The 19AB restriction
10 years
Medicare moratorium period
New IMGs cannot bill Medicare in metro areas for 10 years — unless they work in Distribution Priority Areas (DPAs) or qualify for exemptions.
What this means for city practice
7
Common exemption pathways shown below — the Department of Health lists more
Multiple exemption categories allow IMGs to work in cities like Sydney and Melbourne while billing Medicare — even during the 10-year moratorium.
Distribution Priority Areas (DPAs)
Where IMGs can work without exemptions
What are DPAs?
Distribution Priority Areas are locations identified by the government as having a shortage of doctors. IMGs can work in these areas and bill Medicare without needing an exemption. Every Modified Monash 2–7 (regional, rural and remote) location is a DPA, as are the Northern Territory and Tasmania; Modified Monash 1 inner metropolitan areas are not.
✓ DPA locations include
- Regional and rural towns
- Other catchments classified against the Department's benchmark
- Areas with doctor shortages
- The Northern Territory and Tasmania
✗ Non-DPA locations
- Sydney CBD and inner suburbs
- Melbourne CBD and inner suburbs
- Brisbane inner city
- Other major city centres
Check if a location is a DPA
Use the official Health Workforce Locator to check if a specific address or postcode is classified as a DPA. Classifications can change annually, so always verify before making decisions.
Health Workforce Locator →19AB exemption categories
Each exemption has specific eligibility requirements
After-Hours Exemption
Work evenings, weekends, public holidays in any location
Work between 6pm and 8am on weekdays, or any time on weekends and public holidays, in any location — including Sydney, Melbourne, and Brisbane — and bill Medicare. Most popular exemption for IMGs wanting to work in metro areas.
Spousal Alignment
Exemption based on spouse employment location
If your spouse is a medical practitioner or a skilled migrant, you may qualify to work in the same location as them regardless of DPA status.
Academic/Teaching
For approved academic positions
For IMGs with an academic appointment at an Australian medical school who perform clinical services as part of that appointment, and who meet section 19AA. Not for private practices without teaching responsibilities. Assessed by the Department of Health (applied for through Services Australia).
Approved Placements
Approved workforce or training programs
When you join an approved general practice workforce or training program at a location that meets the program's own location requirements.
Locum Work
One 6-month locum exemption, any location
Medicare access in any location for up to 6 months while you arrange work in a Distribution Priority Area (DPA) or District of Workforce Shortage (DWS). It cannot be extended or repeated.
Discretionary
Medical reasons or exceptional circumstances
For medical reasons (you are the primary carer for a close family member with a serious medical condition that can't be managed in a DPA or DWS location) or exceptional circumstances (an unforeseen, unavoidable and uncommon event). There is no exemption called "public interest".
Other classes the Department lists
Competent Authority Pathway, replacement, prior employment, acute-shortage specialties and more
The Department's section 19AB exemptions page also lists: the Competent Authority Pathway exemption (the locations on your Ahpra registration, in a DPA or DWS except in exceptional circumstances; it also covers the Specialist pathway area-of-need and specialist-recognition routes); replacing a doctor who held an unrestricted exemption and no longer works in the local area; prior employment negotiations that began while the practice was in a DPA or DWS; assistance at operations; Aboriginal and Torres Strait Islander primary health services; specialties in acute shortage (a Department list of specialist registrations); an unrestricted exemption for the same DPA or DWS catchment; continuing at the practice where you completed a 3GA program; and the 5-year IMG Recruitment Scheme, which can reduce the time you must work in a DPA or DWS to as little as 3 years.
After-hours: the most popular exemption
Most IMGs use the after-hours exemption to work in metro areas. You can bill Medicare for consultations after 6pm on weekdays, all day on weekends, and on public holidays — in any location including Sydney, Melbourne, Brisbane, and other major cities.
Important distinction: The after-hours exemption solves Medicare billing access in metro areas — it does not unlock the AGPT general pathway. Doctors under the 10-year moratorium can only train on the AGPT rural pathway, unless the RACGP grants a rural pathway exemption for exceptional circumstances (requested by the close of AGPT applications; it is not an exemption from 19AB). After-hours work also does not count toward GP fellowship training hours. On the RACGP Fellowship Support Program, part-time program time is at least 14.5 hours/week over at least two days, of which 10.5 hours are face-to-face patient consultation.
19AB for workforce doctors (limited registration)
Doctors on the workforce track (Limited Registration, Area of Need) also interact with Section 19AB, but access different Medicare items than GP-track doctors.
MP items, not GP items: Workforce doctors bill using Medical Practitioner item numbers (52-65 series) rather than the GP items (23, 36, 44 series). The after-hours exemption still applies, but to the MP item set.
Timing nuance — 19AB window ≠ MBS loading: The 19AB after-hours exemption window (when you can bill Medicare at all) is not the same as the MBS after-hours loading periods (when items attract higher rebates). There can be gaps where Medicare access exists but after-hours loading does not apply, or vice versa. Always confirm specific billing windows with Services Australia.
Area of Need and 19AB: Workforce doctors typically require an Area of Need designation to obtain Limited Registration. The 19AB exemption is a separate requirement for Medicare billing access. Both must be in place to bill Medicare in metropolitan areas. In DPA locations, 19AB exemption may not be needed.
Check your eligibility
Use our interactive explorer to see which exemptions apply to your situation.
This estimate is indicative only. Individual circumstances vary. Confirm with official sources before acting.
Related guides
An interactive checklist in your own free Doctor Pathways Australia login — every step of your registration, in order, built for your situation. Tick each step off, track your progress, keep your documents and next action in one place, and pick up where you left off. No cost, no obligation.