Specialist OTD trying to work in private- Australia

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May 10, 2019
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I'm an overseas trained specialist, holding a limited registration for postgraduate or supervised training (specialist recognition) from the AHPRA. They have limited my areas of work as per my contract and my employer is in private sector.

After relocating to Australia with my family, my employer told that I need a Medicare provider number to start working. The Medicare sent my application form to Department of Health - 19AB to ask for an exemption.

Since my employer is in metropolitan area, they have declined the exemption application, telling that I'm not yet a specialist thus will be considered as an other doctor working in general practice so the practice needs to be in DWS area.

Could someone advise me which part is faulty in this process?

Basically the college gave me partially comparable report, recommended a center in private business (none available in my specialty in public sector), the center accepted my job application. Then waited for AHPRA to give limited registration according to the contract and finally got the visas.

What should be done more? Did the department of health make a mistake by not assessing this as a specialist- area of need application? If so do we still need a DWS report for the specialty area concerned to get a provider number? This website tells so:

Should we go for an after hour exemption if they still won't give a Medicare provider number?

Your help will be much appreciated,


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What kind of specialist are you?
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I think you’re in a catch 22 situation

If you an IMG regardless of specialty, and work in private practice (and hence will be billing Medicare) you need to work in a DWS for 10 years or get a 19AB exemption. There is no way around it unless you appeal your 19AB rejection or only work after hours

GP DWS locations are a lot more rural than DWS specialist locations, the latter can still be located in the cities but now GPs need to go really rural. It is unfortuante since you are not a vocationally registered sepcialist you can only go where the GPs can go

Even if you get a 19AB exemption, Also keep in mind that According to Medicare rules 19AA as soon as you receive permsnent residency and you DO NOT have a college fellowship you are not allowed to have a Medicare provider number so PR usually complicates matters in people in your situation. Although this is mainly for non-VR GPs who do not hold general registration or FRACGP, not specialists (as of yet I haven’t heard of a limited registration specialist working in private)

As you know usually overseas trained specialists who have passed college assessment and received limited ahpra registration work in the public sector, hence do not bill Medicare and don’t have the problems you do

If you are guaranteed to get a fellowship after your private work, maybe it might be worth it to work for free? Not sure but it’s an idea...a lot of specialist pathway doctors used to do this

But in conclusion ,the best way is to find a public job. maybe be more flexible with the job description, for example instead of finding staff specialist/consultant roles, you could find a fellowship year job, senior registrar, etc , as these can all be considered as part of your 12-24month top up training
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Firstly: You need to complete the necessary requirements to go from Limited Registration to Sepcialist Registration. That is, depending on your specialty and its college (i.e. RACS, RACP, RACGP, etc.), you need to fufil the requirements to attain your Fellowship qualitifcation for that specialty, and thus, eligibile for Specialist Registration with AHPRA / Medical Board of Australia. Usually if your speciality qualification is recognised, you typically have to do 1 to 2 years of supervised practice in a recognised private practice or public hospital, and then apply for fellowship.

Secondly: Access to an unrestricted Medicare Provider Number to access billable rebates from the Medicare Benefits Scheme, is dependent on two factors: a) recognition as a specialist (i.e. as per noted above; attaining your fellowship and specialist registration), and b) if you're an international medical graduate, you have to practice in an 'area of need' (i.e. typicallly rural or regional towns) if you want to be eligible for Medicare rebates immediately; otherwise, you have to wait for a decade as per the '10 Year Moratorium'. Most specialist-qualified IMGs are disincinlined to spend a decade rurally, so as a compromise most typically find work at a salary rate in a public hospital (i.e. no allowances for private billings) -- typically as a Senior Registrar or Fellow -- until the 10 year elapses, and then at that point in time they are finally elligible for an unrestricted Provider Number and able to start their own private practice -- or, if they wish to stay in the public system, can apply for Staff Specialist or Visiting Medical Officer contracts (i.e. which allow for a percentage of private billings) at that stage.

Good luck.
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