Bulk Billing Advertising: Describing Fees Clearly

Updated 29 October 2026 to reflect the latest rules and guidance.

Patients care about cost, and fees are one of the first things they look for. That makes fee wording one of the places where clinics can easily get into trouble. It has also changed recently: from 1 November 2025, Medicare bulk billing incentives can be claimed for any Medicare-eligible patient who is bulk billed, not just children under 16 and concession card holders, and a new Bulk Billing Practice Incentive Program (BBPIP) started for general practices on the same day.

The rule for advertising is straightforward in principle: it must not be misleading. In practice, that means being specific about what a fee covers, who it applies to and what conditions apply, and making sure the wording on your website caught up with the November 2025 changes.

What changed on 1 November 2025

Bulk billing incentives for all Medicare-eligible patients

From 1 November 2023, the bulk billing incentive paid to GPs for bulk billing children under 16, pensioners and other Commonwealth concession card holders was tripled for most common GP consultations. Many practices built their fee wording around that group.

From 1 November 2025, the MBS bulk billing incentive items were amended so they no longer require the patient to be under 16 or a concession card holder. In the words of the MBS Online factsheet, incentives can now “be claimed when any Medicare-eligible patient is bulk billed.”

This doesn’t mean every practice now bulk bills everyone. It means the incentive is available for any eligible patient a practice chooses to bulk bill. Your billing policy is still your decision, and your website needs to describe it accurately.

The Bulk Billing Practice Incentive Program

BBPIP is a voluntary program for general practices that began on 1 November 2025. It pays participating practices an additional quarterly 12.5% on MBS benefits from eligible services, split evenly between the practice and the GP. To participate, a practice must bulk bill every eligible service for every Medicare-eligible patient, be registered in MyMedicare, register as a fully bulk billing practice in healthdirect’s National Health Services Directory and display Medicare Bulk Billing Practice signage on site, with some exceptions such as practices without a physical location.

The Department of Health, Disability and Ageing publishes the program guidelines and a fact sheet on the healthdirect and signage requirements. If you participate, follow those documents for how the signage is used, rather than adapting it for your own advertising.

A longstanding rule that still trips people up

MBS note GN.7.17 explains that when a service is bulk billed, the practitioner accepts the Medicare benefit as full payment, and “Additional charges for that service cannot be raised.” That rules out charges such as booking fees, record-keeping fees, administration fees and consumables on a bulk billed service. The exception is a vaccine supplied from the practitioner’s own stock, where a charge can be raised only to cover the supply of the vaccine.

Who it applies to

The incentive changes and BBPIP apply to general practice. But the advertising rules apply to everyone: GPs, specialists, dentists, allied health and cosmetic clinics. Any practice that mentions bulk billing, rebates or fees must describe them accurately under the Australian Consumer Law, and registered practitioners must also follow the National Law and Ahpra’s advertising guidelines.

What the advertising rules require

Not misleading

The Australian Consumer Law prohibits misleading or deceptive conduct, including about prices. From 28 March 2026, the fixed maximum penalty for a corporation doubled from $50 million to $100 million per contravention.

Clear price information

Ahpra’s Guidelines for advertising a regulated health service list, as examples of misleading advertising, price information that is “unclear, inexact or vague”, and stating an instalment amount without stating the total cost. Comparing prices without complete information is also flagged.

Terms for offers

Section 133(1)(b) of the National Law prohibits advertising a gift, discount or other inducement unless the advertisement also states the terms and conditions of the offer. Ahpra’s guidelines add that terms should be in plain language and easy to find.

Why vague wording causes complaints

The phrase “bulk billing available” might mean bulk billing for everyone, for some patients, for some appointments or for some doctors. If a patient turns up expecting to pay nothing and is charged a fee, they will feel misled, and may complain.

The problem isn’t bulk billing. It is the gap between what the website implies and what actually happens. The November 2025 changes widened that gap for many practices: wording written for the old under-16 and concession rules may no longer describe what you do.

Say who it applies to

Be specific. For example:

“We bulk bill all Medicare-eligible patients for all eligible services.” (Only if that’s true for every doctor, every appointment type and every patient.)
“We bulk bill children under 16, pensioners and concession card holders. Other patients pay a private fee, shown below.”
“Bulk billing is available for standard consultations with some of our doctors. Please ask when booking.”
“We are a private billing practice. Our standard consultation fee is shown below, and part of it may be claimable through Medicare.”

Each of those is clear. None leaves the patient guessing.

Be careful with “fully bulk billed”

“Fully bulk billing” now has a specific meaning in the BBPIP context: a practice that bulk bills every eligible service for every Medicare-eligible patient and is registered as such with healthdirect. If your practice hasn’t joined BBPIP, or doesn’t bulk bill everyone for everything, don’t describe yourself as fully bulk billing.

Don’t advertise bulk billing with extra charges

“Bulk billed, $20 booking fee applies” describes something GN.7.17 doesn’t allow. If you charge booking, administration or consumable fees, the service isn’t bulk billed, and your wording needs to say it’s privately billed.

