19AA | 3GA Training Programs | GP Training Programs | 19AA Exemptions

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Date Updated: 2024-01-23

What is 19AA?

Basically, 19AA requires any NON-Vocationally Registered Australia Permanent Resident or Citizen to be registered on an approved 3GA program prior to commencing work to be able to gain access to Medicare benefits. 

What does ‘Vocationally Registered’ mean? When referring to General Practitioners, it means that they have sat their fellowship exams via RACGP or ACRRM and becoming a Fellow in General Practice. This is also referred to as being a “VR” or “FRACGP” or “FACRRM.”

Who is restricted by 19AA?

All Non-Vocationally Registered Australian Citizens or Permanent Residents are restricted by 19AA. This restricts both people born here in Australia and those who have become Australians.

This means if you are born in Australia, have become an Australian Citizen or hold Permanent Residency you will be restricted until you achieve Fellowship with either ACRRM or RACGP, and are recognised as a Specialist in General Practice.

From 2022, all General Practitioners who are hoping to achieve Fellowship with ACRRM or RACGP will be required to join a 3GA Training program to be eligible to sit the Fellowship exams.

Once you sit your fellowship exams and are recognised as a specialist doctor, this restriction no longer applies.

What does it mean to be restricted by 19AA?

If you are restricted by 19AA, you are required to join a 3GA program to gain access to Medicare benefits. 

As soon as you receive Permanent Residency (from 5pm the day you become a Permanent Resident) you will need to cease practice until you are on an approved 3GA program.

If you are restricted by 19AA and not on a 3GA program, you will not be granted access to Medicare Benefits. Medicare can issue a fine if they discover you have continued to claim Medicare Benefits without being on a 3GA Program. You’ll be responsible for 50% of that money—Medicare will also chase your clinic for the other half of it.

Once you sit your fellowship exams and are recognized as a specialist doctor, this restriction no longer applies.

What if I just don’t want to join a 3GA program?

If for some reason you don’t want to join a 3GA program, you are still able to practice, you just won’t be able to provide services that offer a Medicare rebate through Medicare. Therefore, your patients, even if they have Medicare and are eligible to be bulk-billed, will have to pay the full cost of the appointment out of pocket and will not receive a rebate.

If you’re billing 100% privately, and your patients do not expect to get a rebate from Medicare, this restriction doesn’t apply. It only applies to those who want to be able to bulk bill and their patients have the ability to claim on Medicare.

What are the options for 3GA programs?

Your 3GA program options will depend on if you meet the eligibility criteria and on your practice location, if relevant. We have put together a summary of all the 3GA programs below:

Independent Pathway (IP)

The ACRRM Independent Pathway is a 4 year Specialist training program that assists GPs on the pathway towards ACRRM Fellowship and Specialist Registration.

  • Eligibility: You will be eligible for the program if you:
    • Be an Australian Citizen, Permanent Resident or Temporary Resident
    • Hold Limited, Provisional, Specialist, or General AHPRA Registration.
  • Placement: You will be required to find a practice that is in a MM 2-7 location to work in. Please note that 12 months must be completed in a MM 4-7 area.
  • Application: Applications are open various times in the year and are listed in the key dates calendar on their website. If applications are not open when you apply, you can submit an expression of interest to be notified when applications next open.
  • Fees: The ACRRM Independent Pathway does have a substantial fee ($24,950), so you will need to be prepared to cover these costs if you plan to join.

Rural Generalist Training Scheme (RGTS)

The Rural Generalist Training Scheme (RGTS) is a fully funded program of the College-led Independent Pathway, which leads to the Fellowship of ACRRM (FACRRM). It offers a thorough Rural Generalist education program, a flexible training environment, opportunities to meet program criteria, and individualised training support.

This is a 4-year program broken into 3 years of Core General Training (CGT), and 1 year of Advanced Specialist Training (AST).

  • Eligibility: To be eligible for this training scheme, you need to:
    • Be an Australian or New Zealand Citizen Australian Citizen, or a Permanent Australian Resident 
    • Hold a General AHPRA Registration by the commencement of training
    • Have an Australian Medical Council (AMC) recognised medical qualification
    • Have a job offer or be currently working in a MMM 2-7 location.
  • Placement: You will be required to find a practice that is in a MM 2-7 location to work in.
  • Application: The ACRRM runs two intakes per year. You can apply via their website.
  • Fees: You need to pay a $700 application fee, an ongoing ACRRM membership fee of $430 per year, as well as fellowship assessments.

