Novel COVID-19

Update 26 February 2021

MIGA's COVID-19 medico-legal and insurance Q&A covers the most recent developments around the pandemic for our members and clients, particularly as 'COVID Safe' requirements continue as outbreaks subside, and as we enter the roll-out of COVID-19 vaccines.


MIGA is working closely with the Commonwealth Government and professional groups to ensure the interests of our members and clients are properly protected around insurance coverage, medico-legal issues and practical requirements of the COVID-19 vaccine roll-out.


Latest updates include:

  • COVID-19 vaccination - roll-out, eligibility, booking, informed consent, second does, reporting, Medicare billing requirements and advertising
  • Ongoing state and territory restrictions and mask requirements
  • Latest National COVID-19 Clinical Evidence Taskforce recommendations on Tocilizumab use
  • Upcoming closure of Ahpra’s pandemic response sub-register.


Categories include:

  • Insurance cover for COVID-19 vaccinations
  • COVID-19 vaccinations - medico-legal Q&As
  • Insurance cover for other COVID-19 matters
  • Healthcare restrictions
  • Protecting yourself, your colleagues and your patients
  • Managing COVID-19 - testing, certificates, privacy, medications and vaccines
  • Telehealth and electronic prescribing
  • Registration issues
  • COVID-19 Premium Relief from MIGA
We encourage you to review our Q&A below, and check back for regular updates.

 

Contact MIGA for advice or assistance
We encourage you to contact :
  • MIGA's Legal Service team it you need advice about how to manage COVID-19 medico-legal issues in your practice (1800 839 280 / claims@miga.com.au, or
  • MIGA's Client Services Officers if you have any questions about your insurance cover (1800 777 156 / miga@miga.com.au)
You can also use MIGA's contact form here.

 

Commonwealth, State and Territory advice and contacts

Access the Commonwealth health department advice, CDNA guidelines, AHPPC and ICEG advice and National COVID-19 Clinical Evidence Taskforce recommendations.    
 
Links to the latest State / Territory information and advice, and public health unit contacts are below:

 
State/Territory General Information Health advice Public health unit Public health directions
ACT Information Health advice (02)51249213
(02)99624155 (AH)
Directions
New South Wales Information Health advice 1300066055 Directions
Northern Territory Information Health advice Local unit numbers Directions
Queensland Information Health advice Local unit numbers Directions
South Australia Information Health advice 1300242272 Directions
Tasmania Information Health advice 1800671738 Directions
Victoria Information Health advice 1800675398 Directions
Western Australia Information Health advice Local unit numbers Directions

Insurance cover for COVID-19 vaccinations

Note - the answers in this section only apply to MIGA policies issued to doctors, Eligible Midwives and healthcare businesses which are current as at the date of publication.  Your individual cover is subject to the terms and conditions of your policy with MIGA and your chosen category of practice.  If you are a doctor whose practice entity employs other doctors, eligible midwives or others who bill in their own name, you must ensure that they have their own insurance arrangements in place to cover administration of COVID-19 vaccinations.
  • Am I covered for services related to COVID-19 vaccinations including administering the vaccines? New 1 Feb 2021

    Yes.
    • You are covered with MIGA for claims and inquiries arising from COVID-19 vaccination services you provide
    • We cover you for healthcare services provided within your category of insurance/scope of practice or healthcare business that is consistent with with your qualifications, training, experience or the healthcare services provided by your practice/business
    • You should ensure you comply with all relevant requirements and guidelines - see Q&A - What do I need to do if I’m involved in the COVID-19 vaccination program?
    • If you are being asked to undertake, or are considering undertaking, a new or different role that may be outside your scope of practice and have any concerns around your medical indemnity insurance or any medico-legal implications, please contact us for assistance.  We’ll help to make sure that your cover is appropriate for what you are doing and guide you on potential medico-legal issues involved.
    • You should let us know as soon as possible if you become aware of any claim or potential claim arising from administering the vaccines.
  • Do I need to let MIGA know that I plan to be involved in the administration of the COVID-19 vaccines? New 1 Feb 2021

    No. 
    • Unless you are in a category of insurance that does not include cover for private practice
    • If you are considering entering into any agreement (with governments, healthcare providers or otherwise) to be involved in COVID-19 vaccination services, you should contact MIGA prior to signing any agreement to ensure that you are not assuming any responsibilities for which we are not able to provide cover
    • We can also help you understand any insurance and medico-legal implications of any agreement.
  • Am I covered if I am working outside of my usual scope of practice to administer COVID-19 vaccines? New 1 Feb 2021

    Yes, if it is permitted by your Ahpra registration, you have appropriate qualifications, training and experience and you are in the appropriate category of insurance with MIGA.
    • You should only provide healthcare you are appropriately qualified and trained for and have sufficient experience to provide
    • Ahpra has provided the following information about medical practitioners moving into new roles in responding to the COVID-19 pandemic
    • If the work you are planning to undertake is outside of your usual area of practice, you should ensure you will meet your regulatory obligations with Ahpra
    • We recommend you take the following steps before starting your new work:
      • Ensure your Ahpra registration does not restrict or prevent you from engaging in the new scope of practice
      • Be comfortable that you have the necessary skills, training and experience to provide the level of care expected, and your hospital, practice or other workplace agrees
      • Ensure your proposed practice is consistent with your hospital/facility credentialing
      • Confirm with your hospital, practice or other workplace (preferably in writing) that you will have the benefit of any indemnity you are normally entitled to as an employee or contractor (e.g. as a visiting medical officer for public patients) 
      • Ensure you do not use a specialist title unless you have the appropriate qualifications – for more information see Ahpra’s guide on health titles
      • Contact MIGA to ensure you have the right category of insurance cover with us. 
  • Will my policy provide cover if my employees administer the vaccine and there is a complaint or claim? New 1 Feb 2021

    Yes

    • You are covered for your own vicarious liability as an employer but remember that you should ensure that your employees are working under your supervision and within the scope of their duties and responsibilities as you have agreed with them.
    • If you are:
      • a doctor, remember that your policy covers some but not all kinds of employees for claims made directly against them - refer to the important note at the top of this update regarding employees who need their own insurance
      • a midwife, remember that your policy covers you personally and not any employees
      • a healthcare company, remember that your policy only covers your employed doctors if the relevant optional extension is included in your Schedule.
  • If I'm asked to administer vaccines to public patients in a public hospital, am I covered for this New 1 Feb 2021

    Generally, No
    • If you are employed in a public hospital (including if you are a medical student) you will generally be indemnified by the hospital for work you undertake
    • If you are insured as a Hospital Doctor with MIGA, cover is generally only for legal expenses for inquires and investigations for which you are not otherwise indemnified or insured and for some limited private practice you may undertake outside your public practice employment
    • If you work in the public health system and plan to undertake work in the private system to administer the COVID-19 vaccines, contact us to check the extent to which you may be covered for private work under your category of insurance
    • If in doubt, please check with your hospital’s administration to clarify your indemnity situation or call MIGA to clarify your position.
  • Is my practice or healthcare business covered by MIGA's Healthcare Policy if it contracts to be part of the COVID-19 vaccination program? New 1 Feb 2021

    Yes.

    • MIGA’s Healthcare Policy for entities will cover the business and its employees (excluding doctors and other who bill on their own right) for claims and inquiries arising from their involvement in the vaccination program
    • This is provided it is within their usual scope of practice/specified business and it is subject to them complying with all relevant requirements and guidelines (see Q&A - What do I need to do if I’m involved in the COVID-19 vaccination program?).
    • Employed medical practitioners are not covered by the policy (unless MIGA has agreed to this) and will need to be covered under an individual practitioner policy with MIGA.
  • If I am asked to sign a contract for COVID-19 vaccine administration, what should I do? New 1 Feb 2021

    If you are considering entering into any agreement (with governments, healthcare providers or otherwise) to be involved in COVID-19 vaccination services, you should contact MIGA prior to signing any agreement to ensure that you are not assuming any responsibilities we are not able to provide cover for, and to understand what insurance and medico-legal implications there may be. 

    Contracts may impose obligations on you that you would not otherwise have, or they may ask you to give up rights that you would otherwise have.  Your insurance does not cover you for these changes to your rights and responsibilities unless we first agree in writing to cover you.

  • What do I need to do if I'm involved in the COVID-19 vaccination program? New 1 Feb 2021

    It is extremely important that you are familiar with and follow all guidelines provided by the manufacturers, distributors, Federal and State Governments and your professional college/association.  Be aware these guidelines may be updated regularly as circumstances change and new information becomes available.

    MIGA is working closely with Australian Governments and professional groups on the COVID-19 vaccine program and will provide further information on guidelines and other information on this website once released. 

COVID-19 vaccinations - medico-legal Q&As

Note - the answers in this section only apply to MIGA policies issued to doctors, Eligible Midwives and healthcare businesses.
  • When will COVID-19 vaccines become available? Updated 26 Feb 2021

    The TGA has:
    The TGA has more information on TGA vaccine approval status.  You can also subscribe to Commonwealth Government COVID-19 vaccination updates. 

    The Commonwealth Government has agreements to purchase / access:
    • Enough Pfizer Comirnaty vaccine for a limited proportion of the Australian population
    • Sufficient AstraZeneca vaccine to cover the population
    • Enough Novavax protein vaccine (if viable, currently in Phase 3 clinical trials) to cover the population
    • A range of vaccines through the COVAX facility.
  • How will COVID-19 vaccines be delivered? Updated 26 Feb 2021

    The Commonwealth Government has a COVID-19 vaccine national roll-out strategy, setting out how COVID-19 vaccines will be delivered.

    COVID-19 vaccines will be delivered via a range of ‘delivery hubs’. 

    Delivery hubs in Phase 1a of the roll-out, commencing 21 February 2021, are initially certain hospitals.  Initially they will be limited to delivering the Pfizer Comirnaty vaccine.  More information on Phase 1a staging and delivery locations is here

    This will be followed by approved accredited GP clinics, GP respiratory clinics and Aboriginal health services from Phase 1b of the roll-out (commencement date yet to be set – it is likely to be around late March to early April 2021), and subsequently approved  community pharmacies from Phase 2a.  These settings will deliver the AstraZeneca vaccine and any other COVID-19 vaccines approved for use and available in Australia over time. 

    See Q&A – 'How are COVID-19 vaccines prioritised?' for details of the phases.
     
    The Commonwealth Government is aiming to complete COVID-19 vaccination across the adult population by the end of October 2021.
  • Who can be involved in delivery of COVID-19 vaccines? Updated 26 Feb 2021

    A range of doctors and nurses working in hospitals, GP respiratory clinics and state / territory vaccination clinics will be involved in vaccine delivery through their existing roles. 

    Accredited GP clinics have been able to apply to administer COVID-19 vaccines from Phase 1b onwards, both to their own patients and any eligible individuals under the COVID-19 vaccine national roll-out strategy. Community pharmacies will be involved at Phase 2.  


