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Starting Supervised Practice in Australia: The Readiness Checklist for IMGs

Everything that must be in place before your first supervised session: supervision plan, registration, indemnity, work rights, provider number and 19AB — and who arranges each.

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Starting Supervised Practice in Australia: The Readiness Checklist for IMGs

Before an international medical graduate (IMG) can see a single patient in Australia, three separate things must be in place on day one: registration with a Board-approved supervision plan, work rights that cover the position, and — if you will bill Medicare — a provider number with any Section 19AB exemption the location needs. Each is decided by a different authority on its own timetable, so this checklist sets out every item, which of the three layers it belongs to, and whether you or the practice arranges it.

Registration is decided by the Medical Board of Australia ↗ and administered by AHPRA; work rights by the Department of Home Affairs; Medicare billing by Services Australia and the Department of Health. Always confirm the live requirement on the official site, as forms and rules are updated.

Supervised practice readiness checklist

Tick any box to keep this list in your free personal checklist — it opens at the Supervised Practice step, the one you are reading, with the 11 items below and the documents each one needs.

ItemLayerWho arranges itNotes
Supervision plan approved by the BoardRegistrationThe practiceThe practice and your supervisor submit the plan; the Board approves it with your registration
Named supervisor and starting supervision levelRegistrationThe practicePrincipal supervisor (and any co-supervisors) and your starting level are set in the plan
Professional indemnity insuranceRegistrationYouMust meet the Board's standard before you practise; arrange it once your position is confirmed
Registration grantedRegistrationYouAt least provisional (or limited) registration on the public register before any clinical work
Position, start date, hours and roster confirmedRegistrationTogetherThe position the Board approves is the one you start in
Orientation on day oneRegistrationTogetherPractice systems, emergency procedures and, at Level 1, an early safety assessment
Employer nomination (if you need a visa)Work rightsThe practiceFor example a subclass 482 nomination by the employing practice
Visa granted with work rights for the positionWork rightsYouIn place before your start date; not needed if you already hold unrestricted work rights
Location checked for Section 19ABBillingTogetherIs the practice in a Distribution Priority Area, or will you need an exemption?
Medicare provider numberBillingTogetherOne per practice location; needs your AHPRA registration first
Section 19AB exemption (where needed)BillingTogetherMust be granted before services attract a rebate — exemptions cannot be backdated

Registration alone grants neither work rights nor Medicare billing. Doctors most often lose weeks by finishing one layer and discovering the other two only then. Run all three in parallel from the moment a position is confirmed.

Layer 1 — Registration and your supervision plan

Supervised practice starts when three registration items line up: the Board has approved your supervision plan, your registration is granted, and you hold professional indemnity insurance that meets the Board's standard.

You cannot start before registration is granted

Practising without current registration is a criminal offence under the Health Practitioner Regulation National Law, even while your application is being assessed — you need at least provisional registration, not a receipt of application. AHPRA also requires your supervisor and practice location to be confirmed before it grants provisional registration, which is why the supervision plan and the registration application travel together. See working while your AHPRA application is pending and, for the documents themselves, the AHPRA application checklist.

Which registration you start on

PathwayRegistration you start supervised practice on
Competent AuthorityProvisional registration
Expedited SpecialistProvisional or limited (specialist) registration
Standard AMCProvisional registration — the Board requires the AMC CAT MCQ before you apply; the clinical exam (or workplace-based assessment) "can be completed before or after registration is granted"
Workforce (Area of Need)Limited registration for an Area of Need position

Supervision levels

The Board sets your starting level case by case in your approved plan (MBA — IMG supervision levels ↗):

LevelWhat it means
Level 1 — DirectYour supervisor is on site at all times and has direct responsibility for each patient
Level 2 — Indirect (present)Responsibility is shared; your supervisor is physically present for at least 80% of your practice hours
Level 3 — General (accessible)You take primary clinical responsibility; your supervisor is contactable by phone or video and can attend if needed
Level 4 — Remote / minimalYou take full clinical responsibility; your supervisor provides periodic review

Competent Authority and Expedited Specialist doctors typically start at Level 2 or 3; Standard AMC and Workforce doctors typically start at Level 1. Your supervisor can recommend moving to a less intensive level on the strength of satisfactory progress reports. For the Level 3 arrangement most UK GPs start on, read Supervision Level 3 explained.

