Medicare simplification may cut GP time women rely on most

What just happened

An analysis published in the Medical Republic this week has identified a concern that is easy to miss in the abstraction of health policy reform: a proposal to simplify the Medicare Benefits Schedule could disproportionately remove the billing structures that women depend on for focused, condition-specific care in general practice.

The federal government’s Time-Tiered MBS Working Group has proposed reducing more than 300 time-tiered MBS items to approximately 150. The rationale is administrative efficiency — the current structure is complex, creates billing confusion, and imposes documentation burden on GP practices. None of that is wrong. But the specific items proposed for consolidation include standalone pregnancy counselling, non-directive antenatal codes, and sexual and reproductive health telehealth items — the items that structure the kind of care women disproportionately need.

The analysis, by Dr April Armstrong, draws on MBS data showing that female patients account for 65.5% of Level E (60-minute plus) GP consultations and 55.8% of Level B claims. Women need longer, more complex consultations. The billing architecture that compensates GPs for that complexity and that scaffolds its structure is not a bureaucratic accident — it is load-bearing.

Both-and

The case for simplification

The current MBS is genuinely unwieldy. More than 300 time-tiered items generate significant administrative friction: GPs and practice managers must navigate eligibility criteria, gap rules, documentation requirements, and 12-month rule exemptions that interact in non-obvious ways. That cognitive load falls partly on the clinician and partly on practice staff. Time spent verifying billing codes is not time spent with the patient.

Simplification has a legitimate basis in other healthcare contexts. Where fewer codes cover more clinical situations with adequate compensation, administrative burden drops without measurable harm to care quality. The Working Group’s intent is to free GP time from paperwork, not to reduce care — and that goal is worth taking seriously.

The problem with folding condition-specific items into generic codes

Dr Armstrong’s analysis is that MBS item numbers do more than enable billing. They function as “clinical prompts, documentation guides, and educational scaffolds.” When a GP opens item 16500 for an antenatal consultation, or a specific item for non-directive pregnancy options counselling, that item number is attached to a defined service structure — it tells the clinician what the consultation is supposed to cover, what documentation is expected, and what standard applies.

Remove the item and replace it with a generic attendance, and the explicit scaffolding disappears. In training environments, this matters as much as in practice. Registrars learn what a non-directive pregnancy counselling consultation looks like partly through the existence of an item number that defines it. A generic Level C attendance does not carry that definition.

The women most affected are those who rely on focused reproductive health consultations in general practice — patients seeking antenatal care through their GP rather than a private obstetrician, women accessing sexual and reproductive health telehealth in regional and rural areas where specialist access is limited, and women needing pregnancy options counselling in a time-sensitive situation. These are not unusual presentations. They are common.

What the data shows about who uses long consultations

The MBS data makes the pattern clear: female patients account for nearly two-thirds of the longest GP consultations. Female GPs provide more than half of all Level D attendances despite delivering a smaller share of total non-referred services. A reform that reduces compensation and structure for longer, complex consultations is likely to have asymmetric effects — and the direction of that asymmetry points toward the patients who already experience the most fragmentation in their healthcare.

That fragmentation is not a new observation. The existing siloing of physical and mental health services for women — recently documented in separate RACGP data — is a structural problem that the health system has not yet solved. A billing reform that removes the scaffolding supporting complex women’s health consultations lands on that already-strained foundation.

2 cents

This is a policy consultation, which means it is one of the rare moments where public input can genuinely change the outcome. If you are a woman who has relied on a detailed, focused GP consultation — for pregnancy counselling, reproductive health, or any complex presentation that takes more than 10 minutes to address properly — this is worth knowing about.

The consultation is open through the Department of Health and Aged Care. The RACGP is expected to make a formal submission. As a patient, your written account of how a specific item-structured consultation affected your care is the kind of evidence that policy consultations often lack and that decision-makers say they want.

The verdict here is maybe because the process is still open and these proposals are not yet finalised. The concern is real and the underlying data is solid — but the outcome depends on what happens in consultation and how the Working Group responds. Watch this space before the submission window closes.

This is general information. For questions about your own care or GP access, your GP practice is the right starting point.

Verdict: maybe — a proposal, not a decision. But the MBS items at risk are the ones that structure focused women’s health care in general practice, and the data on who uses long consultations is unambiguous.

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Sources cited

1. Armstrong A. Women’s health: the unintended casualty of MBS simplification? Medical Republic, 12 September 2026.
2. Medicare Benefits Schedule review — time-tiered items consultation. Australian Department of Health and Aged Care.