    Ability to authorise and administer COVID-19 vaccinations is based on:

    • Having necessary training and experience to provide immunisation
    • Completing the Commonwealth Government’s online COVID-19 vaccination training program
    • Being an authorised immunisation provider in your state / territory.

    Authorised immunisation providers generally include doctors, nurse practitioners and registered nurses. 

    For COVID-19 vaccination Medicare billing, activities associated with individual items can only be undertaken by suitably qualified and registered health practitioners working within their scope of practice and who have undertaken required COVID-19 vaccination training.  A range of Q&A below deal with Medicare billing requirements. 
     
  • What is required before I/my practice can be involved in GP COVID-19 vaccination? Updated 26 Feb 2021

    Before you or your GP practice consider involvement in the roll-out of COVID-19 vaccines, you need to consider whether you, your colleagues and your staff have the capacity to meet the Australian Government’s minimum site requirements for COVID-19 vaccination clinics, including:
    • Accreditation
    • Staffing - including a doctor on site whenever vaccination is being provided (who can be the same as the authorised immunisation provider), vaccinating staff (for vaccine preparation and administration) and additional first aid staff
    • Facility
    • Equipment – GP practices are encouraged to source their own consumables (e.g. needles, syringes and sharp disposal containers), but these can be ordered through the Vaccine Operations Centre if unable to be sourced through existing mechanisms
    • Patient booking processes, including ability to integrate with the COVID-19 Vaccination Information and Booking Service (based on the existing National Health Services Directory operated by Healthdirect) – practices that do not have an existing online booking system will be able to use a system currently under development
    • Patient volumes - capability to deal with significant numbers of patients who are not usual patients of yourself or your practice, including scope to ‘scale up’ vaccine delivery as may be required, within practical limits and in consultation with the Commonwealth Government / your local Primary Health Network 
    • Patient assessment for eligibility and risk of adverse reactions / complications, including:
      • History-taking
      • Any necessary liaison with a patient’s treating GP / specialists
      • Access relevant information on a patient’s My Health Record
    • Access to interpreter services as required – such as the Australian Government Translating and Interpreting Service
    • Informed consent
    • Managing multi-dose vials
    • Cold chain management and storage – this includes the National Vaccine Storage Guidelines ‘Strive for 5’
    • Monitoring and follow-up
    • Reporting vaccination to the Australian Immunisation Register (AIR)
    • Reporting adverse events, including:
      • Suspected adverse events to the TGA / local health departments / public health units
      • Vaccine vial loss / breakage to the Vaccine Operations Centre.
    • Keeping health information secure, including IT and data management systems – see:
    Further Q&A on a range of these issues are below. 

    You will also need to keep up-to-date with evolving requirements and information, particularly as government / regulatory / professional requirements, guidance and information may change quickly.  It is important to have a process of regularly checking for and keeping on top of changes.

    If you are asked to sign any contract, whether with governments, employers, practices or otherwise relating to COVID-19 vaccine administration, it is important you contact MIGA prior to signing the contract in order to ensure that you are not agreeing to anything that we are not able to cover.
  • Which COVID-19 vaccines will I be able to use? Updated 19 Feb 2021

    What COVID-19 vaccines can be used depends on TGA approvals and Australian Government frameworks. 

    Access to the Pfizer Comirnaty vaccine will at least initially be limited to certain population groups (see Q&A How are COVID-19 vaccines prioritised?), and all adults will have access to the AstraZeneca vaccine. 

    At least initially, only one type of vaccine will be available from each vaccine delivery site:
    • Pfizer Comirnaty vaccines in hospitals
    • AstraZeneca vaccines in approved, accredited GP clinics, GP respiratory clinics and state and territory immunisation clinics.
  • How are COVID-19 vaccines prioritised? Updated 26 Feb 2021

    The Commonwealth Government’s COVID-19 vaccine national roll-out strategy sets out a phased roll-out of vaccines, based on population vulnerability, including:
    • Phase 1a (from 21 February 2021) – quarantine / border workers, priority frontline healthcare worker groups, aged care / disability care residents and staff – more information is available here

    • Phase 1b (likely from circa late March / mid-April 2021) – older adults 80 years and over, then older adults aged 70-79 years, other healthcare workers, Aboriginal and Torres Strait Islander peoples over 55 years, younger adults with an underlying medical condition (including disability) and critical / high risk workers (including defence, police, fire, emergency services and meat processing)

    • Phase 2a – adults aged 60-69 years, then adults aged 50-59 years, Aboriginal and Torres Strait Islander peoples aged 18-54 years and other critical and high risk workers
    • Phase 2b – rest of the adult population (age 18 years and over).

    Whether children (age 17 and younger) will receive the vaccine (potential Phase 3) is yet to be decided.

    No referral will be required for COVID-19 vaccination.  A patient can receive it once they are in an eligible group in the current phase, or if they were in an earlier phase and are yet to be vaccinated.

    For more information on eligibility, see Q&A How do I know if a patient is eligible for COVID-19 vaccine at this time?
  • How will COVID-19 vaccines be supplied? Updated 26 Feb 2021

    COVID-19 vaccines will only be delivered by Government contractors to delivery hubs for administration to patients. 

    Each hub (i.e. a participating GP practice) will be asked to use an online ordering portal for ordering vaccine stocks, and that a weekly allocation will be provided.

    The Vaccine Operations Centre manages vaccine allocation, ordering, co-ordinating delivery and reports of vaccine vial loss or breakage.

    The Commonwealth Health Department is encouraging GPs and their practices to check that the clinic address associated with their Medicare provider number is up-to-date so it matches information provided to the Department for vaccine ordering processes. 

    There are no other means for supply of COVID-19 vaccines outside this mechanism.
  • How will people know they are eligible for COVID-19 vaccination? Updated 26 Feb 2021

    During Phase 1a of the vaccine roll-out, states and territories are arranging for eligible patients to be contacted, usually through employers.

    For later roll-out stages, there will be Government communication initiatives to indicate who is eligible for vaccination at a particular time, and an online eligibility checker.

    There is no expectation or requirement that you contact patients directly to inform them they are eligible for vaccination.  However there is also no restriction on you doing this, particularly if you are seeing a patient for an unrelated condition and they are eligible for vaccination. 

    For more information, see Q&A - 'Can I contact my patients to invite them for vaccination at my practice if they are eligible?' 

  • How is COVID-19 vaccination arranged for patients? Updated 26 Feb 2021

    Eligible patients at each phase can book directly with a delivery hub (such as a vaccination clinic), or find one via the COVID-19 Vaccination Information and Booking Service.  This will be a platform linking to a clinic’s usual booking system or providing their contact details.

    The only restriction on what patients can be booked is whether they are eligible for vaccine at each phase. 

    There is no requirement for a referral for COVID-19 vaccination. 

    There is no restriction on seeing only existing patients or patients in a particular area. 

    The Commonwealth Health Department advises there should be equal access by all eligible patients, irrespective of whether they are an existing patient or not.  A GP vaccination clinic cannot decline to vaccinate a person on the grounds they are not a usual patient of the clinic. 

    Eligible patients can be vaccinated as part of routine / usual care if it does not lead to vaccine wastage. 

    MIGA recommends making available to patients undergoing the Pfizer Comirnaty the following fact sheets from the Australian Government when booking vaccination so they can consider them beforehand:


    Similar documents are expected be produced by the Australian Government for the AstraZeneca vaccine.  Currently available information is here.

    The fact sheets:

    • Detail information which patients should tell you prior to vaccination
    • Set out contraindications and precautions
    • Explain when to delay vaccine
    • Emphasise the need for two vaccine doses. 

    These documents may assist in ensuring patients are ready to give you the information you need and allow them to consider and questions they need to ask before vaccination.
  • Can I advertise COVID-19 vaccination to my patients? New 26 Feb 2021

    Yes, you can advertise COVID-19 vaccination to your patients and the community, within limits.  This includes on physical signage, websites and social media.

    Although advertising vaccinations and prescriptions medications is generally not permitted, the TGA has made an exception for COVID-19 vaccination.

    You must:

    • Only use material developed by Australian Governments – for example the Commonwealth Government template newsletters / editorial and signage / posters
    • Do not modify or add to this material, except to provide vaccine service locations, opening times and appointment arrangements
    • Not use self-developed advertising material
    • Not make comments about potential harms associated with not receiving the vaccine, comparisons between vaccines or provide incentives for vaccination.

    The TGA has provided further guidance, including examples of acceptable and non-acceptable advertising.

    Healthcare advertising is also regulated by the National Boards and Ahpra, who have an advertising hub  providing information and resources.

    MIGA also provides an overview of your advertising obligations generally, including recent changes.
  • Can I contact my patients to invite them for vaccination at my practice if they are eligible? New 19 Feb 2021

    Yes, you are permitted (but not required) to contact your existing patients to come and receive COVID-19 vaccination if you are a COVID-19 vaccination clinic and they are an eligible patient at that time.  

    You need to ensure that your usual patients are not prioritised over other eligible persons.  All eligible persons need to have equal access to vaccination – see Q&A - 'How is COVID-19 vaccination arranged for patients?'

  • How do I know if a patient is eligible for COVID-19 vaccine at this time? Updated 26 Feb 2021

    Eligibility for COVID-19 vaccination is based on the Commonwealth Government’s COVID-19 vaccine national roll-out strategy. This involves a phased roll-out of vaccines, based on population vulnerability – see Q&A How are COVID-19 vaccines prioritised?

    Eligibility needs to be confirmed on patient's presentation.

    You also need to check the patient hasn't already received a COVID-19 vaccine elsewhere.  If in doubt, information on this may be accessible via the Australian Immunisation Register, Clinician Vaccine Integrated Platform (under development) or a patient's My Health Record.

    During each phase, only eligible patients within that phase (and those from earlier phases who have not already been vaccinated) can receive COVID-19 vaccination.

    The Commonwealth Government provides an eligibility checker to assist in determining whether a person is eligible for COVID-19 vaccination at a particular time, and provide further information on assessing eligibility. The Commonwealth Health Department indicates this checker is a ‘self-declaration’ by the patient as to eligibility, and “evidence would need to be observed by the clinic at the time the patient arrives”. For age criteria, this might include drivers’ license or other identifying documents. For underlying conditions, this could include a letter from a treating GP or specialist.

    Even if you are not involved in the vaccine roll-out as a treating doctor you might be asked to confirm your patient's eligibility for COVID-19 vaccination, particularly whether they have an eligible underlying medical condition during Phase 1b. This is based on ATAGI advice on medical conditions posing a moderate / high risk of severe COVID-19 illness.

