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 (hold specialist registration — for GPs that means FRACGP or FACRRM — or be on an approved section 3GA training or workforce program) and Section 19AB (the 10-year location restriction that applies to overseas-trained doctors and foreign graduates of Australian medical schools).
Provider number, billing privileges, prescriber number — three different things
Practices and new IMGs often use these terms interchangeably. They are not the same, and confusing them is how doctors end up with a Medicare debt.
| Term | What it is | Who issues it | Key facts |
|---|---|---|---|
| Medicare provider number | The number Services Australia records against you at a specific practice location. You need it "to claim, bill, refer or request Medicare services." | Services Australia | "You must first have a registration with the Australian Health Practitioner Regulation Agency (Ahpra) or an approved body." You need a separate provider number for each location you work at, and "you can't use another health professional's provider number." (Services Australia — Use your provider and prescriber numbers) |
| Billing privileges | Informal shorthand for being able to use that provider number so patients receive a Medicare rebate. Legally, it is the combination of a provider number plus meeting Sections 19AA and 19AB for that location. | Not a document — it is the outcome of the two sections below | Services Australia assesses you "for a section 19AB exemption when you apply for an initial Medicare provider number and each time you apply for a new provider number." (Services Australia — Restrictions and exemptions for IMGs) |
| PBS prescriber number | A 7-digit number that "uniquely identifies you're eligible to prescribe medication under the PBS" and "isn't location specific." | Services Australia | One per profession, not per practice. It is applied for on the same form as your initial provider number, or separately on paper. (Services Australia — Apply for initial provider and prescriber numbers) |
A provider number on its own does not guarantee a rebate. The Department of Health warns: "You must hold a valid Medicare provider number and 19AB exemption before you can provide medical services that attract a Medicare rebate. If you do not have a provider number, you will gather a debt for the services you provide. Under the legislation, we cannot backdate exemptions" (Department of Health — Section 19AB restricted doctors). And if a patient will not get a rebate, you must tell them beforehand — it is "an offence under section 19CC of the Act to provide a service without doing this."
The two sections of the Act that gate it
Section 19AA — the specialist-registration requirement
Section 19AA "applies to every doctor who registered to practise medicine in Australia on or after 1 November 1996. No exemption is available for any reason." Permanent residents and citizens "must hold specialist registration with the Medical Board of Australia or be actively working towards it" on an approved section 3GA program — for general practice: the Australian General Practice Training Program, the RACGP Practice Experience Program Specialist Stream and Fellowship Support Program, ACRRM's Independent Pathway and Rural Generalist Training Scheme, the Remote Vocational Training Scheme, and the Approved Medical Deputising Services and Pre-Fellowship workforce programs. Temporary residents "are not required to satisfy section 19AA", but specialist registration still gives access to the higher rebates for the specialty (Department of Health — Section 19AA). New IMGs typically satisfy 19AA by being placed on an approved program while they work toward fellowship. Read the full explainer: What is Section 19AA — and how is it different from 19AB?.
Section 19AB — the IMG location restriction
Section 19AB restricts overseas-trained doctors and foreign graduates of accredited medical schools from billing Medicare outside priority areas for 10 years "from the time you get your medical registration in Australia" — a Distribution Priority Area (DPA) for GPs, a District of Workforce Shortage (DWS) for non-GP specialists — unless an exemption applies. This is the rule most IMGs mean when they talk about "billing restrictions." Read the full explainer, What is Section 19AB and why does it matter?, see every exemption route on our Section 19AB exemptions page, or go to the source: Services Australia — Section 19AB.