This section sets out practical steps that practitioners, practice managers, PSR Committees, and advisers should take to align with the instrument’s requirements as drafted.
Records and documentation (comply with s 6)
- Implement record templates that enforce the s 6 minimums. Each patient encounter should have a discrete record entry that contains:
- The patient’s full name (s 6(a));
- A separate entry for each attendance (s 6(b));
- The date the service was rendered or initiated (s 6(c)(i));
- Sufficient clinical information to explain the service (s 6(c)(ii)) , a concise clinical summary of reason for service, clinical findings, diagnosis or working diagnosis and the clinical basis for the specific service billed; and
- Timestamping or workflow rules that record when the entry was completed and ensure entries are completed at the time or as soon as practicable after the service (s 6(c)(iii)).
- Ensure records are comprehensible to another practitioner (s 6(d)). That means avoiding unexplained acronyms or shorthand, including relevant observations and follow‑up instructions, and storing documentation in a retrievable, readable format (paper or electronic).
- Audit record‑keeping. Run periodic internal audits against the s 6 checklist to catch systemic shortfalls before they are examined under the Act.
Monitor service volumes and item use (comply with s 8 and s 5)
- Map which Medicare items your practice bills to the instrument’s lists of "relevant services" and "relevant phone services" (s 5). The instrument references Groups and Subgroups and lists specific item numbers; practices should extract those item numbers (for example item numbers 92176, 92177, 93302, 93305, 93308, 93311, 93423, 93453 and others listed in s 5) and tag them in internal billing systems.
- Track daily service counts per practitioner. To avoid unintentionally meeting the s 8 thresholds, implement reporting that counts the number of "relevant services" and "relevant phone services" per practitioner per day over rolling 12‑month windows.
- Prepare for the counting methodology. Because the instrument does not set out detailed counting rules (for example aggregation methods), develop and document a consistent internal counting method and, if necessary, seek clarification from PSR or the Department about the counting approach used in enforcement.
Document exceptional circumstances (use s 7)
- When a day’s activity spikes because of an unusual occurrence or because other services were absent, contemporaneously document the reason and the contextual factors that relate to the practice location and patient characteristics as required in s 7(b)(i)-(ii). Photographs, incident reports and contemporaneous logs will assist in establishing the exceptional circumstances defence under subsection 82(1D) of the Act.
Witness and hearing preparedness (s 9)
- If the practice or practitioner is likely to be involved in a PSR hearing as a party or a witness, plan for witness availability and likely compensation. Expert witnesses can claim actual fees for preparation and attendance (s 9(3)); ordinary witnesses can claim lost earnings up to $527 per day (s 9(4)). Confirm with the Committee any expectations regarding prior authorisation of fees and the scope of "reasonable" travel expenses (s 9(5)).
- Keep accurate records of time lost from salary or fees to substantiate any attendance allowance claims under s 9(4).
Referral and regulatory engagement (s 10-11)
- Know the referral list applicable to your role. General practitioners should be familiar with the bodies listed in s 10(2); non‑GP practitioners should be familiar with the broader list in s 10(3). If PSR refers matters, the receiving body will be one of these listed bodies, and s 11 requires that body to either have power to act or to assist a body that does.
- If referred, seek early contact with the recipient body to understand its investigatory powers and timelines. The Regulations identify who may receive a referral but do not describe how the recipient body will proceed.
Maintain awareness of external instruments
- Because the definition of relevant items refers to the general medical services table and determinations under subsection 3C(1) of the Act (s 5 Note), practices must monitor changes to those documents. Any change in the schedule or a determinative instrument can expand or contract what counts as "relevant" for s 8 and related PSR activity.
Governance and systems
- Update practice policies to mandate adherence to the s 6 record standard and to require contemporaneous documentation of exceptional circumstances.
- Train clinicians and administrative staff on the s 6 content and timing expectations, on the items that count as relevant services, and on the internal counting and reporting of service volumes.
- If using third‑party billing or electronic health record vendors, confirm that item coding and record templates capture the information required by s 6 and that billing categorisation aligns with the item lists in s 5.
Legal and compliance review
- Periodically review the practice’s compliance posture with lawyers or compliance specialists familiar with the Act and with PSR processes, focusing on record quality and on mitigation of exposure to the s 8 triggers.
- If queried under the Act, ensure documentation of how internal counting is done and provide contemporaneous records meeting the s 6 standards as the primary statutory defence.
Transitional awareness (s 12)
- Be aware that the phone‑service threshold in s 8(b) applies to relevant phone services rendered on or after 1 October 2022 (s 12). If your practice’s high phone‑service volumes were concentrated before that date, they will not count towards the s 8(b) threshold; volumes on or after that date will.
Following these steps will align operational practice with the instrument’s prescribed standards and thresholds. The central compliance levers are robust, contemporaneous clinical records (s 6), careful monitoring of itemised service volumes against the listed item numbers and Groups (s 5 and s 8), and contemporaneous documentation of any exceptional circumstances (s 7).