Update 14 October 2025 – Minister Butler's Response to ACNP's Telehealth Advocacy
The ACNP has received a formal response from the Hon. Mark Butler, Minister for Health, Ageing and Disability, following our member survey, letter and Policy Impact Analysis outlining the urgent need to review the 12-month relationship MBS eligibility rule for Nurse Practitioner telehealth consultations.
In his reply, Minister Butler confirmed that the Government would not delay implementation of the telehealth rule to enable a Commonwealth Policy Impact Analysis to be conducted.
While this outcome is disappointing, the ACNP will continue to advocate strongly for equitable access to telehealth for all Australians, particularly those in rural, remote, aged care, and veterans’ settings, and for the removal of barriers that limit Nurse Practitioners’ ability to deliver timely, safe, and effective care.
Established Clinical Relationship – Telehealth Information For Nurse Practitioners
Quick Reference Guide for Nurse Practitioner Established Clinical Relationship criteria from 1 November 2025
PDF Version - MBS TELEHEALTH Quick reference guide Nurse Practitioners
Requirements:
From 1 November 2025, the established clinical relationship criteria will be introduced to MBS NP telehealth items.
This will mean patients wanting to claim an MBS rebate will need to have had one face-to-face consultation with their NP, or another practitioner at the same practice, within 12 months preceding the telehealth service.
A range of NP telehealth services will be exempt from the ‘established clinical relationship’ requirement (and will be available to any patient nationally).
This includes:
• Children under the age of 12 months.
• People who are homeless.
• Patients of NPs at an Aboriginal Medical Service or an Aboriginal Community Controlled Health Service.
• People isolating because of a COVID-related State or Territory public health order, or in COVID-19 quarantine because of a State or Territory public health order.
• People affected by natural disaster, defined as living in a local government area declared a natural disaster by a State or Territory government.
• Patients for Blood Borne Virus and Sexual or Reproductive Health (BBVSRH) consultations (excluding assisted reproductive technology or antenatal care).
When an exemption is used to establish a patient’s eligibility for Medicare benefits, this must be documented in clinical notes. This should include which exemption has been used and the justification.
Telehealth Update Monday 15 September 2025
We submitted our Policy Impact Analysis (PIA) to the Honourable Mark Butler MP, Minister for Health, Disability and Aged Care on 28 August and to other key stakeholders on 12 September.
This analysis highlights the serious risks to patient access to care that will result from the proposed 12-month face-to-face requirement for Nurse Practitioner (NP)-delivered telehealth services, due to commence on 1 November 2025.
The ACNP has commenced a national media campaign calling for a Commonwealth-led PIA to ensure patients are not left without essential care. We are committed to working with the Government to support evidence-informed decisions that safeguard patient access to NP-led services across Australia.
As part of this campaign, we are calling for a delay to the rollout of the 12-month face-to-face telehealth requirement, to allow time for thorough analysis and consultation to ensure the policy does not negatively impact access to care. #DelayTheRule
The Hidden Cost of Policy Change - Patient Impact of the 12-Month Face-to-Face Telehealth Rule
Telehealth Update Saturday 13 September 2025
We did not receive a response to our Policy Impact Analysis from the Hon Mark Butler, which was sent on 28 August 2025, when we requested a delay to implementation of the upcoming changes to telehealth. We will continue our advocacy for patients, particularly those who are living in regional and remote areas, those who are aged and/or receiving palliative care, veterans and those persons living with a mental health condition.
This week: We've started a grassroots digital campaign intended to involve health consumers and clinicians writing letters of concern to the Hon Mark Butler and local MPs.
Next steps: We will soon publish our Policy Impact Analysis: The Hidden Cost of Policy Change - Patient Impact of the 12-Month Face-to-Face Rule. We continue our advocacy to protect safe, affordable telehealth access for all Australians.
Telehealth Update Monday 8 September 2025
Following feedback from our ACNP Member Telehealth Survey, we are urging the Hon. Mark Butler, Minister for Health, Disability and Ageing, to implement a 6-month delay to the upcoming 12-month face-to-face rule. This delay would allow time for open consultation and for the Commonwealth to request an independent Policy Impact Analysis on the rule’s potential harm to patient care, particularly in regional rural and remote communities.
Last week: We submitted our ACNP Policy Impact Analysis and Recommendations to Minister Butler
Next steps: Continued strong advocacy to protect safe, affordable telehealth access for all Australians.
