Section 19AB and Distribution Priority Areas: Where Overseas-Trained Doctors Can Bill Medicare

What section 19AB actually says

Section 19AB(1) says a Medicare benefit "is not payable in respect of a professional service rendered by a person who is an overseas trained doctor or who is a foreign graduate of an accredited medical school" unless one of the listed conditions is met, subject to exemptions under subsection (3). Subsection (2) applies the same rule to services rendered on that doctor's behalf.

The Act defines who is covered:

• Overseas trained doctor: "a person whose primary medical qualification was not obtained from an accredited medical school". An accredited medical school is one accredited by the Australian Medical Council and located in Australia or New Zealand.
• Foreign graduate of an accredited medical school: a person whose primary medical qualification came from an accredited medical school but who, when they first enrolled, was not a permanent Australian, a New Zealand citizen or a New Zealand permanent resident.

For a doctor registering now, the way out of the restriction is in paragraphs (e) and (f). Both require that the service is "rendered after the end of the period of 10 years beginning when the person first became a registered medical practitioner", and that the person is a permanent Australian, meaning an Australian citizen or the holder of a permanent visa. It doesn't matter whether they became permanent before or after first registering. The other paragraphs deal with doctors who first registered before 1 January 1997 or before an earlier amendment took effect.

The department puts it this way: the moratorium and all location restrictions "end after 10 years if you are a permanent resident or citizen" and "continue unchanged if you remain a temporary resident".

Under subsection (3) the Minister may grant an exemption "in respect of a person or a class of persons", with conditions, following guidelines the Minister must make as a legislative instrument. If a doctor breaches a condition, the exemption stops applying while the breach continues.

What section 19AB does not do

• It doesn't stop registration. The Medical Board of Australia registers doctors; section 19AB is about Medicare benefits.
• It doesn't stop a visa being granted. Home Affairs decides the visa separately.
• It doesn't restrict salaried work that doesn't bill Medicare. The department's words: "There is no restriction if you work in a salaried position that doesn't attract Medicare benefits, like in a public hospital."

What it does decide is whether a doctor can be given a Medicare provider number for a location, and so whether a private general practice or private specialist rooms can bill Medicare for that doctor's services.

Distribution Priority Areas: the map for GPs

The DPA classification "identifies areas with lower levels of GP services, compared with a benchmark level". Under section 19AB, the department says, international medical graduates and foreign graduates of accredited medical schools "can only access Medicare in areas with GP shortages".

How an area is classified, according to the department:

• Australia is split into 824 non-overlapping GP catchments.
• Each year the department compares the GP services Medicare billed in each catchment with a benchmark, adjusted for the age, gender and socio-economic status of the people living there. If billing is below the benchmark, the catchment is a DPA.
• The benchmark used for international medical graduates is based on the average level of GP services in areas classified MM 2.
• Automatic rules: areas classified MM 2 to MM 7 are a DPA, MM 1 inner metropolitan areas are not, and the whole of the Northern Territory and Tasmania are a DPA.
• The most recent update used Medicare GP billing for calendar year 2023, the ABS 2023 population estimates and the 2023 Modified Monash Model. The department's page says the most recent annual update occurred in March 2025.

If a catchment loses DPA status, doctors who already hold a section 19AB exemption there can keep practising at that location if they keep meeting its conditions. Doctors who were negotiating employment with a practice before the change can still be eligible if they provide evidence of it with their application. A practice can ask for an exceptional circumstances review of its catchment's classification.

To check a location, search the department's Health Workforce Locator.

Districts of Workforce Shortage: the map for specialists

A DWS is an area where people have poor access to specialist medical practitioners. The department uses population and Medicare billing data to work out a ratio of specialists to population in each SA3 area. An area is a DWS if its ratio is below the national average and it is classified Remoteness Area 3 to 5 (rural to remote).

For specialists subject to section 19AB, a location counts as a DWS for their specialty if it is RA 3 or more remote, or if the specialty has a national full-service equivalent above 3 per 100,000 people and the area's ratio for that specialty is below the national average. In November 2023 eight specialties were over that national level: anaesthetics, cardiology, diagnostic radiology, general surgery, obstetrics and gynaecology, ophthalmology, medical oncology and psychiatry.

The department's page says the DWS classification is updated every year and that the most recent update was in November 2023. The same protections apply when an area loses DWS status: existing exemptions continue while their conditions are met. The Health Workforce Locator can be searched by specialty.