Australian General Practice Training Programs (AGPT)

AGPT is a training program for registrars on the journey to either RACGP or ACRRM Fellowship and Specialist Registration as a General Practitioner. It’s a 4-year program that provides a lot of support to GPs with 1 year in the hospital and 3 years working in various clinics as a GP registrar. Applications open each year in April and commence the following January and they take on about 1500 registrars each intake.

  • Eligibility: To be eligible you need to:
    • Be an Australian or New Zealand Citizen Australian Citizen, or a Permanent Australian Resident 
    • Hold or expect to hold General AHPRA Registration by the commencement of the program
    • Have an Australian Medical Council (AMC) recognised medical qualification

There are 2 different pathways available for GPs and these depend on your 19AB restriction.

  • If you are restricted by 19AB you will join the Rural Pathway with AGPT. GPs in this pathway will undertake all of their training in rural areas that fulfil their 19AB restrictions.
  • The General Pathway of the AGPT program is for GPs that are not restricted by 19AB. GPs on this pathway will work in inner and/or outer metropolitan areas. 
  • If you have a 19AB exemption specifically for AGPT, such as a spousal exemption, you are eligible to join the General Pathway instead of the Rural Pathway. You will need to hold the exemption prior to applying for AGPT.
  • Placement: You aren’t able to choose a specific practice to work in on this program, but you can nominate your preferred area regions. Once you have been accepted for a region, you will be provided with a list of practices to contact to try to join.
  • Application: Applications for AGPT generally open in April and August each year and you can apply through their website.
  • Fees: Australian Government funding for the AGPT Program covers the cost of your training, but you will have to pay your own application fees, assessment fees, and college membership costs.

Remote Vocational Training Scheme (RVTS)

RVTS is a Fellowship training program for registrars on the journey to either RACGP or ACRRM Fellowship, designed to provide educational opportunities for GPs in rural areas with limited education opportunities.

RVTS provides training via distance education and remote supervision, so this allows GPs working in remote communities’ access to support whilst providing highly needed medical services.
Every year, only 22 GPs are approved for the Remote Stream and 10 GPs for the AMS Stream, so this program is competitive! These spots will also go to doctors working in more rural communities.

  • Eligibility: To apply, you must:
    • Be an Australian Citizen, Permanent Resident, or Temporary Resident
    • Hold either Limited (AON), Provisional or General AHPRA Registration with Level 3 or 4 supervision level.
      • If you are on limited registration, you must be on Australian Medical Council Standard Pathway, and have first been granted Limited registration on or after 2 January 2023
  • Placement: You can apply to RVTS through either the Remote Stream or AMS Stream.
    • To apply through the Remote Stream, you need to be practicing as a GP in an MM 4 – 7 classification area. 
    • To apply through the AMS Stream, you need to be working as a GP in an Aboriginal Community Controlled Health Service with an MM Classification of 2 – 7.
  • Application: You will need to be working in the practice at the time of applying and remain in the same practice throughout the program. 
  • Fees: Training with RVTS is funded by the Commonwealth.

Fellowship Support Program (FSP)

FSP is the self-funded education and training program that replaced the Practice Experience Program (PEP) Standard Stream. This program reinforces RACGP’s objective of supporting doctors who aspire to complete their Fellowship via the General Practice Experience (GPE) Pathway.

  • Eligibility: To participate in FSP you will need to:
    • Hold General, General and specialist, Limited (Level 2 supervision and above), or Provisional AHPRA registration (Level 2 supervision and above, via the competent authority pathway or the standard pathway with AMC certificate)
    • Have a job offer in an MMM 2-7 location.
  • Placement: You will be required to find a practice that is in a MM 2-7 location to work in. To be eligible for a FSP Provider Number (if it is required), you must work in a training location that complies with the General Practice Fellowship Program Placement Guidelines. This means FSP is particularly made for GPs whose placements are in MM2-7 areas. If you wish to join FSP but are employed in an MM1 area, it will be subject to approval of exceptional circumstances.
  • Application: Applications for the program usually open in January. You can apply via their website.
  • Fees: You will need to pay $573 AUD per year for RACGP Membership fee, $10,000 AUD per term for Year 1, and $6,000 AUD per term for Year 2. For a breakdown cost of the program, you may refer here.

If you pass the entrance exams for FSP, you will have the opportunity to apply for a new Medical Provider Number that is at the A1 level. As per the Medicare Benefits Schedule (MBS) A1 level is equivalent to consultation fee bracket being charged by VR General Practitioners.

Additionally, you must have a minimum of one exam semester remaining to complete all Fellowship examinations, as per the Fellowship Exam Attempts Policy. You may have multiple attempts at the AKT and KFP exams. However, you need to pass the exams in your fifth semester and dedicate your sixth and final semester to your clinical exams.

