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of the MBS item descriptor were met,
but the specialist would be excluded from
claiming at all.
But an aged-care facility, no matter
where it is, is a telehealth-eligible area and a
telehealth item can be claimed. This means
nursing homes are in and GP practices in
non-telehealth eligible areas are out!
Remember, you can solve most telehealth
conundra by asking one simple question:
Where is the patient physically located at
the time the service is provided? But even
that can be baffling sometimes. Consider this
second example.
CASE STUDY 2
A patient attends the emergency department
of a rural hospital in a telehealth-eligible
area. The doctor seeing the patient would
like some specialist assistance in dealing
with the patient, so rapidly sends a referral
to a specialist and then conducts a video
consultation with the specialist. The patient,
at this point, has not been admitted to the
hospital. Can the specialist claim a
telehealth-consultation item number?
Medicare has always provided health-
sector funding across two distinct domains.
The first subsidises private services rendered
by health practitioners on a fee-for-service
basis, and the second is the provision of free
public-hospital services by federal grants
made to state and territory governments.
Since its inception, Medicare rebates have
been available to two categories of patients
­ inpatients and outpatients. So, if a patient
is located in the emergency department
and has not been admitted to the hospital,
the patient would be an outpatient and
therefore potentially eligible for a telehealth
consultation ­ right?
Wrong! Over many years our federal
and state governments have concocted
a magnificent interface between the
Health Insurance Act 1973 and three legal
documents, which together have redefined
the entire concept of an outpatient service
and, consequently, who funds what.
DEFINING MOMENTS
The National Healthcare Agreement 2012 is
the latest iteration of the agreement between
the federal and state governments to fund
public hospitals. It sets out the shared and
individual responsibilities of all parties to
the agreement, upholds the general Medicare
principles of equity and accessibility based
on clinical need and cross-references to the
National Healthcare Reform Agreement.
The National Healthcare Reform Agreement
provides details of the shared intentions of
all governments to deliver the COAG reform
agenda, including Activity Based Funding,
and features key operational provisions ­
known as `business rules' ­ which are found
in Schedule G.
Appendix A to the Agreement is the
definitions section, which cross-references to
the latest version of the National Health Data
Dictionary
, v16 2012.
Still with me?
For present purposes we can narrow
down the relevant definitions:
·Outpatientdepartmentmeansany
part of a hospital (excluding the
Emergency department) that provides
non-admitted patient care.
·Outpatientclinicserviceisdescribedas
`non-admitted patient service activity',
excluding emergency department.
As you can see, there are now two
subdivisions under the outpatient banner ­
non-admitted patient service and
emergency department.
Business rule G18 provides that eligible
patients presenting at a public-hospital
emergency department must be treated as
public patients before a decision to admit
is made, and business rule G17 prevents
emergency department patients being
referred to an outpatient department to
MEDICAl BIllING