The Modified Monash Model in one list

The Modified Monash Model (MMM) classifies every location from MM 1 (major city) to MM 7 (very remote), based on the ABS Remoteness Areas and town size. The current version is the 2023 MMM, and the 2015, 2019 and 2023 versions are all on the Health Workforce Locator.

• MM 1, metropolitan: major cities accounting for 70% of Australia's population; all areas in Remoteness Area 1.
• MM 2, regional centres: RA 2 and RA 3 areas in, or within 20 km road distance of, a town of more than 50,000 people.
• MM 3, large rural towns: RA 2 and RA 3 areas in, or within 15 km of, a town of 15,000 to 50,000.
• MM 4, medium rural towns: RA 2 and RA 3 areas in, or within 10 km of, a town of 5,000 to 15,000.
• MM 5, small rural towns: all other RA 2 and RA 3 areas.
• MM 6, remote communities: all RA 4 areas, and islands less than 5 km offshore.
• MM 7, very remote communities: all other RA 5 areas, and populated islands more than 5 km offshore.

Because MM 2 to MM 7 are automatically DPA, the MMM is the quickest first check for a GP role. It isn't the last check: an MM 1 catchment that isn't inner metropolitan can still be a DPA if its GP billing is below the benchmark, so the Health Workforce Locator is the place to confirm.

A regional visa location is not automatically a DPA

Home Affairs has its own regional map for visas such as the 491 and 494. It sorts Australia into three categories:

• Category 1, Major Cities: Sydney, Melbourne and Brisbane, which get no regional incentives.
• Category 2, Cities and Major Regional Centres: Perth, Adelaide, the Gold Coast, the Sunshine Coast, Canberra, Newcastle/Lake Macquarie, Wollongong/Illawarra, Geelong and Hobart.
• Category 3, Regional Centres and Other Regional Areas.

Categories 2 and 3 are designated regional areas for the visa. That map was drawn for migration, not for Medicare. Hobart is Category 2 and, because the whole of Tasmania is a DPA, it is on both maps. For Category 2 cities such as Perth, Adelaide and Canberra, whether a particular address is a DPA is decided on the DPA map alone, and the DPA rules say MM 1 inner metropolitan areas are not a DPA. So an address can meet the 494's regional test and still sit outside a DPA. A doctor taking a 494 role in a private practice needs both checks: the visa's regional postcode list and the Health Workforce Locator.

The exemptions, as the department lists them

"The best way to get an indefinite exemption is to work in a DPA or DWS location. Exemptions to work outside of a DPA or DWS locations are limited." That is the department's own summary. The exemption types on its page, as at 30 October 2026:

• Priority areas: working in a DPA or DWS for your specialty, on an approved workforce or training program, or after hours.
• 6-month locum: Medicare access anywhere for up to 6 months while you arrange work in a DPA or DWS. It can't be extended or repeated.
• Assistance at operations: assistance-at-operations Medicare items anywhere, under the supervision of a fully qualified surgeon.
• Replacement: replacing a doctor who held an unrestricted section 19AB exemption and no longer works in the local area.
• Spousal: practising near the main workplace of a spouse who is a medical practitioner or a skilled migrant.
• Prior employment negotiations: you started negotiating with a practice while it was in a DPA or DWS for your specialty.
• Aboriginal and Torres Strait Islander primary health services: a service with an exemption under section 19(2) of the Act.
• After hours: 6pm to 8am Monday to Friday, and any time on Saturday, Sunday and public holidays.
• Discretionary: you are the primary carer of a close family member whose serious medical condition can't be managed in a DPA or DWS, or exceptional circumstances apply.
• Specialties in acute shortage: Medicare access anywhere if you are registered with Ahpra as a specialist in one of 25 named specialties (listed below).
• 5-Year International Medical Graduates Recruitment Scheme: reduces the time you must work in a DPA or DWS to as little as 3 years, by working in an eligible regional, rural or remote location for a set period and gaining permanent residency and specialist registration in general practice while on the scheme.
• Academic: you meet section 19AA, hold an academic appointment with an Australian medical school and do clinical work as part of it. Private practices without teaching responsibilities don't count.
• Other circumstances the department may consider: other practices in the same DPA catchment for doctors who hold an unrestricted exemption; the locations on your Ahpra registration for doctors on the Competent Authority pathway or the Specialist pathway (area of need or specialist recognition), which must be in a DPA or DWS except in exceptional circumstances; and staying at the practice where you gained your fellowship through an approved program, after at least 12 months' continuous service there.