    These conditions include those who:
    • Are organ transplant recipients on immune suppressive therapy
    • Have had a bone marrow transplant in the last 24 months
    • Are on immune suppressive therapy for graft versus host disease
    • Have haematological cancers, for example, leukaemia, lymphoma or myelodysplastic syndrome, diagnosed within the last 5 years
    • Are having chemotherapy or radiotherapy
    • Have any of:
      • Chronic renal (kidney) failure
      • Heart disease such as coronary heart disease or failure
      • Chronic lung disease, excluding mild or moderate asthma
      • A non-haematological cancer, diagnosed in the last 12 months
      • Diabetes
      • Severe obesity, with a Body Mass Index of 40 or over
      • Chronic liver disease
      • Some neurological conditions including stroke and dementia
      • Some chronic inflammatory conditions and treatments
      • Other primary or acquired immunodeficiency, including HIV
      • Poorly controlled blood pressure.

    Where in doubt about patient eligibility, liaise with your local Primary Health Network.
  • Could a patient's COVID-19 vaccine be delivered at their home? New 5 Feb 2021

    This may be possible in exceptional situations where a patient is unable to leave home.  The Commonwealth Health Department advises:

    "The use of multi-dose vials may preclude or make it challenging for vaccines to be administered when conducting home visits, noting the need to ensure each and every dose is administered and within a certain timeframe. It is recognised that there may be instances in which patients are unable to leave their homes. As such, there may be some instances in which arrangements could be made at a local level whereby all doses within a multi-dose vial could be effectively used; however, this would require careful planning at the practice level and would be the exception, not the rule."
  • Could COVID-19 vaccination be delivered off-site from my practice, i.e. a pop-up clinic? Updated 19 Feb 2021

    The Commonwealth Health Department advises that vaccination could be delivered off-site from an approved, accredited GP clinic, but it will not fund set-up costs. 

    You would also need to be able to comply with all the minimum site requirements for COVID-19 vaccine clinics, including physical environment requirements. 

    You should engage with the Health Department if you are considering this option. 

    The Health Department also advises that there is no specific requirement that patients be observed following vaccination within the practice building, and that clinical judgment can be used to determine a safe observation space (e.g. marquee, patient’s car etc).
  • What are the COVID-19 vaccination contraindications, precautions and adverse events? Updated 26 Feb 2021

    COVID-19 vaccines have been provisionally approved in Australia by the TGA for use to prevent COVID-19 as follows:

    Pfizer COMIRNATY vaccine:
    • Persons aged 16 years and over
    • No decision has yet been made by the Australian Government on vaccination for those under 18 years of age, so it cannot be used for that age group at present
    • The TGA indicates there should be a careful case-by-case assessment of benefits vs risks for those aged over 85 years with this vaccine, but has advised that there is no specific risk of vaccination in elderly people.

    AstraZeneca vaccine:
    • Persons aged 18 and over
    • The TGA indicates decisions to use this vaccine for certain groups should be made on a case-by-case basis, namely those:
      • Aged over 65 – consider age, co-morbidities and environment, factoring in both potential benefits and risks of vaccination
      • With significant co-morbidities – consider potential benefits and risks.    


    In relation to use of the AstraZeneca vaccine in those over 65 of age, the Commonwealth Deputy Chief Medical Officer Prof Kidd has advised:

    The Provider Information Statement from the TGA is highly precautionary and cautious, and is based on current clinical trial information. Further clinical trial information from studies of older people is expected in the coming weeks. The Australian Government is confident the AstraZeneca and the Pfizer vaccines are both safe and will protect against COVID-19 among all adults, including elderly people, and particularly will provide protection against severe disease.  There is no requirement for people over the age of 65 to discuss with their GP whether they should or should not have the AstraZeneca vaccine, unless they are very frail and/or rapidly approaching the end of life. Patients who are very frail, or their carers, are advised to discuss any vaccination with their GP.

    The Australian Government has also produced a decision guide for frail older people, including those in residential aged care facilities.  Amongst other things, this indicates “The [Pfizer Comirnaty] vaccine was also shown to be very effective in older adults who had stable chronic medical conditions … We do not know exactly how much the vaccine will benefit frail older people, but we expect it will be very protective”.

    Contraindications to both the Pfizer COMIRNATY and AstraZeneca vaccines are hypersensitivity to any components of the vaccine being used.  The TGA and ATAGI recommend not giving a second dose of Pfizer COMIRNATY to a patient who had an anaphylactic reaction to the first does of the same vaccine.  In those circumstances the ATAGI recommends seeking advice from their state / territory specialist immunisation service to discuss the need for specialist assessment and make a decision regarding the second dose.

    Precautions for both vaccines include:

    • Acute severe febrile illness or infection – the TGA recommends postponing vaccination
    • Bleeding disorders – the ATAGI recommends informing people with bleeding disorders those on anticoagulant therapy that they may develop haematomas at intramuscular injection sites
    • Immunocompromise
    • Pregnancy – the TGA recommends vaccination when potential benefits outweigh risks.   


    You should familiarise yourself with the following which cover contraindications, precautions and adverse events (as appropriate for the vaccine you are using):

  • What is I/my patient are concerned about them having the COVID-19 vaccination? Updated 19 Feb 2021

    If in doubt about whether COVID-19 vaccination should be given to your patient, or they remain concerned following discussions with you, consider:

    • Liaison with / referral to an appropriate specialist
    • Liaising with your local immunisation service, public health unit or Primary Health Network. 

     
    There is no legal requirement for a patient to receive COVID-19 vaccination.  They can choose not to receive it. 
     
    MIGA’s resource, Informed refusal – communication and documentation provides more information on what to do in situations where a patient declines recommended healthcare. 
     
    For more information generally around discussing COVID-19 vaccination with patients, see Q&A How can I provide informed consent for COVID-19 vaccines?  

  • How can I provide informed consent for COVID-19 vaccines? Updated 26 Feb 2021

    Appropriate informed consent for COVID-19 vaccination is similar to that for other vaccinations.

    Generally you are required to disclose risks which are ‘material’ to a reasonable person in the patient’s position, or which are ‘material’ to that particular patient.  This will depend on how the patient’s condition and how much information they seek. 

    ATAGI has produced a guide to obtaining informed consent for COVID-19 vaccination. It sets out a range of suggested discussion points and information (including a checklist) to assist in answering them, including:
    • Benefits of vaccination
    • Continuing possibility of COVID-19 transmission
    • Need for a second dose of the same vaccine
    • Vaccine safety, possible side-effects and their management, including when to seek medical care
    • Continuation of public health measures (including physical distancing, hand washing, COVID-19 testing)
    • Mandatory reporting vaccinations on the Australian Immunisation Register.

    Generally you should consider:
    • Whether there are any potential contraindications / precautions which should be raised
    • Potential adverse events
    • Previous experiences with vaccinations, particularly adverse reactions
    • Personal and public health benefits of vaccination
    • Any particular concerns which the patient may have. 

    There is no requirement for written consent from the patient, but MIGA recommends:
    • Using the Australian Government Consent form for COVID-19 vaccination or similar forms developed by your hospital
    • All consent should be documented in patient records
    • For patients with precautions or who raise concerns, documenting your discussions with the patient. 

    For women who are considering pregnancy, pregnant or considering breastfeeding, the Australian Government has prepared a decision making guide to provide to those patients, which provides recommendations and information. 

    A decision guide has also been prepared by the Australian Government for frail older people, including those in residential aged care facilities.

    MIGA’s resource What is informed consent provides more information about general requirements for informed consent.   

    For situations when a patient lacks capacity to provide informed consent, see MIGA’s resources Substitute consent.
  • I am administering vaccinations in an aged care facility. Who is responsible for providing informed consent? Updated 26 Feb 2021

    The Commonwealth Government has advised that under Phase 1a of the vaccine roll-out (see Q&A How are COVID-19 vaccines prioritised?) the aged care facility is responsible to ensure informed consent is obtained from the resident (or their substitute decision-maker if they lack capacity) for vaccination.

    Facilities are required to have a Clinical Lead (e.g. a registered nurse) who is responsible for vaccine program management at the facility, including liaising with immunisation providers and ensuring informed consent has been obtained.   Facilities are required to consult with GPs if there are concerns about a resident’s suitability for a vaccine. 

    More information around responsibilities is available in the Australian Government’s Clinical Governance requirements for COVID-19 Vaccination Clinics at RACF (residential aged care facilities). 

    You will need to ensure informed consent has been provided prior to vaccinating the patient.  Completion of the Australian Government Consent form for COVID-19 vaccination would generally be sufficient.   If not provided, you should ensure informed consent is provided prior to vaccination (see Q&A How can I provide informed consent for COVID-19 vaccines?).

    The Commonwealth Health Department has also released a decision guide for frail older people, including those in residential aged care facilities.

    The Australian Government has also advised immunisation providers should be alert to residents that have a bleeding disorder or are taking anti-coagulant medication – see Q&A What are the COVID-19 vaccination contraindications, precautions and adverse events?  

    You may encounter residents and family members who have questions after informed consent has been provided.  Even though consent may already have been provided, as is the case before any healthcare you need to try and answer the questions to the best of your ability and ensure they are comfortable to proceed prior to vaccination. 

    MIGA’s resource Capacity and consent in the elderly provides further information around capacity and consent issues for this age group.

  • What are the post-vaccination observation requirements? New 19 Feb 2021

    ATAGI advises the following post-vaccination assessment and monitoring of the patient before they leave the practice is required:

    • At least 15 minutes for all patients to ensure immediate adverse reactions
    • 30 minutes for patients with a history of anaphylaxis to any antigen (including food, insect stings, medicines) and those who have been prescribed an adrenaline autoinjector (e.g., Epipen).
  • What advice should I provide to patients following vaccination? New 19 Feb 2021

    Following vaccination, you should advise patients about the need to:
    • Monitor for any adverse reactions after leaving the practice (ATAGI provides guidance on them)
    • When to seek medical attention
    • Continue to follow public health advice to minimise the risk of COVID-19 infection and transmission.

    For the Pfizer Comirnaty vaccine, MIGA recommends providing the Australian Government After your COVID-19 vaccination factsheet to patients following vaccination, explaining what they can expect, when to seek medical attention and when COVID-19 testing may be required.  A similar factsheet is expected to be produced for the AstraZeneca vaccine. 
  • Do COVID-19 vaccinations need to be reported to the government/regulator? Updated 19 Feb 2021

    Yes.  COVID-19 vaccinations must to be reported to the Australian Government’s Immunisation Register (AIR), ideally within 24 hours of vaccination.     

    This requires PRODA and HPOS registration, reporting via practice software upload, the Clinician Vaccine Integrated Platform or the AIR portal.

    Patients can access an AIR Immunisation History Statement, recording COVID-19 vaccination.

    COVID-19 'proof of vaccination' certificates, based on AIR data and accessible by a patient following vaccination on the MyGov website or via the Express Plus Medicare app, have also been foreshadowed.

