It has been announced that co-payment billing practices for psychologists is returning starting today, Monday 6 April.

This is following the news made just last week that psychologists across Australia were required to bulk bill all telehealth sessions effective 30 March April. Unsurprisingly, this wasn’t well received by the psychologist community.

And in just a week, this decision has been reverted, allowing psychologists to return to their usual billing practices, except for the clients who meet the mandatory bulk billing criteria:

  • a person who is a concessional beneficiary
  • a person who is under the age of 16
  • a person who is ‘more vulnerable’ to COVID-19 virus

A patient more vulnerable to COVID-19 virus means a person who:

  • (a) is required to self-isolate or self-quarantine in accordance with guidance issued by the Australian Health Protection Principal Committee in relation to COVID-19; or
  • (b) is at least 70 years old; or
  • (c) if the person identifies as being of Aboriginal or Torres Strait Islander descent—is at least 50 years old; or
  • (d) is pregnant; or
  • (e) is the parent of a child aged under 12 months; or
  • (f) is being treated for a chronic health condition; or
  • (g) is immune compromised; or
  • (h) meets the current national triage protocol criteria for suspected COVID-19 infection.
For a list of the updated MBS factsheets, click here.

So, psychologists must be jumping up and down with joy, right?


The main concerns from psychologists can perhaps be summarised in the following points.

  1. Practices that focus on children, adolescents or the elderly will still be significantly impacted.
  2. Psychologists already bulk bill or give concessions to those who struggle financially. It should be left to the practitioners/practices to continue making this decision.
  3. The telehealth bulk bill policy was already announced to all the clients. Now we’ll look greedy and irresponsible announcing that we’re charging gap fees again.

Points 1 & 2 are being discussed and debated on more appropriate platforms like the APS or AAPi Facebook pages and other forums. And while you can sign petitions and continue to show support for the psychologist community, these points unfortunately don’t have immediate and actionable solutions.

The 3rd point however, needs an action plan right away and has some solutions that could minimise damage to your practice and the therapeutic relationship with your clients.

Let’s dive in.

Check out and bookmark our COVID-19 Private Practice Support & Resources page for more coronavirus-related information and support.


The telehealth bulk bill policy was already announced to all the clients. Now what?

Many psychologists have closed their physical practices and moved to telehealth entirely. And following the announcement of telehealth bulk billing, many of you advised your clients of these changes (no matter how much it hurt you to do so).

And now that you’re able to charge a gap fee again, how can you “take back” what you said last week without seeming greedy and flakey?


First, can the bulk bill decision be reversed if I’ve already notified my clients?

Yes, it can. You can go back to charging a gap fee even if you told your clients last week that they were going to be bulk billed for all telehealth sessions. You need to pay your bills, your contractors, feed yourself and your family, and you shouldn’t feel guilty about that.

This wasn’t planned and nobody could have seen it coming. You, your team and your clients know that if it were up to you, you wouldn’t have made these decisions.

You may be rightfully concerned about its impact on the relationship between you/your practice and your clients. But if managed well, you’ll be able to quickly address it and move on.


How should I approach the gap fee reintroduction?

First, let’s all remind ourselves and each other that people are generally empathetic and understanding. The current coronavirus pandemic is affecting us all in unexpected ways. As such, it’s only understandable that plans change and some decisions need to be quickly adjusted to reflect the current climate. Just as you’re understanding of these circumstances, so are most of your clients.

Now, having said that, below are some of my suggestions for approaching the reintroduction of gap payment so soon after announcing your bulk-bill-for-all-telehealth policy.


#1. Those who were offered bulk billing get bulk billed

Clients who booked an appointment since the introduction of the telehealth bulk billing items would have been bulk billed, or told that they will be bulk billed. One of the simplest approaches is to continue to bulk bill these clients in line with their expectations at the time of booking. And anyone that books in from today onwards gets quoted the regular fee.

