What Are Medicare Billing Privileges, and How Do IMGs Get Them?

"Billing privileges" is the informal name for the right to have your medical services attract a Medicare rebate — to bill Medicare under your own provider number. For an international medical graduate (IMG), this right is governed by the Health Insurance Act 1973, and two sections decide whether — and where — you can use it: Section 19AA and Section 19AB.

The one-sentence answer

To bill Medicare you need a Medicare provider number for the location you work at, and you must satisfy Section 19AA (be vocationally registered, a recognised fellow, or on an approved 3GA training/workforce program) and Section 19AB (the 10-year geographic restriction that applies to overseas-trained and foreign graduates).

What "billing privileges" actually means

Every Medicare-rebatable service is claimed under a doctor's provider number, which is tied to both the doctor and the practice location. Having "billing privileges" simply means your provider number is active and unrestricted for the work you are doing — so your patients receive the Medicare rebate and the practice can bulk-bill or charge a gap. Without it, you can still see patients, but the consultation is not subsidised by Medicare.

The two sections of the Act that gate it

Section 19AA — the vocational-registration requirement

Since 1996, Section 19AA requires that a doctor be vocationally registered, a fellow of a recognised college (e.g. FRACGP, FACRRM), or enrolled on an approved 3GA program (such as AGPT, the RACGP PEP, or FSP) to access Medicare rebates at the full rate. This applies to all doctors who entered the profession after November 1996 — not just IMGs. New IMGs typically satisfy 19AA by being placed on an approved program while they work toward fellowship.

Section 19AB — the IMG geographic restriction

Section 19AB restricts overseas-trained doctors and foreign graduates from billing Medicare in well-serviced MM1 metro areas for 10 years from their first Medicare billing date — unless an exemption applies. This is the rule most IMGs mean when they talk about "billing restrictions." Read the full explainer: Section 19AB explained.

How a new IMG gets billing privileges in practice

  1. Obtain provisional or general AHPRA registration.
  2. Apply to Services Australia for a Medicare provider number for your work location.
  3. Satisfy 19AA by being on a recognised program or holding fellowship.
  4. Work within your 19AB position — most commonly via the after-hours exemption or in a DPA/regional location.

Billing from day one: the after-hours route

Even under 19AB, Medicare permits after-hours billing at metro (MM1) practices, because the government wants after-hours coverage everywhere. This is why a newly arrived IMG can earn from their first week — see 19AB exemptions and our guide to after-hours work in Sydney.

Sources: Medicare Provider Number — Services Australia · Restrictions & Exemptions for IMGs · Section 19AB