Recent Changes to the After-Hours Medical Deputising Service (AMDS) 3GA Program

The Department of Health have recently made a few changes to the AMDS program guidelines, so our team have put together the following information for doctors wanting to know more.

 

Please note, this is just a quick overview of the AMDS Program, if you have specific questions or you need help, please let us know.

 

Quick Facts

 

  • AMDS provides after hours care to patients on behalf of their regular in-hours GP.
  • An AMDS is a General Practice service that has been accredited specifically as an AMDS- not just a General Practice that operates in the afterhours. AMDS practices can’t operate in the same building as another service where they can share the facilities such as treatment rooms or reception.
  • The AMDS program provides access to Medicare for General Practitioners seeking to get General Practice experience within the after-hours period. These doctors must be NON-VR and subject to 19AA.
  • The RACGP may consider after hours to be only “partially comparable” and assess the experience at 50% of the time worked, capped at 2.5 years.
  • The AMDS Program is a maximum of 6 years.
  • Doctors under the AMDS program are restricted in the MBS items that they can access. One of the important ones is surrounding prescribing. A full list is detailed below.

 


 

Jump to information on:

 

Quick Facts

What is the Purpose of AMDS?

When is the Commonwealth’s defined ‘after-hours’ period?

Can I work in-clinic on AMDS?

I’m restricted by 19aa, If I work in a non-AMDS approved clinic, will I still be able to meet this requirement?

REVISED ELIGIBILITY – THE DOCTOR

REVISED ELIGIBILITY – THE PRACTICE

How Long Can I Stay on AMDS?

Is After-Hours Experience Assessed Differently to In-Hours Experience?

Will there be restrictions to my practice while on AMDS – specifically around medicare billing?

CLINICAL MATTERS THAT ARE OUTSIDE OF THE SCOPE OF DEPUTISED CARE

HEALTH PROMOTION ACTIVITY THAT REQUIRES ONGOING CARE

MANAGEMENT OF CHRONIC DISEASE

PROCEDURES THAT REQUIRE RESUSCITATION FACILITIES

PROCEDURES THAT MAY NEED A CHAPERONE, GOOD ILLUMINATION OR SPECIFIC EQUIPMENT

CERTIFICATION

FAQs – Relationship Between AMDS Providers and General Practices

CLAUSE 8.3 OF THE REVISED GUIDELINES PROVIDES THAT IT HAS BEEN ENGAGED BY A PRACTICE PRINCIPAL BEFORE IT DEPUTISES TO PATIENTS OF THE PRACTICE. WHAT DOES THIS CLAUSE MEAN?

ARE AMDS PROVIDERS RESTRICTED FROM DEPUTISING ON BEHALF OF GENERAL PRACTICES THAT ARE NOT ACCREDITED ACCORDING TO THE RACGP STANDARDS?

CAN AN AMDS PROVIDER DEPUTISE ON BEHALF OF AN AFTER-HOURS CLINIC?

CAN A GENERAL PRACTICE ENTER INTO AGREEMENTS WITH MORE THAN ONE AMDS PROVIDER?

How We Can Help You

 


 

What is the Purpose of AMDS?

The purpose of the AMDS Program is to offer non-VR GPs the opportunity to gain general practice experience in after-hours settings and access a Medicare Provider number.

 

When is the Commonwealth’s defined ‘after-hours’ period?

Commonwealth’s defined after-hours period is

  • from 6pm to 8am on Weekdays (Monday – Friday),
  • from 12pm on Saturday, and
  • all day on Sunday
  • all Public holidays are also part of this period

 

Can I work in-clinic on AMDS?

Yes, the AMDS program covers both accredited clinics and home visit services during the Commonwealth defined after-hours period.

 

I’m restricted by 19aa, If I work in a non-AMDS approved clinic, will I still be able to meet this requirement?

No. While there are many clinics who offer ‘after-hours’ appointments, the clinic is required to be accredited as an AMDS, and both you and the location must be approved by the Department of Health. An outline of the revised eligibility criteria for joining this program has been provided below.

