Bulk-billing AoB — what's changing on 1 July 2026
From 1 July 2026 the Assignment of Benefit process is modernised: the provider no longer signs, there's no prescribed form, and an electronic signature is valid as long as it identifies the patient and shows they agreed. Verbal consent isn't abolished on day one — a 12-month transition (1 July 2026 to 30 June 2027) is expected to keep it valid, subject to the enabling amendment commencing, after which the patient must sign before you can lodge a bulk-billed claim. This page is a plain-English summary for GP and consultant-physician practices — pathology and diagnostic-imaging have their own rules and aren't covered here.
The signature requirement
From 1 July 2026 the provider no longer signs — only the patient, or the person who incurred the expense (for example a parent), signs to evidence that they agree to assign the benefit. A physical or electronic signature is acceptable; an electronic one must meet the Electronic Transactions Act 1999 (Part 2, Division 2, s 10), which treats a signature as valid when three things are true:
- It identifies the person signing and shows they meant to sign.
- The method is as reliable as appropriate for the purpose.
- The signer agreed to use that method.
The law is technology-neutral. The Department of Health's FAQ (as at 26 June 2026) confirms a range of methods may meet the electronic-signature test — expressly including checking a box or typing a name on a screen or kiosk — provided a method is used to identify the person and the practice's information-technology requirements are met. A tap-to-accept ("I accept") signature therefore qualifies when it is tied to an identified patient and captured as an auditable record. Drawn signatures and a typed name fit the same examples. The FAQ's list is illustrative, not exhaustive, and the law doesn't prescribe the channel — an SMS "reply YES" can equally be a valid signature, provided the patient is identified, the act is captured as an auditable record, and they reply against the itemised AoB content (for example, after viewing the form via a link) rather than a bare prompt. The requirement is the same for every channel: a valid AoB signature must be identifiable, made against the presented content, and auditable.
Transition: the Department has said it will make a regulatory amendment allowing verbal assignment of benefit to be accepted for all bulk-billed services, in every setting (including telephone and telehealth), for a 12-month transition from 1 July 2026 to 30 June 2027. As at the 26 June 2026 FAQ that amendment was still to be finalised, so confirm it has commenced before relying on verbal consent. Either way, verbal assignment only changes how agreement is evidenced — it never removes the obligation to record the full data set and retain it for two years. A signed record is the durable, audit-ready evidence the regulations ultimately require, so it's the method to adopt now.
Format and delivery
There is no prescribed template. An AoB can be paper or electronic, in any layout, as long as it contains the required information and the patient or assignor signs it. A 12-month transition (1 July 2026 to 30 June 2027) is expected to keep verbal assignment valid in all settings, including telephone and telehealth, subject to the enabling amendment commencing; once the transition ends a signature is required.
The FAQ's named examples are signing on a tablet or touch screen, typing a name into the form, clicking or tapping "I accept", and secure digital-signature processes — each paired with a way to identify the signer. Those examples are illustrative; other channels such as an SMS reply can meet the same technology-neutral test, as long as the signer is identified, they sign against the itemised AoB content, and the act is auditable.
Nothing in the regulations mandates PIN protection, link expiry or any other technical specifics. Whether a given method satisfies the tests for a particular situation is a question for your privacy officer or legal advisor.
Verbal consent still means presenting the full information
A verbal assignment isn't a yes/no shortcut. During the transition you must still convey the same required information to the patient — who the provider is, the service or its Basic Service Description, the dates, and that they're assigning their Medicare benefit as full payment so they won't be charged — and the patient must agree to that. The only difference from a signed AoB is how the agreement is evidenced (spoken rather than signed). Record that verbal agreement was obtained, by whom, and keep it for two years.
Pre-agreement vs post-agreement
| Pre (before service) | Post (after service) | |
|---|---|---|
| Service identifier | Basic Service Description (BSD) — the official descriptor for a category of services | The actual MBS item number(s) |
| Why | The exact item isn't known at booking | You know what was billed |
| Risk | If the rendered service falls outside the BSD scope, a fresh post-agreement is required | Lower — the agreement matches the claim |
The Basic Service Description list is published on MBS Online and refreshed quarterly — 1 January, 1 March, 1 July and 1 November. Pre-agreements must use the wording current at the time the patient signs.
Enduring agreements (GP settings only)
Alongside per-visit (episodic) agreements, the rules introduce an enduring assignment — a standing agreement that covers a patient's future bulk-billed services without re-signing each time. Enduring agreements are limited to general-practice settings: patients registered through MyMedicare, Aboriginal Community Controlled Health and Aboriginal Medical Services, and residential aged care. They are not available to consultant physicians or specialists — those practices continue to use pre- or post-service episodic agreements. An enduring agreement still requires the data set, a valid signature, and the same two-year retention.
Common scenarios and what's required
Situations a GP or consultant-physician practice will hit, and what the rules say in each.
| Scenario | What the FAQ says is required |
|---|---|
| Patient cannot sign — needs an assignor | A parent, partner, carer, relative, person with power of attorney or friend can sign as the assignor. Persons employed by the rendering practitioner cannot. Without a patient or assignor signature, the AoB is not complete and a bulk-bill claim should not be made. |
| Minor patient | The assignor only needs to be the person who would otherwise meet the cost — typically a parent, guardian, or carer, but not limited to those relationships. The assignor's identity and authority must appear in the record. |
| Multiple services, same practitioner, same day | Multiple services may be included under a single AoB if all listed services are rendered by the same practitioner. Each item must appear in the data set. |
| Multiple services, different practitioners (same or different practice) | Separate AoB agreements are required for each practitioner. |
| Patient sees a different practitioner than booked | Capture a fresh pre-service AoB before the visit if you know in advance, or a post-service AoB with the actual practitioner's details. Mismatched details invalidate the claim. |
| Rendered service differs from the BSD agreed in a pre-assignment | If the actual service falls outside the basic service description scope, the pre-agreement is invalid and a post-service AoB must be captured. |
A few more things to know
- The provider no longer signs. Only the patient or their assignor does.
- Old forms no longer valid. From 1 July 2026 the DB4e and DB020 forms no longer meet the requirements — capture a new agreement containing the required data set instead.
- Copy on request. If the patient asks for their signed agreement, you must be able to provide it.
- Keep records for two years from when the claim is made. Services Australia may ask for them during an audit.
- No mandatory form. Services Australia will publish an optional sample, but you can use any layout — paper or electronic — as long as it includes the required information and is signed.
Official sources
- Department of Health · Bulk-Billing AoB FAQ
- Department of Health · Simplified-Billing AoB FAQ
- Health Insurance Amendment (Assignment of Medicare Benefits and Other Measures) Regulations 2025 — s.65C(4) is the data-set source
- Electronic Transactions Act 1999 — governs electronic signature validity
- Attorney-General's Department · Electronic signatures — the Commonwealth's plain-English statement of the three-prong test
- Services Australia · Assignment of benefit for bulk-bill claims
- MBS Online · Downloads (BSD dataset, XML fee file)