  • What are the recommended timeframes between COVID-19 vaccine dosages? New 19 Feb 2021

    The TGA recommends the following timeframes between first and second doses of the following COVID-19 vaccines:
    • Pfizer COMINARTY vaccine – the TGA recommends at least 21 days apart – ATAGI recommends completing the two doses within 6 weeks, with 19 days between doses being the minimum acceptable interval
    • AstraZeneca vaccine – the TGA recommends 12 weeks between doses, but if this interval is not possible (offering examples of imminent travel, cancer chemotherapy or major surgery) there can be a minimum of 4 weeks between doses.
  • How can I ensure patients return for any necessary second dose of COVID-19 vaccine? Updated 19 Feb 2021

    You should ensure your patient:
    • Understands the need to return for a second dose of vaccine
    • Either makes a booking for a second dose at the time of the first dose, or is reminded about the need to return for a second dose if not booked soon afterwards.


    Follow-up of patients who miss a vaccination appointment or fail to return for a second dose should follow a similar process to your normal procedures for patient follow-up.  This could involve a reminder call or SMS to a patient, followed by an email or letter to emphasise the need to return for the second dose.
      
    For the Pfizer Comirnaty vaccine, MIGA recommends providing the Australian Government After your COVID-19 vaccination factsheet to patients following vaccinationwhich emphasises the need and timeframe for a second dose of this vaccine.  A similar factsheet is expected to be produced for the AstraZeneca vaccine.  

    MIGA’s resource Patient follow-up – Recalls and reminders provides more information and tips on meeting requirements for patient reminders and follow-up. 

  • What advice is available on providing COVID-19 and flu vaccines at the same time? Updated 19 Feb 2021

    ATAGI advises:
    • Routine scheduling and administration COVID-19 vaccine and flu vaccine on the same day is not recommended
    • It is preferred there is a minimum of 14 day between COVID-19 and flu vaccinations
    • ​If an individual is likely to miss the opportunity to receive vaccine doses because of this minimum interval, or there is an imminent need to administer either vaccination because of local circumstances, shortening the interval between or same day administration of COVID-19 and flu vaccination may be justified
    • There is no particular requirements for the order of COVID-19 and flu vaccines.

    ATAGI also recommends a minimum of 14 days between administering the Pfizer COMIRNATY vaccine and any other vaccine.

    There is no particular requirements for the order of COVID-19 and flu vaccines.
  • How is COVID-19 vaccination billed to Medicare? Updated 19 Feb 2021

    Temporary Medicare COVID-19 vaccine suitability assessment bulk billing only item numbers are being developed for COVID-19 vaccination, based on existing Level A consultation items and incorporating bulk billing incentives.

    Individual MBS COVID-19 vaccination item descriptors and explanatory notes are being finalised, but a detailed factsheet is available.

    There are different items for GPs and other medical practitioners, urban and rural settings, and after hours services (based on usual non-urgent MBS after-hours periods). There are also COVID-19 Vaccine Incentive Payments for practices enrolled in the Practice incentives program.

    The items are billed in the name of the supervising GP (or other doctor working in general practice), who must be present at the location where the assessment is being undertaken and accept “full responsibility” for the service.

    Activities associated with each item can be undertaken by a GP, other doctors working in general practice, registered nurse or other suitably qualified registered health practitioner working within their scope of practice who have undertaken required COVID-19 vaccination training.  For more information on who can undertake COVD-19 vaccination generally, see Q&A Who can be involved in delivery of COVID-19 vaccines?

    The items can be billed at each vaccination appointment, so long as the item requirements are met.  This means they can be used when both first and second doses of a vaccine are given (there are different items for each appointment).

    If a patient chooses not to go ahead with vaccination following assessment, the relevant MBS item can still be billed if its requirements are met.  If a patient decides not to receive a COVID-19 vaccination, but later chooses to receive it, the relevant item numbers can still be billed at each consultation.

    Medicare COVID-19 vaccination items are exempted from the ‘80/20’ rule (the Medicare “prescribed pattern of service”), triggering a compliance process and Professional Services Review referral.

    It will be important to familiarise yourself with the MBS item descriptors and notes once available, and ensure you follow their requirements strictly.

  • What limits are there on COVID-19 vaccination billing? Updated 26 Feb 2021

    The Commonwealth Government has announced that COVID-19 vaccinations will be free to the population. 

    It has indicatedConsistent with the Australian Government’s commitment that the vaccine will be free, general practices will not be permitted to charge co-payments for vaccine administration”.

    Consequently the only permissible COVID-19 vaccination billing are via the MBS COVID-19 vaccine suitability assessments items bulk billed by GPs or other doctors working in a GP setting.

    The Commonwealth Government considers these items are sufficient for vaccine billing, without need for co-claiming. All aspects of COVID-19 vaccine assessment and administration must be free to the patient and bulk billed. As is the case for bulk billing generally, there should be no charges associated with COVID-19 vaccination, such as new patient registration or consumables charges.
  • Do I need a referral for COVID-19 vaccination to bill Medicare for it? New 19 Feb 2021

    No, a referral is not required for COVID-19 vaccination billing, or for COVID-19 vaccination generally.

    Eligibility for COVID-19 vaccination is based on eligibility criteria during each phase of the vaccine roll-out - see Q&A - 'How are COVID-19 vaccines prioritised?'

  • Does Medicare require the claiming doctor to see the patient personally? New 26 Feb 2021

    No, the claiming doctor is not be required see or assess the patient in person in order to claim MBS COVID-19 vaccine assessment items.

    A claiming doctor will need to be on-site during vaccination (telehealth availability is insufficient) and take 'full' responsibility for other team members (e.g. registered nurses) assessing patients and delivering vaccinations to them.

    Doctors need to be available to see COVID-19 vaccination patients as clinically appropriate.

    There is are no limitations on doctors seeing patients for COVID-19 vaccination. 

    If you are not seeing the patients yourself for vaccination you should ensure:

    • Only appropriately qualified staff are managing the patients – see Q&A - 'Who can be involved in delivery of COVID-19 vaccines?' 
    • You have appropriate processes in place for triage, assessment and observation
    • Any issues requiring attention of a doctor are referred promptly to you as clinically appropriate.  Depending on individual circumstances, this might include patients with suspected contraindications, certain precautions or who have complex or many questions about vaccination. 
  • What assessment requirements are there to bill a Medicare COVID-19 vaccination assessment item number? New 26 Feb 2021

    The MBS COVID-19 vaccine assessment items include the following requirements:

    • A face-to-face attendance on the patient by a GP or other suitably qualified and registered health practitioner
    • Scope for a short patient history and limited examination / management where clinically relevant
    • The vaccine needs to be immediately available to administer to a suitable patient
    • Post-vaccination observation is required in line with professional requirements.
  • What are the Medicare COVID-19 vaccination assessment item record-keeping requirements? New 26 Feb 2021

    The MBS COVID-19 vaccination assessment record-keeping requirements include:

    • Completion at time of service or as soon as practicable afterwards
    • Clearly identifying the name of the patient
    • Reasons for the patient’s attendance
    • Outcomes of the consultation, including whether or not the patient received a COVID-19 vaccine
    • Contain a separate entry for each attendance by the patient for the vaccination suitability assessment service and the date(s) on which the service was provided
    • Record the patient’s consent to receive the vaccine
    • Provide clinical information adequate to explain the service
    • Be sufficiently comprehensible that another GP, relying on the record, can effectively undertake the patient’s ongoing care as it relates to COVID-19 vaccinations.

    In addition, the Commonwealth Health Department recommends recording the time of service for any after hours billing.
  • Can I still bill the Medicare COVID-19 vaccination assessment items if the patients chooses not to receive the vaccination? New 26 Feb 2021

    Yes. If a patient is assessed as not being suitable or doesn’t want to go ahead with vaccination, the MBS items can still be billed if the item requirements are met.

    If a patient needs more than two assessment services, only one PIP incentive payment can be paid. 

    The Commonwealth Health Department has indicated there shouldn’t be more than one claim on the same day (eg patient decides against vaccine, then changes their mind) unless there are exceptional circumstances which need to be detailed in the patient’s records.

  • Can I see a patient for other medical issues at the same time as COVID-19 vaccination and use my usual billing practices for those other issues? New 26 Feb 2021

    Yes, in certain circumstances where this is necessary.

    According to the Commonwealth Health Department:

    • Patients presenting with multiple clinical matters should be encouraged to book a separate consultation, preferably with their usual practice
    • There are some circumstances where deferring other treatment is not feasible (e.g. patient is ill or there is scope for “opportunistic treatment for other conditions” where “clinically appropriate” – a range of scenarios have been provided in the Department’s detailed fact sheet
    • Standard MBS multiple same-day attendance rules apply for co-claiming including:
      • The other GP service must be unrelated to the vaccine assessment item
      • The subsequent attendances are not a continuation of the initial or earlier attendances.
    • Before billing, there is a need for informed financial consent for the patient so they understand there is no cost with the Covid vaccine component, and understands how the other service is billed
    • You should include a note stating ““The additional service [MBS item…] is clinically relevant but not related to the vaccine suitability assessment service [MBS item…].”
    • No items can be claimed for time spent administering a vaccine following assessment
    • COVID-19 vaccination assessment items cannot be co-claimed with certain other bulk billing incentive items – see the Department’s detailed fact sheet for more information.
  • What if a non-Medicare eligible patient presents for vaccination at an approved GP clinic? New 5 Feb 2021

    Non-Medicare eligible patients cannot be ‘privately’ billed. 

    The Commonwealth Health Department advises that non-Medicare eligible patients should be referred to a GP respiratory clinic or state / territory immunisation clinic. 

    It has foreshadowed providing further information on what to do where these alternatives do not exist. 

  • My patient experienced an adverse reaction to the COVID-19 vaccination. Does this need to be reported to the government/regulator/MIGA? New 5 Feb 2021

    Practitioners should report suspected adverse events following COVID-19 vaccination to the TGA and their local state / territory health department
     
    Whilst reporting is only mandated in some states and territories, it is encouraged for adverse reactions more generally. 

    For more information on reporting, see the TGA’s Reporting suspected side effects associated with a COVID-19 vaccine

    If your patient experiences a significant and persistent adverse reaction to COVID-19 vaccination, we encourage you to contact MIGA’s legal team (email claims@miga.com.au or telephone 1800 839 280) for advice and support.
  • My patient seeks a certificate exempting them from COVID-19 vaccination. What should I do? Updated 26 Feb 2021

    There is no law requiring a patient to have a COVID-19 vaccination.

    It is conceivable that patients may be in situations where they are expected or encouraged to be vaccinated.

    Requests for ‘exemption certificates’ might be based on contraindications or personal choice. 

    In providing any certificate or other letter for a patient declining COVID-19 vaccine, you should:
    • Be up-to-date with current government, regulatory and professional guidance on COVID-19 vaccinations, contraindications and precautions – see Q&A What are the COVID-19 vaccination contraindications, precautions and adverse events?
    • Limit your certificate / letter to clinical issues within your expertise
    • Avoiding being perceived to support patient decisions which are not based on clinical grounds (e.g. recognised contraindications)
    • Consider providing your patient with further information on COVID-19 vaccination from appropriate sources, or arranging appropriate specialist referral to discuss their concerns
    • Be aware that there is no requirement for you to provide a certificate / letter if you do not feel comfortable in doing so. 