 

REVISED ELIGIBILITY – THE DOCTOR

A non-VR recognised GP must be able to meet the eligibility criteria before approaching an AMDS and applying to join the Program:

  • Be restricted by 19AA of the HIA (PR or Citizen of Australia) and must not be a VR GP
  • Hold current General Registration with AHPRA (for AMDS home visiting services) OR
  • Hold minimum Limited Registration (for clinic based AMDS)
  • Have successfully completed the Level 1 Advanced Life Support Course (ALS) as approved by the RACGP and/or ACRRM;
  • Be a current member of either RACGP or ACRRM;
  • Completed a minimum of 2 years post-graduate experience that includes rotations in paediatrics, accident and emergency medicine, surgery and general practice; and
  • Be able to provide a current (less than 6-month-old) General Practice Experience Assessment Report from RACGP or ACRRM and be working towards either the FRACGP or FACRRM.

 

REVISED ELIGIBILITY – THE PRACTICE

For a clinic to be eligible for the AMDS Program, it must be able to meet the following criteria:

  • Hold current full accreditation as an MDS from an Australian Government nominated accreditation body (AGPAL or GPA);
  • Have operated as an MDS for a minimum of 12 months prior to applying to join the AMDS Program;
  • Be clinically governed by a minimum of one Medical Director;
  • Have a physical location, with a ‘communications control centre’. (This means Practices operating from a virtual office are not eligible for the AMDS Program);
  • Be a stand-alone service that is not co-located in the same building or address as a general practice or another MDS where surgery, treatment rooms and/or receptionist facilities (including office equipment) is shared between the prospective AMDS Program provider and the other service;
  • Operate exclusively during the Commonwealth defined after-hours period;
  • Be fully operational, including the Communications control centre, during the entirety of the Commonwealth defined after-hours period; and
  • Be able to demonstrate that it has a clinical triage protocol that satisfies each of the minimum capabilities identified in Appendix B of these Guidelines.

 

How Long Can I Stay on AMDS?

Non-VR recognised GP’s can access the AMDS Program for a maximum of up to 6 years. During the application process, potential applicants must be able to demonstrate that they are actively working towards their FRACGP or FACRRM by providing evidence that they are continuing professional development either through the RACGP CPD program or ACRRM PDP Program they must also demonstrate they will become a VR GP by attaining their qualification within this time frame.

 

Is After-Hours Experience Assessed Differently to In-Hours Experience?

In our experience, After-hours AMDS roles are assessed at a maximum of 50%. For example, if you worked for the full 5 years on this program, you would have accrued a total of 2.5 years GP experience to be assessed by RACGP or ACRRM. After Hours experience will make up a total of 2.5 years of your experience and RACGP require 18 months to be during the in-hours period or “fully comparable”.

 

Will there be restrictions to my practice while on AMDS – specifically around Medicare billing?

A doctor approved for the AMDS Program does not technically meet the definition of a “GP” provided in clause 1.1.1.A of the Health Insurance (General Medical Services Table) Regulations 2017 (GMST Regulation). For this reason, AMDS doctors are subject to restrictions on the MBS items they may claim for after-hours deputising services they may provide while participating on the AMDS Program. The next paragraph will clarify.

 

CLINICAL MATTERS THAT ARE OUTSIDE OF THE SCOPE OF DEPUTISED CARE.

The AMDS program is in place to provide GP services to patients outside of the normal hours of operation. It is not intended to take the place of regular GP services- the guidelines speak specifically about After-Hours GP taking instruction from the patients regular in-hours GP and referring the patients back to their regular in-hours GP.

Therefore, it is not appropriate that deputising doctors who are employed by an AMDS, provide care to patients who present with symptoms or circumstances that can be addressed by their normal GP.

Here are some examples of the types of consultation requests that are deemed to be the sole responsibility of a patient’s normal GP. These requests are deemed to fall outside of the deputising activity that may be performed by a non-VR doctor who has received access to the MBS during the after-hours period under the conditions of the AMDS Program.

 

HEALTH PROMOTION ACTIVITY THAT REQUIRES ONGOING CARE:

For example: after hours doctors are encouraged to provide brief interventions regarding smoking, alcohol or recreational drug use but would refer to the usual GP for medication and management of smoking cessation or opiate withdrawal.