The 25 specialties in acute shortage: cardiothoracic surgery, dermatology, emergency medicine, endocrinology, geriatric medicine, gastroenterology, general medicine, haematology, intensive care medicine, nephrology, neurology, neurosurgery, orthopaedic surgery, otolaryngology, paediatric medicine, paediatric surgery, palliative medicine, pain medicine, plastic and reconstructive surgery, rehabilitation medicine, rheumatology, sports and exercise medicine, thoracic medicine, urology and vascular surgery.

Steps in order: from registration to a Medicare provider number

1. Registration (you and the Medical Board of Australia). The Board's pathways for international medical graduates are the Competent Authority pathway, the Standard pathway, the Specialist pathway, the Expedited Specialist pathway and short-term training in a medical specialty. Only the last one doesn't lead to ongoing registration. The Board's advice: "You need to wait for your Ahpra registration before you apply for your visa."
2. Check the location (you and the employer). Before accepting a role that will bill Medicare, look the practice address up on the Health Workforce Locator: DPA for a GP, DWS for your specialty. For a 494 role, check the Home Affairs regional postcodes as well.
3. Nomination and visa (the employer, then you). The employer lodges the nomination and you lodge the visa application, quoting the Transaction Reference Number the employer receives. For the 482 Core Skills stream, Home Affairs says a medical practitioner must have their qualifications recognised by the Australian registration authority, and asks for evidence of registration. GP roles may also need a Health Workforce Certificate (see the visa section below).
4. Medicare provider number and exemption (you, Services Australia and the department). For every exemption except the spousal and discretionary ones, you include the supporting documents with your provider number application and Services Australia applies to the department for you. The department says it assesses exemption applications within 28 working days and doesn't give status updates. From November to March, its peak period, it asks applicants to allow at least 6 weeks for the application to be processed and a provider number issued. Spousal and discretionary exemptions need the department's initial assessment before you apply for the provider number.
5. Start billing only once both are in place. "Under the legislation, we cannot backdate exemptions." Services provided without a provider number create a debt.
6. Build scaling credits (automatic). Working in Remoteness Areas 2 to 5 and billing at least $5,000 a month in Medicare items earns credits that can shorten the time you must stay in a DPA or DWS (table below).
7. Permanent residence (you). If you become a permanent resident, tell Medicare straight away; your exemption may no longer be valid. If you hold a fellowship or are on a 3GA program, your existing exemption terms stay in place. If you don't, you must join a 3GA program under section 19AA and get a new section 19AB exemption to keep billing Medicare.
8. The end of the restriction. Ten years after your first Australian registration, the restriction ends if you are then a citizen or permanent resident. If an exemption application is declined along the way, you have 90 days from the decision to ask the department to reconsider, and if it declines again you can apply to the Administrative Review Tribunal.

Scaling: how remote work shortens the time in a DPA or DWS

Scaling credits are applied automatically by Medicare once you have submitted billing data and reached the threshold. To earn them you must be a doctor covered by section 19AB, working in an eligible regional or remote area, claiming Medicare Benefits Schedule items as part of your employment, with a monthly billing threshold of $5,000. If you work in several areas, the month is scored where you do most of your Medicare claiming. Scaling uses Remoteness Areas, not the Modified Monash Model.

The department's wording matters here: "The moratorium is always 10 years minimum. But once you have enough scaling credits, you may have a class exemption for the rest of your moratorium." In other words, scaling shortens the time you must spend in a DPA or DWS; it doesn't shorten the 10-year count itself. Doctors on the 5-year scheme don't receive scaling credits because that scheme already gives moratorium credits. You can check your credits and dates in Health Professional Online Services (HPOS).

How section 19AB meets the 482 and 494 visas

Temporary visa holders stay restricted. A doctor on a Skills in Demand (subclass 482) or Skilled Employer Sponsored Regional (subclass 494) visa is a temporary resident, so the department's rule applies in full: restrictions "continue unchanged if you remain a temporary resident". The 10 years still count from first registration, but they only end the restriction for a citizen or permanent resident.