    For further information, see Q&A - "A patient wants a medical clearance certificate for COVID-19.  Can I give this?"  for more information on certificates generally.
  • When will the COVID-19 vaccines be available for healthcare workers? New 19 Feb 2021

    During Phase 1a of the vaccine roll-out, “frontline healthcare worker sub-groups for prioritisation” are eligible for the vaccine.  This includes:

    • Clinical staff, medical students and administrative staff in facilities and services such as hospital emergency departments, COVID-19 and respiratory wards, Intensive Care Units and High Dependency Units
    • Laboratory staff handling potentially infectious material
    • Ambulance and paramedics services
    • GP respiratory clinics workers
    • COVID-19 testing facility workers


    All other healthcare workers are eligible for COVID-19 vaccination during Phase 1b of the roll-out. 
    For more information on the roll-out phases, see Q&A - 'How are COVID-19 vaccines prioritised?'

  • Can I require my practice staff/can I be required by my workplace to undergo COVID-19 vaccination? Updated 26 Feb 2021

    Generally workplaces can take reasonable steps to ensure workplace safety – this includes both for workers and visitors. 

    Whether COVID-19 vaccination could be required depends on a variety of issues, and will depend on individual circumstances. 

    Whether a workplace can mandate COVID-19 vaccination of its workers depends on:
    • Whether there are any public health directions / other legal requirements around COVID-19 vaccination
    • Government, workplace regulator and public health advice
    • Current risks of COVID-19 transmission in your workplace and in your local area
    • Extent to which vaccination would reduce the risk of COVID-19 transmission in your workplace
    • Whether you / your staff member have medical condition which may make COVID-19 vaccination unsuitable
    • Considering whether other measures, such as physical distancing, cleaning, PPE use and minimising contact with others (including work from home), sufficiently reduce the risk of COVID-19 infection.

    At this stage, Safe Work Australia indicates that it is unlikely an employer requirement for COVID-19 vaccination would be considered a “reasonably practicable” step to eliminate or minimise risk of exposure to COVID-19 in the workplace, but it will ultimately depend on particular circumstances at any one time. It provides a range of factors to consider in undertaking a risk assessment (which are similar to those set out above). 
     
    Absent public health or other legal requirements for COVID-19 vaccination, it would be preferable to encourage vaccination in the workplace, and consider individuals’ reluctance to do this on a case by case basis.  This might include exploring concerns, obtaining public health and / or specialist advice on the situation, and other viable ways of reducing the risks of COVID-19 transmission.

    Safe Work Australia is progressively providing guidance and information on COVID-19 vaccination and workplace issues.

    The OAIC has also released guidance on the obligations that organisations have to their workers if they want to keep records of their workers’ COVID-19 vaccinations.
  • Could healthcare workers refuse to come to work if another worker isn’t vaccinated? New 26 Feb 2021

    Safe Work Australia indicates that “In most circumstances, a worker will not be able to rely on work health and safety laws to cease work simply because another worker at the workplace isn’t vaccinated, however this will depend on the circumstances”.

    For a worker who is reluctant to come to work if others are not vaccinated in the workplace, MIGA recommends exploring their concerns, obtaining public health and / or specialist advice on the situation, and considering whether there are other ways of reducing the risks of COVID-19 transmission.
  • What guidance is available on administering COVID-19 vaccines? Updated 26 Feb 2021

    Commonwealth Government


    ATAGI


    TGA


    NCIRS - COVID-19 vaccines: Frequently asked questions

    NPS MedicineWise - Q&A on Vaccines and COVID-19

    MBS Online – COVID-19 Vaccine Suitability Assessment Service information

    Ahpra – COVID-19 vaccination

    Safe Work Australia – COVID-19 vaccination information


    States / territories

     

Insurance cover for other COVID-19 matters

Note - the answers in this section only apply to MIGA policies issued to doctors, Eligible Midwives and healthcare businesses about their insurance cover in relation to COVID-19.
  • Am I covered for treating COVID-19 patients? Updated 3 Apr 2020

    Yes. Claims and inquiries arising from services provided to patients who may be or are suspected of being infected with COVID-19 are covered by MIGA’s insurance policies. *

    We cover you for healthcare services provided within your insurance category / scope of practice or healthcare business irrespective of the patient’s condition.

    If you are being asked to undertake, or are considering undertaking, a new or different role that may be outside your scope of practice and have any concerns around your medical indemnity insurance or any medico-legal implications, please contact us for assistance. We’ll help to make sure that your cover is appropriate for what you are doing and to guide you on potential medico-legal issues involved.


    * Your individual cover is subject to your chosen category of practice and the terms and conditions of your policy with MIGA.  If you are a doctor whose practice entity employs other doctors, Eligible Midwives or others who bill in their own name, you must ensure that they have their own insurance arrangements in place to cover any disease that they might carry and transmit to others in your practice.

  • Am I covered for providing telehealth? Updated 6 Aug 2020

    Yes. Claims arising from healthcare services provided to patients in Australia via telehealth consultations are covered by MIGA’s insurance policies *

    Within your scope of practice, our policies do not place limitations on how you provide your care.

    Telehealth is a well-recognised way of providing care in a wide variety of situations and can include consultations via a wide range of video platforms and telephone.

    You need to ensure that you conduct telehealth in accordance with applicable professional guidelines - see our various Q&A on telehealth.

    * Your individual cover is subject to your chosen category of practice and the terms and conditions of your policy with MIGA.  If you are a doctor whose practice entity employs other doctors, Eligible Midwives or others who bill in their own name, you must ensure that they have their own insurance arrangements in place to cover any disease that they might carry and transmit to others in your practice.

  • Am I covered if I am unknowingly infected and I infect patients resulting in a claim? Updated 17 Jul 2020

    Yes. Claims arising from healthcare services provided whilst you are infected with COVID-19 are covered by MIGA’s insurance policies *

    Your policy requires you to ensure that you take adequate precautions to prevent the transmission of a virus, bacteria or disease, which means that the steps that you take to prevent transmission must be accepted as competent practice by your peers.

    This would mean that you follow professional obligations for infection control, keep up to date with the potential signs and symptoms of COVID-19, know when to be tested (including the criteria for healthcare worker testing) and follow government requirements for quarantine and isolation (e.g. following travel overseas or to a COVID-19 hotspot, close contact with a confirmed COVID-19 case etc.)

    We recommend that you keep up to date with advice and other information on these issues from Commonwealth Department of Health’s COVID-19 advice for the health sector, your local health department and professional college / association (a range of relevant links are provided on MIGA’s COVID-19 web resources.

    If in doubt about any of these issues, seek advice from your local public health unit.

    If you are aware you are infected or suspect you may be, you should notify your hospital / health service, immediately cease practice, follow public health and other medical advice and complete the necessary isolation period before returning to practice.  

    * Your individual cover is subject to your chosen category of practice and the terms and conditions of your policy with MIGA.  If you are a doctor whose practice entity employs other doctors, Eligible Midwives or others who bill in their own name, you must ensure that they have their own insurance arrangements in place to cover any disease that they might carry and transmit to others in your practice.

  • Am I covered if I change my scope of practice? Updated 1 May 2020

    Yes, if you need to change your scope of practice you are covered provided it is permitted by your Ahpra registration and you are in the appropriate category of cover with us.*
     
    We recommend you take the following steps before starting your new work:
    • Ensure your Ahpra registration does not prevent you from the new scope of practice - the Medical Board has confirmed that doctors with general and specialist registrations are not restricted in their scope of practice because they have specialist registration
    • Be comfortable that you have the necessary skills, training and experience to provide the level of care expected, and your hospital, practice or other workplace agrees (see below Q&A ‘What if am asked to work outside my usual scope of practice to help my hospital deal with COVID-19 cases?’ for further guidance)
    • Confirm with your hospital, practice or other workplace (preferably in writing) that you will have the benefit of any insurance cover you are normally entitled to as an employee or contractor (e.g. as a visiting medical officer for public patients) 
    • Contact MIGA to ensure you have the right category of insurance cover with us. 

     

    * Your individual cover is subject to your chosen category of practice and the terms and conditions of your policy with MIGA.  If you are a doctor whose practice entity employs other doctors, Eligible Midwives or others who bill in their own name, you must ensure that they have their own insurance arrangements in place to cover any disease that they might carry and transmit to others in your practice.

  • How might restrictions on healthcare in a COVID-19 hotspot affect my cover? New 6 Aug 2020

    Public health directions may restrict healthcare which may be provided, particularly in a COVID-19 hotspot - see Q&A on healthcare restrictions.  

    We are conscious that this is an extremely challenging time for our members and clients, and that there is potential scope for uncertainty in individual situations.  

    It is important that you take reasonable steps to ensure you only provide healthcare in accordance with applicable public health directions, and regulatory, workplace and peak body guidance.   

    Through our Q&As, we endeavor to provide you with available information around these issues.   

    When in doubt, you should liaise with your local health department, public health unit, relevant peak body and workplace as appropriate.  If you remain in doubt, contact MIGA legal services.  

    * Your individual cover is subject to your chosen category of practice and the terms and conditions of your policy with MIGA.  If you are a doctor whose practice entity employs other doctors, eligible midwives or others who bill in their own name, you must ensure that they have their own insurance arrangements in place to cover any disease that they might carry and transmit to others in your practice.


    * Your individual cover is subject to your chosen category of practice and the terms and conditions of your policy with MIGA.  If you are a doctor whose practice entity employs other doctors, Eligible Midwives or others who bill in their own name, you must ensure that they have their own insurance arrangements in place to cover any disease that they might carry and transmit to others in your practice.

Healthcare restrictions

  • Do any restrictions remain on Victorian healthcare following the end of the five-day lockdown on 19 February 2021? Updated 19 Feb 2021

    From 19 February 2021, restrictions on Victorian healthcare during the five day lockdown, limiting it to only ‘essential’ healthcare face-to-face, have been removed.  Restrictions on elective surgery, including cosmetic procedures, have been removed.
     
    The only remaining lockdown restriction on Victorian face-to-face healthcare is that fitted face masks must be worn when leaving the home, including to provide or receive face-to-face healthcare, unless specific exceptions apply. 
     
     
    Existing Victorian healthcare requirements which continue include:

    • Businesses must continue to have a COVID Safe Plan
    • A workplace attendance register of all persons at the premises for longer than 15 minutes is required where confidentiality obligations do not apply (ie it is not required to be kept for patients) – use of electronic records or QR codes are recommended, such as the Victorian Government free QR code service
    • Regular cleaning of premises using disinfectant
    • Hospitals and day surgeries have additional obligations around daily comprehensive cleaning and worker declarations before starting shifts, and further obligations for high-risk services (i.e. treating confirmed COVID-19 cases or if in areas of community transmission)
    • For any COVID-19 cases amongst staff, notify both WorkSafe Victoria and the Victorian Health Department, which has further information on notification and other necessary responses, including isolation, risk assessment and management.
  • What requirements are in place around face-to-face healthcare? Updated 26 Feb 2021

    For information about requirements for Victorian face-to-face healthcare following the end of the five day lockdown on 19 February 2021, see Q&A - 'Do any restrictions remain on Victorian healthcare following the end of the five day lockdown on 19 February 2021?'