Advocacy in Progress
The ACNP extends heartfelt thanks to all member collaborators who generously volunteer their time, knowledge, and expertise in supporting our submissions. Your frontline clinical insights and contributions play an invaluable role in strengthening our shared advocacy efforts.
View and access previous submissions made by the ACNP through the member portal.
CLICK HERE FOR THE MEMBERS ONLY SUBMISSIONS PAGE
View Frequently Asked Questions from our Membership.
CLICK HERE FOR THE MEMBERS ONLY MBS / PBS FAQ's
CLICK HERE FOR FAQ's RELATING TO WORKING AS AN NP
Submissions, Letters, and Engagement in Progress and/or Completed: January/February/March 2026
Submissions
- Nurse Practitioner – Professional Practice Standards for Perioperative Nurses
- Getting it Right – A New definition for NDIS Providers
- Designated RN Prescribing - Stakeholder Feedback
- MBS Policy – Modernising Referral Pathways
- Senate Inquiry into Rural, Regional and Remote Medicare Access and Funding
- Joint letter – Senate Standing Committees – Rural, regional and remote Medicare access and funding
- Access to Superannuation for Victims of Child Sexual Abuse – Draft Legislation
- My Health Records (Information Commissioner Enforcement Powers) Guidelines 2026
- Federal Pre-Budget Submission 2026-27
- The Health Revolution – Tasmania's 20-year plan
- ACSQHC Clinical Care Standard on Osteoporosis
- Proposed amendments relating to transparency of disruptions to supply of a medical device
- QLD Health practitioner disciplinary jurisdiction
- Proposed Amendments to the Poisons Standard – Consultation
- Application for S100 NP prescribing approval with PBAC – Letter of support
- Nurse Practitioner Proposed Workers Compensation ACT Legislative Reform consultation
- RANZCR Draft Image Access Strategy – Consultation
- Post Implementation Review of Medicare Funded Cardiac Imaging Items
- Health Legislation Amendment (Prescribing of Pharmaceutical Benefits) Bill 2025
- NSW Voluntary Assisted Dying Legislative Review
- Inquiry into the Transition of the Commonwealth Home Support Program to the Support at Home Program
- Inquiry into the value of skilled migration to Australia
Representations
- South Australian Government – Safe Care for Persons Without Capacity – Legislative Framework Review on Restrictive Practices
- National Multidisciplinary Primary Care Research, Policy and Advocacy Consortium - PEAKS Group – Chair Bec Sedgman
- Australian Lawyer Alliance (ALA) – Meeting
- Assignment of Medicare benefits for simplified billing services info session
- SUPPORT – Meds Health Professional Advisory Group
- Early Pregnancy Loss Coalition (EPLC) – Member meeting
- Medicine Shortages Stakeholder Forum (MSSF)
- ACN Policy Summit
- Virtual Care and Telehealth Expert Advisory Group Meeting
- Better and Faster Access Expert Advisory Group
- The Council of Therapeutic Advisory Groups (CATAG) Off-Label Prescribing EAG
- Partnering for prevention – strengthening the Australian chronic disease prevention system – Workshop
- CATAG Off-Label Prescribing EAG
- ACSQHC Point of Care Testing (PoCT) Focus Group
Removal of the Collaborative Arrangements
Updated - 01/11/2024
From 1 November 2024, there will no longer be a requirement for a Collaborative Arrangement for patients to access Medicare and PBS entitlements. This outcome reflects 18 months of dedicated work by the Department of Health and Aged Care, alongside ACNP’s sustained advocacy.
Key Information on the Collaborative Arrangements Change:
- What Were Collaborative Arrangements?
Collaborative Arrangements allowed patients to access MBS rebates and PBS subsidies for services by Nurse Practitioners. Removing this requirement will reduce administrative burdens for many NPs and improve patient access to affordable healthcare. - What Does (and Doesn’t) Change?
Importantly, there are no changes to Nurse Practitioner clinical practice, prescribing rights, or collaborative patient care. This change focuses on access to MBS rebates and PBS subsidies, helping patients reduce out-of-pocket costs while ensuring NPs continue providing autonomous, collaborative care. The Collaborative Arrangements were often misinterpreted as a requirement for medical supervision of NPs. As this was never actually a requirement, there is still no requirement for medical supervision of NP practice.
Read the ACNP Media Release HERE
Quotes attributable to Leanne Boase, Chief Executive Officer, Australian College of Nurse Practitioners:
“The requirement for a Collaborative Arrangement has frequently been misinterpreted, hindering access to Nurse Practitioner care. Nurses are fundamentally collaborative health professionals, underpinned by our educational and professional standards."