Show fees where you can

Many patients choose a clinic based on cost, so showing fees helps you as well as them. If you publish prices, make sure they are:

Current. Update them when they change, and put a date on your fee page.
Complete. Include what is and isn’t covered, and common extra costs.
Clear about rebates. Say that Medicare or health fund rebates depend on eligibility, and don’t suggest everyone will get a particular amount.
Total, not partial. If you mention payment plans, show the total cost as well as any instalment amount.

Don’t mix fees with pressure

For cosmetic procedures especially, discounts and deals are restricted. The Medical Board’s guidelines for medical practitioners who advertise cosmetic surgery, in effect since 1 July 2023, don’t permit discounts or gifts tied to surgery and require total cost information rather than just consultation fees. Ahpra’s guidelines for practitioners who perform non-surgical cosmetic procedures, in effect since 2 September 2025, ban promoting financing schemes and offering free or discounted procedures for promotion. For other services, make sure any promotion has clear terms, an end date if there is one and no pressure to decide quickly.

What it means for each channel

Website

Your fees page is the main reference, and every other page should agree with it. Check the homepage banner, the booking page, the FAQs and individual doctor profiles, which often carry their own billing notes.

Google Business Profile

Check the business description, any attributes and any posts. If your Google listing says bulk billing and your website says private fees, one of them is wrong. Changes to your billing after 1 November 2025 often haven’t made it to Google.

healthdirect and directories

BBPIP practices must register as fully bulk billing in healthdirect’s National Health Services Directory. Whether or not you participate, check that your directory listings match your actual billing.

Social media and paid ads

Short copy encourages oversimplification. “Bulk billing!” in an ad headline needs to be true for the people the ad reaches, or qualified in the ad itself.

Phone and reception

The on-hold message and the reception script are part of how you describe fees. Update them at the same time as your website.

Train the team

Reception staff need to give the same answers as the website. A short script about fees and rebates helps, and so does a regular check that the website still matches what the clinic actually does. Make sure staff know the difference between bulk billed and privately billed services, and that extra fees can’t be added to a bulk billed service.

Common mistakes we see

Wording that still describes the pre-November 2025 rules as if they were a Medicare requirement, rather than the practice’s own policy.
“Bulk billing available” with no indication of who, when or which doctors.
“Fully bulk billed” claims from practices that charge some patients or some services.
Booking or admin fees added to services described as bulk billed.
Rebate amounts shown as if every patient will receive them.
Fee pages with no date and prices from two years ago.
A Google profile, healthdirect listing and website that each say something different.

A practical checklist

Does every mention of bulk billing say who it applies to, for which services and with which practitioners?
Have you updated wording written for the pre-November 2025 incentive rules?
Do you only say “fully bulk billing” if you bulk bill every eligible service for every Medicare-eligible patient?
Are there no booking, admin or consumable fees on services you describe as bulk billed?
Are published fees current, dated and complete, with rebates described as dependent on eligibility?
Do payment plan references show the total cost?
Do any offers include plain-language terms, and are cosmetic procedures kept out of discounts?
Do your website, Google profile, healthdirect listing, social bios, on-hold message and reception script all match?
If you participate in BBPIP, are you following the Department’s healthdirect and signage requirements?

How this fits with other rules

Medicare rules, set through the MBS and its explanatory notes, determine what you can charge when you bulk bill. BBPIP has its own participation requirements. The Australian Consumer Law and, for registered practitioners, the National Law and Ahpra’s advertising guidelines, govern how you describe all of this to patients. Cosmetic procedures add the Medical Board and Ahpra cosmetic guidelines on top.

Frequently asked questions

Do we now have to bulk bill everyone?

No. From 1 November 2025, the incentive can be claimed for any Medicare-eligible patient you bulk bill, but whether you bulk bill is still up to your practice. BBPIP is voluntary, and only practices that join must bulk bill every eligible service for every Medicare-eligible patient.

Can we describe ourselves as a bulk billing clinic?

Only if it’s accurate for the patients and services the statement suggests. If some patients or services are privately billed, say so in the same place.

Can we charge a booking fee on a bulk billed appointment?

No. MBS note GN.7.17 says additional charges can’t be raised for a bulk billed service, other than for vaccines supplied from the practitioner’s own stock.

Can we offer a discount for new patients?

Possibly, with clear terms stated in the advertisement. For cosmetic surgery, discounts and gifts aren’t permitted, and for non-surgical cosmetic procedures, free or discounted procedures for promotion are banned.

Do we have to publish every fee?

There is generally no rule that you must list every fee, but whatever you do say has to be accurate and not misleading. Partial information that gives a false impression is a problem.

What about gap fees for specialists?

Explain that a gap may apply and, where you can, give an estimate with a note that it can vary depending on the patient’s circumstances and cover.

A quick fee-wording audit

Once a year, and whenever your billing changes, check every place a patient might read about your fees: the homepage, the booking page, the Google profile description, your healthdirect listing, your social bios, the on-hold phone message and the reception script. If any of them says something different from the others, fix it so they all match what actually happens.

Need a hand?

We often find fee wording in our compliance audits, and our content service can rewrite it clearly. See our GP clinic marketing page for more.

This article is general guidance based on the published rules, not legal advice. Final responsibility for advertising sits with the registered practitioner, and complex situations may need independent legal advice.