482 Core Skills stream. Home Affairs lists, among other things, pay at the market rate and no less than the Core Skills Income Threshold ($79,423 from 1 July 2026), at least 1 year of relevant work experience, and evidence from the Australian registration authority. The visa application charge for the primary applicant is AUD 4,015 from 1 July 2026. A 482 role in a public hospital salaried position that doesn't bill Medicare isn't restricted by section 19AB; a 482 role in a private general practice needs a provider number and so an exemption.

494. The visa needs a designated regional area (Categories 2 and 3). Medicare billing needs a DPA or DWS location, or another exemption. They are different maps, as set out above. The primary applicant charge is AUD 6,140 from 1 July 2026.

Health Workforce Certificate. The Department of Health's Visas for GPs program guidelines (December 2020, the latest version we could read) say employers nominating a doctor in ANZSCO 253111 (General Medical Practitioner), 253112 (Resident Medical Officer) or 253999 (Medical Practitioner nec) for an employer-sponsored visa must attach a Health Workforce Certificate, or for hospital employers on 482 and 494 nominations a Health Workforce Exemption Certificate. They state that "A visa will not be granted if an employer does not include an appropriate HWC or HWEC in the visa nomination application". Those guidelines pre-date the Skills in Demand visa, so confirm the current process with the state's Rural Workforce Agency. The guidelines also make the key distinction: "Being eligible for a Health Workforce Certificate does not automatically equate to eligibility for a Medicare Provider Number, including section 19AB exemptions".

Occupation lists. On the Home Affairs skilled occupation list as checked on 30 October 2026, General Practitioner (253111) and Medical Practitioners nec (253999) are on the MLTSSL and the Core Skills Occupation List, and Resident Medical Officer (253112) is on the STSOL and the Core Skills Occupation List, so it has no 189 pathway.

Section 19AA: the second Medicare rule

Section 19AA applies to every doctor who first became a registered medical practitioner on or after 1 November 1996, wherever they trained. A Medicare benefit is not payable for their services unless, at the time, they are a specialist, a consultant physician or a general practitioner as the Act defines those terms, a person registered under section 3GA (an approved workforce or training placement, for the period and location of that placement), or a person covered by a section 19AB(3) exemption who is neither an Australian citizen nor a permanent resident.

That is why the department says a doctor without a fellowship who becomes a permanent resident "must join a 3GA program under section 19AA" to keep billing Medicare: permanent residence takes them out of the last category, so they need one of the others.

Does section 19AB stop an overseas-trained doctor working in Australia?

No. It decides whether Medicare benefits are payable for the doctor's services. Registration is the Medical Board of Australia's decision and the visa is Home Affairs'. The department says there is no restriction on salaried work that doesn't attract Medicare benefits, such as in a public hospital.

When does the 10-year moratorium start and end?

Section 19AB counts the 10 years from when the doctor first became a registered medical practitioner in Australia. At the end of the 10 years the restriction ends only if the doctor is an Australian citizen or holds a permanent visa. The department says the restrictions continue unchanged for a doctor who remains a temporary resident.

What is the difference between a DPA and a DWS?

A Distribution Priority Area is the GP map: GP services billed in each of 824 catchments are compared with a benchmark. A District of Workforce Shortage is the specialist map: specialists per head of population in each SA3 area, limited to RA 3 to RA 5 except for eight specialties assessed nationally. Both are searchable on the Health Workforce Locator.

Can the time in a DPA or DWS be shortened?

Yes, in two ways the department lists. Scaling credits from working in Remoteness Areas 2 to 5 while billing at least $5,000 a month can bring the required time down to 9, 7, 6 or 5 years, after which a class exemption may apply. The 5-Year International Medical Graduates Recruitment Scheme can reduce it to as little as 3 years.

How long does a section 19AB exemption take?

The department says it assesses exemption applications within 28 working days and doesn't provide status updates. From November to March it asks applicants to allow at least 6 weeks for the application and the Medicare provider number together. Exemptions can't be backdated.

Is a regional location for the 494 visa automatically a Distribution Priority Area?

No. The 494 uses Home Affairs' designated regional areas, which include Category 2 cities such as Perth, Adelaide and Canberra. Whether an address there is a DPA is decided on the DPA map, and only the Northern Territory and Tasmania are a DPA everywhere. A private practice role needs both checks.

What happens if an exemption application is refused?

You have 90 days from the decision to ask the department to reconsider, with reasons and any new information. If it declines again, you can seek review by the Administrative Review Tribunal.