Orientation and reporting

Orientation happens in your first days: practice systems, emergency procedures and, at Level 1, an early safety assessment. Your supervisor then reports to the Board at the intervals your plan sets — at Level 1 the orientation report is what the Board uses to review your level. Supervision ends when you complete the required period with satisfactory reports and move to general registration; see provisional to general registration.

Layer 2 — Work rights

Work rights come from your visa, not from AHPRA. If you need one, the usual route is an employer-sponsored visa such as the subclass 482: the employing practice lodges a nomination for the position, then your visa application follows. The visa must be granted, with work rights covering the position, before your start date — see the 482 visa guide for UK GPs for how nomination and sponsorship work.

If you already hold unrestricted work rights — for example as a citizen, a permanent resident, or on a partner visa that allows any work — this layer is already complete. Whatever your visa, check its conditions against the position before you accept it; immigration advice specific to your situation should come from a registered migration agent ↗ or lawyer.

Layer 3 — Medicare billing

To have your services attract a Medicare rebate you need a Medicare provider number ↗ for each practice location, and you must satisfy Section 19AB for that location.

Check the location first

Section 19AB applies to anyone who got their medical degree outside Australia or New Zealand, for 10 years from first medical registration in Australia. In a Distribution Priority Area you can generally bill; elsewhere — most inner-metropolitan practices — you need an exemption, such as the after-hours exemption. Check the location with the Department of Health's Health Workforce Locator ↗, and read DWS, DPA and the Modified Monash Model for how the classifications work. For who the restriction covers and every exemption type, read Section 19AB explained.

Provider number and exemption

Apply to Services Australia once your registration is granted — the provider number application needs it — and attach your 19AB exemption evidence at the same time where the location needs one. The Department of Health is explicit that "you must hold a valid Medicare provider number and 19AB exemption before you can provide medical services that attract a Medicare rebate" and that exemptions cannot be backdated, so work seen before both are in place does not attract a rebate. The full sequence, and the difference between a provider number, billing privileges and a prescriber number, is in Medicare billing privileges for IMGs.

After-hours billing during supervision

After-hours work is allowed only where it is consistent with your approved supervision plan: at Level 1 your supervisor must be working on site alongside you, at Level 2 on site for at least 80% of the hours, and from Level 3 you can work after-hours independently with your supervisor available by phone. What a first after-hours session looks like in practice is covered in after-hours GP work in Sydney: day one; how after-hours income is structured is in IMG GP pay, tax and contractor arrangements.

If your position is in an Area of Need role on limited registration, read the Area of Need exemption alongside this layer.

The order that works

  1. Confirm the position and its location — every other item depends on it.
  2. Start all three layers at once: the practice prepares the supervision plan (and any visa nomination) while you arrange indemnity cover and assemble your AHPRA documents.
  3. Lodge the registration application with the supervision plan and position details — AHPRA recommends at least 8 weeks before your intended start date.
  4. Check the location for Section 19AB and prepare any exemption application.
  5. Receive registration, then apply for your provider number (with exemption evidence).
  6. Confirm your visa is granted with work rights for the position.
  7. Day one: orientation with your supervisor, working at the level your approved plan sets.

See the order for your own pathway in the pathway timeline.

Sources: Medical Board of Australia — Supervised practice guidelines · Medical Board — IMG supervision · AHPRA · Services Australia — Medicare provider number · Department of Health — Section 19AB · Home Affairs — subclass 482

Sources

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This article is maintained to align with current AHPRA, RACGP, and Medicare guidance. For regulated advice, consult a registered migration agent or legal professional.