Modernising gap-only billing – replacing Medicare cheques with electronic benefit payments

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Closes 27 Feb 2026

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Modernising gap-only billing – replacing Medicare cheques with electronic benefit payments

1. To what extent are gap-only billing arrangements for high cost services necessary to support patients who cannot afford the full fee at the time of service?
2. Does the impact analysis accurately reflect the impact of gap-only billing, including the saving in administrative time estimated in section 4.3?
3. Gap-only billing is proposed for services with an MBS fee over $697. Please discuss the effect of this threshold on patients and, if a lower fee is proposed, how fee inflation would be mitigated and bulk billing rates would be protected.
4. The payment of the Medicare benefit to the provider is proposed for 90 days after the claim has been submitted. Please discuss the effect of this delay and, if a different duration is proposed, how fee inflation would be mitigated and bulk billing rates would be protected.
5. How will the removal of cheques from the Child Dental Benefits Scheme (CDBS) affect eligible patients? (No response required if CDBS is not relevant to your services or industry sector)
6. Do you foresee any unintended consequences of the proposed gap-only billing arrangements?
7. Do you have any other feedback on the proposed gap-only billing arrangements?

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