    There are specific state and territory public health order / directions applying to healthcare in South Australia, Queensland, Western Australia and the Northern Territory, detailed below.

    In New South Wales, Tasmania and the ACT, public health orders relating to COVID-19 safety plans, density limits and collecting visitor information (via QR code or otherwise) do not apply to healthcare.  MIGA understands this to be on the basis that existing healthcare procedures, including for infection control and prevention, and the keeping of records should already minimise the risk of COVID-19 transmission and allow any necessary contact tracing.

     

    South Australia

    For face-to-face care South Australian healthcare providers must:

    • Have a completed COVID Safe Plan – once completed and lodged you will receive a unique QR code for patients and visitors to use for your premises
    • Use an approved contact tracing system (including COVIDSAfeCheckIn via the mySA GOV app) to capture the contact details of patients and other visitors
    • Use “best endeavours” to ensure contact details are recorded
    • Use a paper recording log if a patient or visitor lacks a smart – these should be kept for 28 days then disposed of securely
    • Ensure total number of persons in ‘public’ (i.e. patient accessible areas) areas of your premises (excluding staff members and anyone else providing healthcare), and within a single room or other enclosed area, does not exceed 1 person per 2 sq m
    • Use best endeavours to keep a distance of 1.5m between people, unless required for healthcare (e.g. physical examination).


    Queensland

     
    In Queensland, cosmetic injections are permitted so long as your practice:
    • Operates in compliance with a COVID SAFE framework (including a COVID Safe checklist)
    • Has ‘public health controls’ to reduce risks, which may include “environmental cleaning, hygiene measures, regular washing of hands, availability of hand sanitiser and avoiding handshaking
    • Collect and keep contact information about all visitors (information separate to usual healthcare or financial records should be deleted after 30 days) – more information is available here 
    • For public areas, has no more than 1 person per 2 square metres
    • Practice physical distancing (1.5 metres) where reasonably practicable
    • More information is available here.

    Western Australia

    From 14 February 2021, those in the Perth and Peel regions are no longer required to wear a mask outside the home.

    Public and private hospitals are required to collect contact information from visitors (patients are excluded from this requirement), but this requirement does not extend to community healthcare settings.


    Northern Territory

    Hospitals and other premises where healthcare is provided must:
    • Lodge a COVID-19 safety plan online and review it 6 monthly
    • Appoint a COVID-19 safety supervisor
    • Collect contact information (including time of entry) from visitors present for more than 15 minutes – The Territory Check In app  or paper system can be used for this
    • Provide hand sanitiser or handwashing facilities
    • Conspicuously display signage encouraging people to consider COVID-19 safety principles and practices.

    More information is available here

    The RACGP has produced a template COVID-19 safety plan which can be adapted for your practice and local state / territory requirements.

  • What requirements exist around doctors entering aged care facilities to treat their patients? Updated 19 Feb 2021

    Across Australia there are various restrictions in place around entry to aged care facilities.

    Doctors and other healthcare workers are permitted entry, but a range of differing restrictions can apply around any recent travel, close contact of a confirmed COVID-19 case, presence of respiratory symptoms and whether they have been vaccinated against seasonal influenza.

    You should also check current state or territory restrictions where you practice, as these can change in response to levels of community transmission – see for ACT, NSW, NT, Queensland, SA, Tasmania, Victoria and WA

    Specific state requirements include:

    • Victoria - doctors and others visiting aged care facilities are required to wear a fitted face mask
    • New South Wales – doctors and others visiting aged care facilities in the Greater Sydney region are required to wear a surgical mask.
    • Queensland
    • ​Western Australia
      • Healthcare must be provided by telehealth, or by attending an external facility, where reasonably practicable or in the resident's best interests.

    ICEG has also provided COVID-19 guidelines for infection prevention and control in residential care facilities

  • Are there any restrictions on surgery? Updated 19 Feb 2021

    Victoria – end of lockdown
     
    From 19 February 2021, there are no longer any restrictions on elective surgery or cosmetic procedures.
     
    Safer Care Victoria has also released guidance on prioritising elective surgery as COVID-19 restrictions ease, and best practices approaches for specific procedures more generally.
     
    Outside Victoria



    Elsewhere across the country, elective surgery has remained at 100% of usual volumes. 
     
    You should:

    • Know your state or territory requirements and peak body guidance for surgery – including any screening requirements
    • Where surgery may be delayed, have a process in place for assessment and ongoing review of degree of urgency for surgery or other procedures for your patients, so you know about and can act on any deterioration or other changes in your patient’s condition.

Protecting yourself, your colleagues and your patients

Managing COVID-19 - testing, certificates, privacy, medications & vaccines

  • My patient doesn't fit the criteria for COVID-19 testing, but they are demanding a test. Updated 10 Sept 2020

    Except in WA, outside health department criteria for COVID-19 testing, any testing is at the discretion of the clinician.

    You are not compelled to provide care you believe to be unwarranted or inappropriate.

    In WA there are Testing Directions restricting on what COVID-19 testing primary health care providers can order, with an evolving range of exemptions detailed. 

    If in doubt about whether a test is warranted or appropriate contact your local public health unit. 

     
  • Are there special requirements/restrictions on COVID-19 tests? Updated 23 Nov 2020

    Outside notifiable disease obligations for COVID-19, there are various other obligations / restrictions around testing in certain states.
     
    Pathology laboratory obligations
     
    In South Australia, by public health order there are requirements for responsible person for a pathology service to ensure:

    • Notification of COVID-19 testing results to patients within a timely manner, which must be within 72 hours of swabbing
    • SA Health Communicable Disease Control Branch notification of various details of tests, both undertaken to date and on an ongoing basis
    • Appropriate laboratory accreditation, quality assurance (including clinical microbiologist oversight) and following the national COVID-19 surveillance plan.


    Point of care / rapid antigen testing

    The PHLN and CDNA have released a joint statement on COVID-19 rapid antigen tests, indicating they should only be used with medical oversight under public health direction in specific settings, strictly following the manufacturer’s instructions and applicable laws / regulations.

    South Australia, Queensland and Western Australia, certain point of care COVID-19 tests are precluded by public health order.  Western Australia also precludes the use of rapid antigen testing.  Financial penalties apply for their use.  In Western Australia certain exceptions apply, including in certain remote communities.

    Victoria advises against the use of various rapid point of care COVID-19 tests outside a research framework or unless specifically advised by the Victorian Health Department.  Its "test of choice" for the diagnosis of acute coronavirus (COVID-19) infection is the reverse transcription-polymerase chain reaction (RT-PCR) assay confirmed in a laboratory. 

    The TGA has confirmed that supply of self-tests for COVID-19 is prohibited. 
     
    Each of the AHPPC, the TGA, the PHLN and the RCPA have issued guidance on these issues.

     

  • My patient refuses to follow advice for COVID-19 testing or self-isolation. What should I do? Updated 15 Oct 2020

    These situations may pose a risk to public health and safety.  Contact your local public health unit for advice.

    In some places, a refusal to undergo a test may be a breach of public health orders.

    Your patients should be encouraged to check their local requirements if they are reluctant to undergo testing.  Breaches can lead to financial or criminal penalties for them.
  • A patient wants a medical clearance certificate for COVID-19. Can I give this? Updated 29 Sept 2020

    Patients are approaching their doctors for a range of certificates or clearances associated with the COVID-19 pandemic, particularly following quarantine / isolation, they are vulnerable to COVID-19 or have chronic health conditions.

    Release from isolation

    In Victoria, there are specific requirements around isolation, overseen by the local public health unit.  The DHHS provides clearances once isolation is complete.

    NSW Health provides specific advice on COVID-19 release from isolation.   

    More generally the CDNA and PHLN Revised Australian criteria for the release of persons recovered from COVID-19 from isolation provides detailed information around isolation requirements.


    Vulnerability to COVID-19

    For patients seeking medical certificates around vulnerability to COVID-19:


    Medical certificates generally

    For medical certificates MIGA advises:
    • Be clear on the limits of your knowledge and expertise, both with the patient and in the certificate
    • When writing the certificate, clearly demarcate between patient history on the one hand, and your examination findings, assessment, opinion and recommendations on the other
    • Don’t let the patient ‘drive’ what is in the medical certificate – only ever include opinions you feel comfortable and confident in expressing
    • Generally speaking, the clearer the basis for your opinions and recommendations the more likely those relying on the certificate will be willing to accept them
    • It is generally better to avoid certificates lacking detail about your findings and the basis for your recommendations – if the patient doesn’t want this in the certificate explain to them this could make the certificate less useful, and consider whether you are comfortable providing a certificate lacking detail
    • Be careful about the questions you are answering – if asked to give an opinion on whether the patient fits certain criteria (e.g. ‘vulnerability’), answer based on the definition given, not your own interpretation of what the criteria should be
    • It may be the best certificate you can give is to explain the history given and clinical diagnoses if you can’t address certain questions the patient / employer want answered
    • Be prepared to say to a patient you cannot give the opinion they seek – it may be they need to see someone else with particular expertise on the issue, i.e. specialist physician or surgeon
    • Given the misconceptions around ‘certificates’, it may be better in some situations to provide a short ‘letter’ or ‘report’ instead, not using the terms ‘certificate’ or ‘clearance’.

    For medical certificates generally, the Medical Council of NSW and AMA have each prepared medical certificate guidelines.   

    The RACGP has prepared a template letter to employers, schools and child care centres around issues with requesting medical certificates or clearances.
  • Can I undertake certain practice activities, like COVID-19 testing, outside or in other premises? Updated 15 Dec 2020

    A number of our members and clients are exploring different options for where to provide certain medical services in order to minimise risks of COVID-19 transmission, e.g. outdoor flu clinics, using separate rented premises for some face-to-face clinical presentations. 

    MIGA supports these initiatives where:

    • They are for reasons of patient and / or staff safety
    • ​You are able to provide the same level of care as you would in your usual practice location.  This includes availability of necessary emergency and monitoring equipment, infection control, post-injection monitoring and privacy / confidentiality. 


    NSW Health has provided guidance on drive-through, pop-up and mobile van COVID-19 screening clinics.

    If you are considering running certain face-to-face practice activities from a different physical location (i.e. new rented premises):

    • Consider whether you should seek a separate Medicare provider number
    • ​Make sure the owner is aware of the nature of what is being done.


    Check  if your other business insurances (e.g. workers’ compensation, public liability, business interruption etc) cover these activities.

  • Can I encourage my patients or staff to use COVIDsafe, the contact tracing app? Updated 22 May 2020

    You can encourage your patients to use COVIDSafe, but you cannot do anything that could be considered coercion or compulsion to do so.

