Legal Considerations for Providers of Chronic Disease Management
From 1 July 2025, the Australian Government implemented significant changes to the Medicare Benefits Schedule (MBS), reshaping how chronic disease management is delivered and funded across general practices. These changes replace the long-standing GP Management Plans (GPMPs) and Team Care Arrangements (TCAs) with a single, streamlined framework: the GP Chronic Condition Management Plan (GPCCMP).
While the reforms aim to simplify care coordination and improve patient outcomes, they also introduce new legal, operational, and compliance considerations for medical centres and practices. From referral protocols and billing structures to privacy obligations, practitioner service agreements and employment arrangements, healthcare providers must be prepared to adapt.
Key Considerations
- Referral Compliance and Documentation
The shift to referral letters (rather than prescribed forms) introduces new risks around documentation standards. Practices and practitioners must ensure that referral letters meet the new legal requirements to avoid compliance issues or billing disputes.
- Delegation and Employment Structures
The ability for practice nurses and Aboriginal Health Workers to assist in preparing and reviewing GPCCMPs may require new or updated employment contracts with staff, delegation protocols, and supervision arrangements.
- Privacy and Data Security
With referrals encouraged to be transmitted electronically, practices must ensure compliance with privacy laws and cybersecurity obligations under the Privacy Act and the Australian Digital Health Agency’s standards.
- MyMedicare and Practice Obligations
Patients registered with MyMedicare must access GPCCMP services through their enrolled practice. This raises questions around patient mobility, continuity of care, how practices manage enrolment and access rights.
- New MBS Items
The introduction of new MBS item numbers and the phasing out of existing ones requires updates to billing systems, and practitioner and staff training.
- Transitional Period
Patients can continue to access services under an existing GPMP or TCA until 30 June 2027 , however, as of 1 July 2025, healthcare providers must comply with new review and referral requirements.
What Should Practices Do Now?
- Audit your current documentation and referral processes.
- Review and update employment and practitioner agreements.
- Conduct a privacy and cybersecurity check-up.
- Train your team on the new MBS items and compliance requirements.
- Communicate with patients about what these changes mean for their care.
How Burke Lawyers Can Help
At Burke Lawyers, we understand that navigating these changes requires more than just awareness, it demands strategic and legal insight. Our team is committed to helping medical practitioners, medical centres and practices stay compliant, protect their operations, and seize opportunities for growth under the new framework.
Our team can help you:
- Review and update employment and practitioner agreements.
- Prepare, review and update ownership agreements such as shareholder agreements.
- Advise on health law and compliance matters.
- Conduct privacy audits.
- Provide strategic advice on practice structuring and risk mitigation.
- Support training and policy development for clinical and administrative staff.
Whether you're a medical centre, general practitioner, specialist, practice manager, or allied health provider, now is the time to review your systems, update your documentation, and ensure your team is prepared.
Contact us to schedule a consultation to discuss how we can improve and support your practice.
