Assignment of benefit is changing on 1 July: what your practice needs to know

If your practice bulk bills, the way you collect and store patient consent is about to change. From 1 July, there are new requirements for how an “assignment of benefit” is obtained, and, importantly, how long you need to keep evidence of it.

There’s been a lot of noise about this one, and we’ve had plenty of questions from practices who aren’t quite sure what they need to do. We’ll cover what assignment of benefit actually is, why it’s changing, how it’s changing, and the concrete steps to take before and after 1 July.

I’d like to present some reassurance up front: We’ve been working closely with our practice management system partners, and all of them either already have the tools you need, or have updates releasing shortly to make assignment of benefit easy to collect and store. Additionally, the only change you must have in place on day one is the record-keeping. Everything else can be phased in at a pace that suits your practice. More on that below.

What is an assignment of benefit?

As a practitioner, when you fully bulk bill a patient for an invoice, you’re not waiving a fee. You’re accepting the Medicare benefit as full payment, and the patient agrees to “assign” their Medicare benefit to you so you can claim it directly. The patient pays $0 out of pocket, and you bill Medicare for the invoice.

That agreement, the patient handing their benefit over to you, is the assignment of benefit. It’s a long-standing requirement under the Health Insurance Act 1973, so it isn’t new. What’s changing is how you can capture it, and who’s responsible for holding onto the proof.

Up until now, assignment was collected on a specific approved form (the DB4e or DB020), signed by the patient after the consult. In some settings, like telehealth, verbal consent was accepted. And the onus sat with the patient to keep the evidence that they’d assigned their benefit, which, in reality, often meant nobody kept it at all.

Why is assignment of benefit changing?

The short version: this is the long-promised modernisation of bulk billing consent, and it has a bit of a backstory.

During the COVID-19 pandemic, The Department issued temporary guidance allowing doctors to collect verbal consent to assign the benefit for MBS telehealth items, recorded in the patient’s notes during the consult. In January 2023, the Australian National Audit Office made note of this in its report on Medicare telehealth services, finding there was no clear legal basis for it and that it created a fraud risk. Without the patient acknowledging the consult took place, in theory, benefits for services that didn’t take place could be claimed.

In September 2023 The Department tightened things up. Verbal consent for telehealth stayed available, but it now had to be followed up with a completed approved form sent to the patient. Understandably, many GPs and practices pushed back against the added paperwork, in response, the health minister promised a modernised, digital-friendly process.

The 1 July changes are the result, and they bring the verbal-consent era to a close for bulk billing across the board. Through its submission to the DoHDA, the RACGP has advocated to make a digital signature just as legally valid as a pen-and-paper one, which is genuinely useful.

The intent is good: a consent process that produces a verifiable record, which works with modern digital workflows practices expect.

The catch, and the reason there’s been so much chatter, is that a number of practical scenarios (particularly around vulnerable patients) seem to conflict with the new methods and requirements. We’ll come back to that.

How is it changing?

Here are the core changes coming on 1 July.

The record-keeping onus shifts to practices and clinicians. This is the big one. Your practice, not the patient, now needs to retain evidence that the patient assigned their Medicare benefit, and you need to keep that record for two years.

Verbal consent is gone. Verbal assignment of benefit will no longer be accepted in any setting. You’ll need a signature, physical or electronic, from the patient or an appropriate person acting on their behalf.

The approved forms are retiring. The DB4e and DB020 will no longer meet the requirements. The “approved form” is being replaced by a required data set, a defined set of information that has to be presented to, and agreed by, the person assigning the benefit.

There’s no mandatory template. As long as the agreement contains all the required information and the assignor has agreed, it’s valid, whether it’s on paper or electronic, and whatever the format. Services Australia has said it will publish optional example templates, but you don’t have to use them.

Consent can be collected before or after the consult. You can now obtain assignment either before the service (pre-service assignment) or after it (post-service assignment), as long as agreement is in place before invoices are batched to Medicare.

Consent is per episode of care. Each assignment covers a single episode of care, so patients will need to consent each time you bulk bill them. An “enduring” assignment (a standing consent) has been flagged as a future development, but there’s no confirmed start date yet, and it’s being talked about as a 2027 change rather than something to count on now.

Pre-service assignment and rejections have a re-consent trap. If you collect consent before the consult, you’ll need to estimate the broad service group of the item you expect to bill. If the service changes during the consult, say a standard consultation turns into a care plan, the original assignment no longer matches what you delivered, and you’ll need a fresh assignment that reflects the actual service. The same goes if a claim is rejected and you need to change the MBS item number, that needs a new assignment too.

The workflows that remain unresolved: vulnerable patients

We want to be upfront about this, because it’s the question we hear most, and it doesn’t have a clean answer yet.

Because a signature is now required, the obvious question is: what happens when a patient can’t sign? The guidance allows an “assignor”, a parent, partner, carer, relative, person with power of attorney, or friend, to sign on the patient’s behalf. But without a signature from the patient or an assignor, the agreement isn’t complete, and a bulk-billed claim shouldn’t be made.

This has the potential to create real problems in aged care, palliative care, disability care, and for patients who are acutely unwell. If you’re visiting an aged care facility, the patient can’t sign, and there’s no authorised assignor present, there’s currently no clear, compliant way to bulk bill that service. There’s also no provision in the legislation for what to do when a patient simply never responds to a request for consent.

These gaps are being actively raised with The Department. For now, the practical step is to work out where in your patient population this is likely to bite, and keep an eye out for further guidance.

How does assignment of benefit interact with the recent introduction of the bulk billing practice incentive?

I was recently at the RACGP Practice Owners and Business for Doctors conferences, and this is a hypothetical that came up a few times with various practice owners and managers. Let’s pause for the world’s quickest recap of the incentive. The Bulk Billing Practice Incentive Payment (BBPIP) was introduced in November of 2025, and effectively provides a 12.5% total additional payment split between practices and practitioners who fully bulk bill all GP non-referred attendance items. It’s designed to incentives bulk billing and expand accessibility of care while making bulk billing more financially viable.

The reason practices are worried about assignment of benefits here is that if they are fully bulk billing to qualify for the incentive, this means they will need to acquire and store the assignment of benefit for every single appointment.

So what happens when patients inevitably forget to complete the assignment, ignore the follow up text, or simply decline to assign the benefit? A fully bulk billing practice is faced with either privately billing the patient, forfeiting the 12.5% BBPIP for all service, or accept that they won’t be able to correctly invoice Medicare, receiving a rejection and $0 for the appointment.

What you need in place before 1 July

Let’s start with the most important point, because it cuts through a lot of the worry: the only change you must action on day one is the record-keeping requirement. You don’t have to roll out pre-service assignment or a fully digital workflow on 1 July if it doesn’t suit you. You can phase those in. What you can’t skip is keeping evidence, for two years, that you obtained assignment of benefit for each bulk-billed service.

With that in mind, we’ve put together a practical checklist your practice can work through to get ready, and we’ve made it a free download so you can share it with your team and tick things off as you go.

It walks you through the key actions step by step: getting your systems and record-keeping ready, deciding on the workflow that suits your practice, building assignment checks into your billing and reconciliation, clearing outstanding billing items before 1 July, reviewing your digital consent and communication tools, planning for patients who don’t respond, handling patients who need alternative consent arrangements, and bringing your team and patients along with you.