    For example, you cannot make use of COVIDSafe a condition of attending your practice or remaining your patient.

    Similarly, you cannot compel your staff to use COVIDSafe as a workplace requirement.

    Breaches of these restrictions may lead to financial and/or criminal penalties. 

    More information about COVIDSafe is available here.
  • Are there restrictions on medications for managing COVID-19? Updated 26 Feb 2021

    There is a range of regulatory and peak body advice on COVID-19 clinical management, including for:


    Further advice:

  • What are the Victorian notification and response requirements if there is a COVID-19 case in my staff? Updated 15 Dec 2020

    There are requirements to notify both WorkSafe and the Victorian Health Department of COVID-19 cases in your workforce.

    Details on how to notify WorkSafe Victoria are available here.

    Other necessary steps

    The Victorian Department of Health has further information on notification and other necessary responses, including isolation, risk assessment and management.
  • My patient died from COVID-19. How do I certify cause of death? New 9 Apr 2020

    The Australian Bureau of Statistics has provided Guidance for Certifying Deaths due to COVID-19.   This includes example medical certificates involving ‘chains of events’ and chronic conditions. 

Telehealth

  • Using Telehealth during the COVID-19 pandemic? Updated 16 Nov 2020

    Teleheallth has been widely used throughout the COVID-19 pandemic.
     
    Telehealth is appropriate to use where:
    • You have a reliable, secure telehealth system
    • You can provide the same level of care and advice you can in a face-to-face consultation
    • You have appropriate arrangements to see the patient face-to-face if necessary.  

    Telehealth can still be used if it does not qualify for a Medicare item where clinically appropriate to do so. 
    Your fees for this should be disclosed to the patient prior to consultation.
     
    For telehealth guidance see:
  • What platforms can I use for telehealth? Updated 16 Nov 2020

    A range of commonly used video platforms and landline / mobile telephone services can be suitable for telehealth.  
     
    Be aware free versions of telehealth platforms may not meet privacy and security requirements. 
     
    To assist in choosing suitable video conferencing platforms, the Australian Digital Health Agency provides:
  • What is the COVID-19 Medicare Telehealth framework? Updated 29 Sept 2020

    New temporary COVID-19 Medicare telehealth items for non-admitted patients are in place until 31 March 2021.
     
    The items extend to all Medicare eligible Australians, so long as the requirements for individual item numbers are met. 
     
    Both you and your patient must be in Australia to use Medicare telehealth items (as is the case for Medicare items generally). 
     
    You do not need to be within your regular practice to provide telehealth.  It can be provided from home.  You should use your provider number for your primary practice location. 

    Your Medicare provider number should only be used for telehealth consultations you undertake yourself.   It cannot be used by other practitioners you work with for their consultations. 
     
    For each service / consultation, the full requirements of a telehealth item must be met.  They cannot be used solely for triaging.  There are also restrictions around when you can initiative a service, and when they need to be patient initiated – see Q&A - "Can I initiate Medicare telehealth services with patients, or should they come to me first?"
     
    In determining whether telehealth is appropriate, Medicare requires the practitioner must:
    • Have the capacity to provide the full service through this means safely and in accordance with professional standards; and
    • Be satisfied that it is clinically appropriate to provide the service to the patient; and
    • Maintain a visual and audio link (or audio only for telephone) with the patient; and
    • Be satisfied that the software and hardware used to deliver the service meets the applicable laws for security and privacy – see Q&A What platforms can I use for telehealth? 
    • Only use telephone if video cannot be used.
     
    Online chat, messaging and email cannot be used for Medicare telehealth items.
     

    Before using the new items, you should familarise yourself with the requirements for telehealth use generally and each individual item.   This is very important.  This includes:​

    • ​Obtaining informed financial consent before providing telehealth where you are not bulk-billing (the AMA’s Informed Consent guide is here). 
    • Documentation – there are the same record-keeping requirements as for face-to-face consultations – this includes referrals where required
    • Assignment of benefit – for the new telehealth items only, documentation in clinical notes of a patient’s agreement to assign their benefit as full payment for the service is sufficient – other options include posting the completed assignment of benefit form to the patient for their signature and return, or email agreement between the practitioner and patient
    • Multiple attendances on the same day (co-claiming is precluded) – see Q&A below ‘What if I see a patient via telehealth and then need to see them face-to-face’.


    The Department of Health provides an email service for questions around COVID-19 MBS items –AskMBS@health.gov.au.  It has also provided advisories for GPs, physicians and other specialists covering both telehealth and broader MBS claiming questions.

    For GPs:

    • Bulk-billing requirements for COVID-19 telehealth are being lifted from 1 October 2020, but temporary doubling of bulk billing incentives will also end – see Q&A Are there any bulk billing requirements for COVID-19 telehealth items?
    • Need for an existing and continuous treating relationship for a wide range of patients - see Q&A – Can I only use COVID-19 telehealth items for existing patients?

     
    The Commonwealth Health Department has released the following Medicare telehealth guidance:

  • Can I only use COVID-19 telehealth items for existing patients? Updated 16 Nov 2020

    GPs and other doctors working in general practice can only claim COVID-19 telehealth items if they have an existing and continuous relationship with a patient.
     
    An existing and continuous relationship involves the patient having seen the same doctor or another medical or health practitioner (including a practice nurse) at the same practice face-to-face in the last 12 months. 
     
    There are a number of exceptions, which are:
    • Patients living under COVID-19 movement restrictions imposed by state or territory public health requirements, including local quarantine requirements
    • Children under 12 months of age
    • Homeless patients – this includes people who live in an inadequate dwelling, have no tenure or a short and non-extendable tenure, or live somewhere where they do not have control of, and access to, space for social relations
    • Patients receiving an urgent after-hours (unsociable hours) service
    • Doctors located at an Aboriginal Medical Service or Aboriginal Community Controlled Health Service
    • Doctors participating in the Approved Medical Deputising Service (AMDS) program if the AMDS provider has a formal agreement in place with a medical practice to provide services to its patients, and that practice has provided, or arranged, at least one personal attendance for the patient in the past 12 months.
     
    Details of GP COVID-19 telehealth claiming requirements are here
     
    Similar restrictions have not been imposed on specialists or other healthcare providers.
  • Can I initiate Medicare telehealth services with patients, or should they come to me first? New 10 Sept 2020

    Where clinically relevant, a practitioner can contact an existing patient for a telehealth consultation as part of appropriate, ongoing care.
     
    Medicare telehealth services cannot be initiated by the practitioner for new patients.  This can only be done by the patient seeking a consultation or on referral by another practitioner. 

     
  • What if I see a patient via telehealth and then need to see them face-to-face? Updated 10 Sept 2020

    For use of Medicare telehealth items, the Commonwealth Health Department has indicated:

    • You need to have the capacity to see the patient face-to-face if required, wherever possible, or otherwise scope to arrange prompt care as required, whether through colleagues at your practice / hospital or other frameworks you have put in place before providing telehealth services
    • If a subsequent attendance on the same day does constitute a continuation of an earlier attendance, the sessions together are considered a single attendance for benefit purposes.
    • If you cannot meet the requirements of a telehealth item without a subsequent face-to-face consultation, you cannot bill Medicare until you have provided a complete MBS service - this could be through billing either a telehealth item or a face-to-face item, whichever took the longer, so long as the individual item requirements are met – you cannot bill both items
    • If two components of a single service are provided by different practitioners, each should bill the appropriate item number fo rhte individual service they provided
    • The new telehealth items are stand-alone items – they cannot be co-claimed with existing face to-face or existing telehealth items - in addition, you cannot claim a telehealth item and a chronic desease management plan item on the same day
    • Multiple Medicare items could only be claimed on the same day by the same practitioner if subsequent attendances are not a continuation of initial or earlier attendances – if you bill multiple items you should state the time of each attendance on the account, and also include in the clinical records time of each service, how each item descriptor was met and explain why they are separate services.

    More information is available here (Provider FAQs). 

    For telehealth that is not Medicare billable, you should ensure that you have the necessary arrangements in place to provide continuity of care within appropriate timeframes for patients who you initially consult with via telehealth, but subsequently need to see face-to-face, where you cannot do this yourself. 
     
  • Are there any bulk billing requirements for COVID-19 telehealth items? Updated 16 Nov 2020

    Practitioners can choose whether to bulk bill or use their regular billing practices.   .
     
    COVID-19 telehealth services provided by GPs and other doctors in general practice are eligible for MBS incentive payments when provided as bulk billed services to Commonwealth concession card holders and children under 16 years of age. 
     
    Rural bulk billing incentives are only payable to practitioners in areas classified as regional, rural and remote under the Modified Monash Model (MMM) classification system (MMM 2 – 7 locations).  Practitioners in metropolitan (MMM 1) areas receive the standard bulk billing incentive payment.
     
    Further information on eligibility and claiming rules is available here (COIV-19 Bulk-billing incentives – FAQs).
     
    Where bulk billing is not being used, the Commonwealth Health Department advises providers should ensure “informed financial consent is obtained prior to the provision of the service”.  Informed financial consent includes details relating to fees, including any out-of-pocket expenses.  The AMA’s Informed Consent guide is here
     
    There can be no non-rebatable deposits charged which are then put towards later consultations.  Fees charged for this (and any MBS service) can only be for the service which is being claimed for.  It cannot include fees for another service.

    More information is available here.

     
  • Can I use telehealth for patients in aged care facilities? Updated 9 Sept 2020

    Yes, the Medicare telehealth items can be used for patients in aged care facilities, subject to individual item number requirements and whether it is clinically appropriate to use telehealth for the patient in question.

    The patient must be present when receiving the telehealth service.  The items cannot be used for consultations with family or care providers without the patient being present.

    Where a patient lacks capacity, their substitute decision-maker (guardian, power of attorney, close relative as relevant) can be involved, whether with the patient or linked in from another location via video or telephone.  MIGA’s resource on Substitute consent provides more information on who should be involved in these situations.  

     

Electronic prescribing

  • How can I use digital image prescribing? Updated 15 Oct 2020

    Interim image-based prescription arrangements

    An interim image-based prescription model has been introduced, which means:
    • You can create a paper prescription, signed in writing or via valid digital signature (a digital signature cannot be used in NSW, where a handwritten signature is required)
    • A clear digital copy of the entire prescription (photo or PDF) can be sent to the patient’s pharmacy via email, text message or fax (in NSW, the copies cannot be sent via text message)
    • You retain the original prescription for two years (in Victoria and Tasmania, you must make certain records of any digital image being transferred, and you are advised to make records of how you sent the prescription and the pharmacy you sent it to in Queensland).