 

MANAGEMENT OF CHRONIC DISEASE:

Examples that would be considered inappropriate include:

  • blood pressure or blood glucose monitoring
  • discussion of test results
  • repeat prescriptions
  • medication reviews
  • GP management plans
  • chronic disease management plans
  • mental health care plans
  • specialist referrals
  • routine referrals to other health professionals, or pathology and imaging tests

 

PROCEDURES THAT REQUIRE RESUSCITATION FACILITIES:

Examples that would be considered inappropriate include:

  • Immunisations
  • Surgical procedures such as joint injections, skin cancer surgery

 

PROCEDURES THAT MAY NEED A CHAPERONE, GOOD ILLUMINATION OR SPECIFIC EQUIPMENT:

Examples that are considered inappropriate include

  • Examinations such as urological or gynaecological unless specific to the presenting illness
  • Cervical screening tests
  • Ear syringing Hearing tests
  • Skin checks
  • Routine uncomplicated dressing changes for patients who can present to their regular GP or community nurse

 

CERTIFICATION:

Examples that are considered inappropriate include:

  • Medical reports including but not restricted to pre-employment, insurance, and Centrelink
  • Driving licence medicals
  • Taxi subsidy forms

 

AMDS doctors are not completely prohibited from prescribing medicines to a patient who has not been referred for a deputised attendance by their normal GP. Under the revised Guidelines, AMDS participants will remain eligible to prescribe medicines to unreferred patients if they identify a genuine clinical need to issue a prescription.

 

AMDS participants are prohibited from issuing multiple repeats for medications prescribed. A single prescription can be issued for up to a month’s supply. To obtain further repeats patients will need to see their usual GP or practice. This change seeks to encourage continuity in prescribing in recognition of the increase in multimorbidity and polypharmacy.

 

These Guidelines consider that a patient ‘running out of a prescribed medicine’ is a recognised challenge in general practice and offer scope for an AMDS Program participant to prescribe as a means of preventing significant harm to a patient who has not been referred by their normal GP. These Guidelines do limit the ability of these doctors to prescribe multiple repeat medicines as a routine practice and confirm that participants should not be issuing repeat prescriptions as a matter of patient convenience and must identify a genuine clinical need.

 

FAQs – Relationship Between AMDS Providers and General Practices:

 

CLAUSE 8.3 OF THE REVISED GUIDELINES PROVIDES THAT IT HAS BEEN ENGAGED BY A PRACTICE PRINCIPAL BEFORE IT DEPUTISES TO PATIENTS OF THE PRACTICE. WHAT DOES THIS CLAUSE MEAN?

  • Clause 8.3 of the revised AMDS Program Guidelines requires AMDS providers to have entered into an agreement with a general practice before deputising on behalf of that practice. However, the revised Guidelines also provide a set of minimum triaging competencies that will apply to situations where a prospective patient makes a direct approach to an AMDS. An AMDS can provide a consultation to a patient who has not been referred by their normal caregiver if there is a genuine clinical need. The triaging guidance in the revised AMDS Guidelines provides advice on the management of un-referred patients.

 

ARE AMDS PROVIDERS RESTRICTED FROM DEPUTISING ON BEHALF OF GENERAL PRACTICES THAT ARE NOT ACCREDITED ACCORDING TO THE RACGP STANDARDS?

  • No. The AMDS Guidelines do not restrict AMDS providers from deputising to patients of unaccredited general practices.

 

CAN AN AMDS PROVIDER DEPUTISE ON BEHALF OF AN AFTER-HOURS CLINIC?

  • No. An AMDS provider may only offer deputised care on behalf of a practice that operates on a full-time basis.

 

CAN A GENERAL PRACTICE ENTER INTO AGREEMENTS WITH MORE THAN ONE AMDS PROVIDER?

  • Yes.

 

How We Can Help You:

If you are looking for further guidance on the AMDS Program or would like to ask further questions about 3GA programs options, this is something our team can help you with. Contact us directly on admin@peoplemedical.com.au.

 

Information for this blog has been taken directly from:

 

People Medical Consulting are a team of professionals with a passion for guiding those specialising in the Medical industry to find their career pathway and settle into Australia. Working with both Australian trained and Overseas trained professionals, we have extensive experience in Recruitment of General Practitioners, Migration for all with a special emphasis on Medical and Document Assistance for those requiring support with RACGP, AHPRA, 19AA and 19AB Medicare Exemptions.