Australian Health Dep't failed to manage risks in expanding telehealth: state auditor

Australian Health Dep’t failed to manage risks in expanding telehealth: state auditor

The Australian National Audit Office has conducted a review of the expansion of telehealth services across the country by the Department of Health and Aged Care in response to the COVID-19 pandemic.


Based on the state audit, the department fell short in governance, risk management, and evaluation of the telehealth expansion.

While it made “significant” changes to the Medicare Benefits Schedule (MBS), the expanded telehealth services were “only partly supported by sound implementation arrangements.”

The audit found that it did not require key implementation decisions and plans to be documented.

It was also noted that the department did not manage implementation risks associated with temporary or permanent telehealth changes in accordance with its risk management policy. It also did not conduct a risk assessment of integrity risks, such as provider fraud and non-compliance, before implementing the temporary and permanent MBS telehealth items.

Therefore, as per ANAO, its governance arrangements for telehealth expansion were not “fit-for-purpose.”

Meanwhile, the state audit also found that the department did not plan for performance monitoring or evaluation of temporary or permanent telehealth.

“Health has not consistently evaluated the effectiveness of telehealth as a pandemic response, although some analysis of billing data and independent research has been undertaken,” the report said.

It used MBS billing data to monitor telehealth usage patterns on the assumption that telehealth usage and billing behaviors were sufficient indicators of successful telehealth implementation. It also has no performance targets.

Still, both temporary and permanent expansion of MBS telehealth items were largely informed by “robust” policy advice and planning, the audit emphasized.

During the initial pandemic response, the department quickly advised the Health minister on the costs and some of the benefits and risks of temporary telehealth policy settings. He also consulted with and took in the opinions of peak bodies into its policy advice for temporary and permanent telehealth.

Following these findings, ANAO made a few recommendations, which the department agreed on. This includes strengthening its systems of control for implementing changes to the MBS, embedding elements of governance such as documentation of implementation issues and decisions, and planning for monitoring and evaluation. It also agreed to develop procedures which ensure the changes in MBS are subject to a structured and documented risk assessment, as well as finalize its plans to evaluate permanent telehealth.

It only agreed in-principle to the recommendation that it consider the lessons learned from introducing temporary telehealth items as a pandemic response measure for future pandemic preparedness.

In response, the department said that it “acknowledges the ANAO findings while also recognizing the unique scenario of the COVID-19 emergency health response.”

“The department delivered on its objectives to maintain patients’ access to essential health services throughout lockdowns as well as reducing [the] risk of transmission for patients and providers,” it added.

Moreover, it said that it still has to refine and evaluate the alignment of MBS telehealth items with contemporary clinical practice through a post-implementation review. It will be done by the MBS Review Advisory Committee, which shall report back to the government later this year.


ANAO conducted the audit to provide “assurance” over the rapid implementation of health policy changes and the transition from emergency to permanent settings. “Rapid implementation of policy changes can increase risks to [the] effective and efficient delivery of public services,” it explained.


To provide greater access to health services amid an ongoing global pandemic, the Australian government introduced 281 new telehealth items on the MBS. In late 2021, the Health Ministry announced that the government has set aside funding to make the subsidized telehealth items permanent. However, weeks following this announcement, the government disclosed its move to end its support for 128 telehealth items on Medicare as per the recommendation by the MBS Review Taskforce. Later in November, the government brought back its subsidy for bulk-billed video telehealth psychiatry consultations by providing additional funding in the October budget.

As of late, over 130 million services have been provided via subsidized telehealth in Australia, based on the current Health Department’s figures.

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