    Image-based prescribing cannot be used for Schedule 4D or 8 medications, except in:
    • Victoria – where it can be used for all Schedule 4 medications except for drugs of dependence
    • Queensland – restricted drugs of dependency, anabolic steroids and Schedule 8 prescriptions can be sent electronically to a pharmacy so long as the paper prescription is sent to the pharmacy within 7 days and the paper copy is not given to the patient – the paper prescription should be marked as being confirmation of the earlier electronic request
    • WA - Schedule 8 prescriptions may be sent electronically via the same process to a pharmacy, and the original prescription dispatched to the pharmacy within five working days, marked to indicate that it is confirmation of an earlier digital request
    • ACT - Schedule 4D and 8 prescriptions can be sent electronically to a pharmacy. 

    These arrangements have been extended to 27 March 2021 in Victoria, and to 31 March 2021 in other states and territories.

    The Commonwealth Department of Health provides a guide for prescribers and an overview of state and territory rules.  Further information is also available for South Australia, NSW, Victoria, Queensland, WA, Tasmania and ACT.

    If the patient prefers to receive the original prescription themselves to take to the pharmacist to fill, instead of using the interim electronic prescribing arrangement, you can still post it to them for this purpose.
  • Where can electronic prescribing be used? Updated 8 Dec 2020

    Subject to local pharmacy readiness, electronic prescribing, including for Schedule 4D and 8 medications, is available in:

    • Sydney and across each of Victoria, South Australia and the ACT
    • Elsewhere in communities of interest across Australia.

     
    It is important that you ascertain whether local pharmacies are ready to dispense medication using electronic prescribing and that you let your patients know which pharmacies provide this service. 
     
    For more information on electronic prescribing, see Q&A What does electronic prescribing involve?
     
    Both digital imaging and paper prescribing may still be used, depending on pharmacy readiness and patient preference.  

  • What does electronic prescribing involve? Updated 15 Oct 2020

    Token model – available now
     
    The first phase involves the Token model – a unique QR barcode (token) is sent via app, SMS or email to a patient. 
     
    Patients can send the token / take it in to a pharmacy of their choice for dispensing.
     
    One token is used for each medication.  Once scanned at a pharmacy, it cannot be reused.  Pharmacies sent a new token to the patient for each repeat. 
     
    If your patient requests, you can send the token to someone else caring for them, such as a family member.  It can only be sent to one mobile number or email address by you. 
     
    You should confirm token receipt before the end of the consultation.  If it was not received / sent to the wrong location, cancel the prescription and generate a new token. 

    Active Script List model – under development

    The second phase involves the Active Script List (ASL) model.  
     
    An ASL contains a patient’s active prescriptions which can be dispensed by a pharmacy. 
     
    Patients need to register for an ASL and must provide consent for you to access and view their ASL. 
     
    This model will eliminate the need for a token, and is meant to be particularly helpful for patients on multiple medications.  
     
    Getting ready for electronic prescribing

    To use electronic prescribing:

    • You need a Healthcare Provider Identifier-Organisation and be connected to the Healthcare Identifier service (more information on how to do this is here)
    • Your electronic records system will need to have the necessary capability to connect to a Prescription Delivery Service.  You can liaise with your system provider to confirm this
    • Confirm with your system provider that your system complies with local state / territory electronic prescribing requirements
    • You or your staff should also ensure you have up to date mobile phone and email details for your patient. 

     
    You cannot provide both an electronic prescription and a paper or digital image prescription to a patient.  Only one method of prescribing can be used for each prescription. 
     
    Electronic prescribing use is not mandatory.  You can continue to use paper or digital image prescriptions instead of these new methods.  However both you and your patients may find it easier and quicker to use than existing prescribing methods, particularly when utilising telehealth and for patients who are familiar with using devices.  It also reduces the risk of lost prescriptions. 
     
    More information on the Token and ASL models, including timing for roll-out, is available here
     
    The Commonwealth Health Department has prepared policies on both privacy, and security and access, obligations for healthcare providers using electronic prescribing.
     
    The Australian Digital Health Agency provides a free online electronic prescription course, focusing on the Token model. 
     
    The RACGP has also released electronic prescribing resources.

Registration and training issues

  • What if I am working outside my usual scope of practice? Updated 16 Nov 2020

    We are conscious that a range of our members are undertaking a broader range of work in helping to respond to the challenges of COVID-19. 
     
    The Medical Board indicates:

    • Individual doctors, as well as organisations who engage them, will need to make decisions about scope of practice
    • Decisions should prioritise patient safety and take into account your qualifications, training, experience and transferability of their skills to deliver safe care
    • Consider the conditions in which you will be working, including facilities and access to supervision and training
    • The Board does not prescribe what individual doctors can and cannot do – these are decisions for you and your hospital, practice or other workplace, prioritising patient safety.

     
    We recognise practitioners are often equipped to work across a number of specialties or fields of practice. 

    You should:

    • Make sure your Ahpra registration does not restrict or preclude new or broader work
      • The Medical Board has confirmed that doctors with general and specialist registration are not restricted in their scope of practice because they have specialist registration
      • If your registration does restrict you (e.g. you are limited to certain fields of practice)you would have to apply to Ahpra for changes to your registration before commencing work
    • Consider whether you have the necessary skills, training and experience to provide the level of care expected in the new context
    • Contact MIGA to ensure you have the right insurance category for your new work
    • Ensure you do not incorrectly represent your qualifications, training and experience – the Medical Board has confirmed working in a different scope of practice does not permit you to use a title for which you do not have specialist registration  See Ahpra and the National Boards guidance on Titles in health advertising – Getting it right.   


    If you have concerns about being able to work in a new area, you should raise them with senior colleagues, your hospital or health service.

  • I have returned to practice as part of Ahpra's pandemic sub-register. Are there limitations on what I can and cannot do? Updated 19 Feb 2021

    The pandemic sub-register for doctors, nurses and midwives closes on 5 April 2021.

    Practitioners wishing to continue to practice after this time must apply for ongoing registration by lodging a transition pathway application form.

    You cannot now return to practice under the sub-register.  Practitioners wanting to return to practice must now follow usual return to practice pathways, which include recency of practice requirements.

    Ahpra has provided information for practitioners on the sub-register.

    Whilst on the sub-register, and similarly to your practising peers, you are required to follow your profession’s code of practice (doctors or midwifery) and work within your scope of practice. 
     
    Although the Medical Board has indicated does not define scope of practice for those with unconditional general registration, it expects doctors will exercise their professional judgement and work within their level of competence to ensure they have the necessary knowledge and skills to provide appropriate and safe care.
     
    Midwifery scope of practice is defined in the Nursing and Midwifery Board’s Midwife Standards for Practice.

     
    Outside other conditions you may have on your practice, you are not restricted by the pandemic sub-register in the location or context of your work. 
     
     
  • I have only returned to work in the public sector. Do I need cover from MIGA? New 3 Apr 2020

    Doctors employed in the public hospital system will usually have cover for civil damages claims from their employer, but this does not normally include cover for legal expense or assistance with responding to other issues, such as professional disciplinary matters (i.e. a Medical Board / Ahpra notification) or workplace disputes.  Assistance available in relation to coronial investigations and inquests may also be limited.
     
    Before starting work, you should confirm the nature and extent of your insurance cover or indemnity with your hospital or health service.  We recommend you consider insurance cover from MIGA for matters for which you are not covered.

  • If I return to private practice will I lose eligibility for Commonwealth Government run-off cover scheme? Updated 19 Feb 2021

    A special exemption has been agreed to allow doctors and midwives to return to private practice and not lose their eligibility for the Commonwealth’s run-off cover scheme (ROCS).  

    This is a temporary exemption for the COVID-19 pandemic, which presently has been declared to run until 17 March 2021, and may be extended further.  It ceases one month after the pandemic ends.  If you continue in private practice after that time, the special ROCS exemption will no longer apply and you will need to obtain run-off cover for past practice at your own expense. 

    Practitioners returning to public practice only do not lose ROCS eligibility.

COVID-19 Premium Relief with MIGA

  • My Gross Income has dropped and is lower than I estimated due to COVID-19, what does this mean for my premium for the 2020/21 financial year? Updated 17 Jul 2020

    MIGA’s policies include an option to adjust the premium if your actual Gross Income (or Sessions) is higher or lower than what you expected.

    If your Gross Income has reduced but it’s not significantly lower than anticipated, we suggest that you leave your estimated Income as is for the year and adjust it after the end of the year.

    Alternatively, if your Gross Income is significantly lower than anticipated contact us and we can review your annual premium now.  In this situation a different Income/Sessions Band may apply and you may be entitled to a premium adjustment.

    Please see the Question below 'What is MIGA doing to support Members and Clients who are suffering financial hardship arising from COVID-19?'

    Please call our staff to discuss the above or e-mail us at COVIDrelief@miga.com.au.  Our staff will guide you through your options.


    * The definition of Gross Income can be found in MIGA’s Categories Guide.
  • What is MIGA doing to support Members and Clients who are suffering financial hardship arising from COVID-19? Updated 17 Jul 2020

    MIGA is committed to supporting our Members and Clients who suffer financial hardship as a result of the impact of COVID-19.

    We understand the challenges faced by many as we deal with the unprecedented change that COVID-19 has brought.

    With concerns over the financial impact of the current crisis, MIGA’s Boards have agreed a COVID-19 Premium Relief arrangement to support our Members and Clients during these extraordinary times.

    It involves a number of mechanisms to respond to the changing financial circumstances of eligible members and clients whilst maintaining our financial strength. Eligible clients may include doctors in private practice, Healthcare clients and Midwives.

    Under our COVID-19 Premium Relief arrangement, you may have access to:
    • Eligibility for a premium reduction, if your practice and/or the level of activity of your practice has materially changed
    • If you are suffering significant financial hardship
      • If you meet our Eligibility Criteria you may be able to access additional financial relief from MIGA in terms of your annual premium or direct debit 
      • The Eligibility Criteria are if you have ceased working, if your practice has closed and/or if your income has or will reduce by 50% or more over what it would normally be.

    Please call our staff to discuss if you are eligible and your specific situation or e-mail us at COVIDrelief@miga.com.au.  Our staff will guide you through your options.

    Rest assured, supporting you is a key priority for us as we understand how important this is particularly for those who are significantly impacted.

    As a member owned mutual helping our Members and Clients through difficult times is very important to us and always front of mind.

    * The definition of Gross Income can be found in MIGA's Categories Guide.
  • I have ceased practice and am not currently working, do I still have to have insurance? Doctors and Midwives Updated 22 Apr 2020

    Yes, under your registration requirements as a doctor or a midwife, you must maintain run-off cover for matters that would otherwise be uncovered arising from your previous practice.

    If you cease practice, your Policy with MIGA can be amended to run-off cover only, to cover you for claims that may still be made against you that arise from your prior practice.

    If you change your policy to run-off, you will need to notify us prior to returning to practice to arrange ongoing insurance cover.

Insurance policies are issued by Medical Insurance Australia Pty Ltd.  MIGA has not taken into account your personal objectives or situation.  Before you make any decisions about our policies, please review the relevant Product Disclosure Statement (which can be found here) and consider your own needs.