While you’ll have to cut your losses and undergo a perhaps significant revenue drop, it can still be manageable assuming that you didn’t get hundreds of new bookings. If appropriate, you can also minimise the impact on revenue by spacing out bulk billed sessions and filling your diary with higher paying sessions where possible.

(This method may be more appropriate for those who didn’t send out mass communications to their clients advising of the new telehealth bulk billing policy.)


#2. Bulk bill for April only

Another option is to leave things the way they are just for the month of April (for those who can survive doing so). With this method, you’re going to have a very tight month. But it could give you peace of mind by not having to go back to your clients just one week after announcing the new bulk bill policy. It could also allow you to see how it works for your practice and better identify clients who may need concession.


A sample email script to get you started

For the month of April, all telehealth sessions at [Practice Name] will be bulk billed for those with Mental Health Care Plans. This decision was made in order to support all our clients to easily access psychological care in light of the ongoing coronavirus outbreak.

In a perfect world, we would like to continue to bulk bill everyone indefinitely. However, given our current position, it cannot be sustainable in the long term.

As such, from 1st of May, we will continue to bulk bill clients who are [bulk bill criteria]. Those who don’t meet the criteria will pay a gap fee. We are however committed to taking your individual financial circumstances into consideration.

If you have any questions about this policy and your eligibility, please don’t hesitate to contact our reception team or your psychologist.


#3. A new bulk bill policy instead of “reverting”

Instead of “taking back” what you said and reverting your bulk bill policy, approach it as the introduction of a new policy. It’s all in the wording and perspective; Focus on who is eligible for bulk billing, not those who aren’t.

You’re following government orders to bulk bill clients who meet the criteria perhaps in addition to your own criteria.


A sample email script to get you started

At [Practice Name], we are committed to making our services as accessible as possible for those who need it. As such, we have updated our bulk bill policy in light of the coronavirus pandemic and in line with the government orders.From today, clients who meet the following criteria will be bulk billed:

  • [Bulk bill criteria]

We are also more than happy to discuss your individual financial needs during this time.

If you have any questions about this policy and your eligibility, please don’t hesitate to contact our reception team or your psychologist.


#4. Talk to clients individually

Of course, every client is different and has different circumstances. Your relationship with each client is also unique, meaning you can make bulk bill decisions on a case-by-case basis.

Instead of (or in addition to) doing a group mail-out, you and your team can reach out to each individual client booked into the diary. Talking to clients individually will help both of you to practice empathy towards each other and make an arrangement that works.


#5. Explain to clients that ask

As a rule of thumb, you should never share the business sides of your practice with your clients as it could interfere with your therapeutic relationship. However, some clients may want a deeper understanding of your decision to reintroduce a gap fee. Some clients may also believe that private practice psychology is a naturally lucrative business, underestimating the expenses and wrongly assuming that most of their session fees go straight to the practitioner.

For these clients, explain without too much detail the circumstances that led to this decision.


Sample scripts to get you started

“Let’s not go into it too much because my only focus with you is your psychological care. But simply put, our practice won’t survive if all of our clients are bulk billed. We won’t be able to pay all of our bills including rent, reception, our psychologist team, bank fees, electricity, phone, membership fees, and so on. We make some exceptions and try to bulk bill where necessary, and that’s only possible if we’re in the financial position to do so, which we won’t be if we bulk bill everyone.”

“Our previous bulk-bill-for-all-telehealth policy was following the government announcement. By following the rules we were having to forego important aspects of our practice like cutting down reception hours and cancelling services that are beneficial to our clients. The government recognised that forced bulk billing is detrimental to our ability to care for our clients and reverted their decision.”


At the end of the day, you set the overall tone of your practice and you know your clients best. What works for one practice may not work for another. So, using your knowledge of your practice, team and clients, find the most suitable and effective way forward. If you need tailored support, you can reach out to us here and if you have any suggestions share them in the comments below.

Check out and bookmark our COVID-19 Private Practice Support & Resources page for more coronavirus-related information and support.