The 10-year moratorium, DWS exemptions, provider numbers, what you can bill, and the pathway to fellowship. Plain English, for doctors new to the Australian system.
Looking for the bigger picture first? See the IMG Hub — registration, AMC exams, the GP and expedited specialist pathways, and links to AHPRA, the Medical Board, AMC and the colleges.
Under Section 19AB of the Health Insurance Act 1973, overseas-trained doctors (OTDs) — including New Zealand-trained doctors — cannot generate Medicare benefits for 10 years from whichever of the following comes first:
In practical terms: if you practise without an exemption during this period, your patients get no Medicare rebate for seeing you. They pay the full cost out of pocket. This is why almost all IMGs in general practice work in a District of Workforce Shortage (DWS) with a 19AB exemption — it’s how they can generate Medicare benefits at all.
A District of Workforce Shortage (DWS) is a geographic area the Department of Health has designated as having insufficient medical workforce. Most rural, regional, and some outer-metropolitan areas are DWS.
If your practice is located in a DWS, the Minister for Health can grant you a section 19AB exemption. This exemption allows your services to attract Medicare benefits during the moratorium period. Without this exemption, your services simply do not generate Medicare rebates regardless of what you do.
| Key fact | Detail |
|---|---|
| Exemption is location-specific | It applies only to the approved practice address. If you move practices, you need a new exemption for the new location. |
| Your employer applies, not you | The practice/employer supports and helps initiate the exemption application. They provide a letter stating why the provider number is needed. |
| Check DWS status before accepting a job | Use the Health Workforce Locator to confirm a practice is in a DWS before signing a contract. |
| DWS designations change | An area that is DWS today may not be DWS next year. Check current status at health.gov.au. |
A provider number is required to bill Medicare. It is location-specific — you get a different number for each practice location. You need a new number every time you change practices.
This depends on whether you are classified as a Medical Practitioner (MP) or a Prescribed Medical Practitioner (PMP) for MBS purposes — and whether you have achieved GP fellowship.
IMGs working under a 19AB exemption who are not yet VR GPs bill as Medical Practitioners using Group A2 items:
| Item | Description | Fee |
|---|---|---|
| 52 | Consulting rooms, ≤5 min | $11.00 |
| 53 | Consulting rooms, >5 to ≤25 min | Verify pbs.gov.au |
| 54 | Consulting rooms, >25 min | Verify mbsonline.gov.au |
| 57 | Consulting rooms, >45 min | Verify mbsonline.gov.au |
Group A2 fees are lower than GP items (23/36/44). This is the most important financial implication for IMGs on a percentage-of-billings model. Always verify current fees at mbsonline.gov.au.
Once you achieve RACGP or ACRRM fellowship and are recognised as a GP for MBS purposes, you access the full Group A1 GP item set — items 3, 23, 36, 44 and all associated health assessment, CDM, and mental health items. These pay significantly more than Group A2 items.
The doctor accepts the Medicare benefit as full payment. Patient pays nothing. You bill Medicare directly — Medicare pays 100% of the schedule fee. No gap, no invoice to the patient.
The doctor charges above the Medicare schedule fee. Medicare pays the schedule fee; the patient pays the difference (the “gap”). The practice sets the fee — this is usually a practice-level decision, not yours individually.
Why this matters for IMGs on percentage-of-billings: Your income is usually a percentage of what you bill. Group A2 items have lower schedule fees than GP items. If the practice bulk bills, your income per consult is lower than a VR GP doing the same consult. If the practice private bills with a gap, the practice fee may be higher but your percentage stays the same. Understand your contract carefully.
Fellowship with RACGP or ACRRM is the goal — it removes the billing restrictions, opens the full GP item set, and is required for vocationally registered GP status. There are two main routes for IMGs:
The AMC assesses whether your primary medical qualification is comparable to an Australian medical degree. If your country is not on the AMC’s list of comparable countries, you typically sit AMC exams (MCQ + clinical). Passing grants AHPRA provisional registration for supervised practice. This is often the first step — before RACGP assessment.
amc.org.au →The current RACGP fellowship pathways for IMGs are the Fellowship Support Program (FSP) for non-VR doctors (FSP 2027.1 introduces a new structure from 2027), the Practice Experience Program — Specialist Stream for IMGs holding a recognised overseas specialist GP qualification, the standard AGPT Program (open to eligible IMGs), and RVTS for those working in rural/remote locations. PEP Standard has closed to new applications. Older references to “RACGP OSCAR” or “Fellowship by Assessment” predate the current program names. See the interactive FRACGP pathway selector for current eligibility, intakes, and fees, or the RACGP IMG fellowship programs page.
racgp.org.au/education/imgs →ACRRM (Australian College of Rural and Remote Medicine) offers FACRRM via independent pathway for IMGs, particularly suited to those committed to rural practice. Useful if your DWS location is also rural and you want to build a long-term career there.
acrrm.org.au/support/support-for-imgs →⚠️ Pathway requirements change. Contact RACGP, ACRRM, or AMC directly for current entry requirements specific to your country of training and qualification.