development of an APS can be a lengthy process that requires extensive research and consultation with the key stakeholders including the profession and the Department of Health and Ageing. It is anticipated that an APS may take up to six months to develop.
The APS process includes:
1. the development and approval of business case
2. a research and consultation phase including consultation with key stakeholders such as the profession and the Department of Health and Ageing
3. the development of draft APS and release of exposure draft for public comment
4. the finalisation of draft APS.
Medicare Australia reserves the right to withdraw or discontinue the development of an APS at any stage.
Mail:
Guidelines and Policy Section
Health Advisory Branch
Compliance and General Programs Division
PO Box 1001, Tuggeranong
ACT 2901
or email Request.APS@medicareaustralia.gov.au
Useful links
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Last updated: 19 March, 2010