Recently, we received an update that you may be able to apply to have your Recognition of Prior Learning (RPL) assessed in certain circumstances. Depending on how this assessment goes, your time in the program could be reduced by six months (from 24 to 18 months). You can apply for RPL after the first six months of your program. Read more here.

More Doctors for Rural Australia Program (MDRAP)

UPDATE: Pre-Fellowship Program (PFP) will soon replace MDRAP. We’ll keep you updated once details about PFP are released. Read the DoH update here.

MDRAP is a 3GA program that has been created to encourage more doctors to work in rural and remote communities.

This program allows GPs 2 years on the program before they will need to transition to an alternative 3GA Program. Whilst on the program, you are expected to submit 1 application for either AGPT, ACRRM Independent Pathway, RVTS or FSP every year, as well as complete foundation general practice training modules provided by either the Royal Australian College of General Practitioners or the Australian College of Rural and Remote Medicine within six months of commencing on the MDRAP. If you are on MDRAP for more than 12 months, at least half of your annual professional development activities must be relevant to general practice.

Whilst MDRAP fulfils your 19AA requirements, it is not a fellowship training program and you will need to transfer to AGPT, ACRRM Independent Pathway, RVTS or FSP in order to sit the Fellowship exams.

  • Eligibility: To be eligible for the program you need to:
    • Be a Temporary or Permanent Resident
    • Hold current AHPRA registration
    • Have a job offer in a DPA and MMM 2-7 location (regardless of whether you are restricted by 19AB or not)
  • Placement: As part of this program you will need to find a practice in a DPA area with a MM Classification between 2 – 7. All Aboriginal Medical Services are eligible regardless of location criteria.
  • Application: Applications for MDRAP are open throughout the year and you can apply for this program by emailing the Rural Workforce Agency in your State or Territory. The application process depends on the state. Applications take around 28 business days to process.
  • Fees: There are no costs associated with MDRAP.

After Hours Medical Deputising Services (AMDS)

This program allows you to gain clinical experience during the after-hour periods.

AMDS services can either be clinic based or involve visiting patients’ homes and these practices are available in both metropolitan and regional areas.

Your eligible working hours are between 6pm to 8am on weekdays, before 8am and from noon onwards on Saturday, all-day Sunday and on Public Holidays.

As your patient base is restricted, your experience will be assessed at 50% if visiting patients outside of the clinic and 75% if managing patients in clinic. Additionally, this time will be capped at 2.5 years assessed.

Whilst AMDS fulfils your 19AA requirements, it is not a fellowship training program and you will need to transfer to AGPT, ACRRM Independent Pathway, RVTS or FSP in order to sit the Fellowship exams.

This program will also allow you to work in the CBD and there are plenty of options of organisations for you to work for, so make sure you shop around to get a good percentage and a good working environment. One thing to note: the RACGP now calculates MDS experience at 50% of the time worked (e.g. 1 year working in AMDS is counted as 6 months).  A maximum of 2.5 years (assessed) of after-hours can be considered towards fellowship. Regardless of your previous experience you are required to also have 6 months in-hours (Australian day-time clinic) to be eligible to sit Fellowship.

  • Eligibility: You are eligible if you:
    • Hold Limited, Provisional or General AHPRA Registration.
    • Hold a current Level 1 Advanced Life Support (ALS) Course Certificate
    • Have at least 2 years of post-graduate experience, including paediatrics, accident and emergency, and medicine and surgery.
  • Application: You can apply for AMDS at any time through an AMDS accredited practice after you have received a job offer. The practice will need to be accredited through AMDS – a practice that operates in the after-hours but is not accredited with AMDS will not be accepted in an application. Essentially, all AMDS clinics are after hours, but not all after hours clinics are AMDS. So make sure you check!
  • Fees: There is no cost associated with AMDS.

Important to Note: Becoming an Australian Permanent Resident / Citizen DOES NOT negate the 19AB / DPA requirement that all doctors who completed their degrees outside of Australia, or who were not residents when they completed their Australian degrees are also restricted by. Some of the 3GA programs also have specific 19AB requirements linked to them.

So, what now?

This, all in all, is a brief summary of this part of the health act. The aim is to encourage people into rural areas and give them the tools and the support to provide great healthcare. The issue is that when you put it into practice – people have set up their lives somewhere and relocating can be challenging and frightening.

It’s important to look at your options and make a decision based on what is best for you and your family. Don’t be afraid of change, because you never know what amazing things and new friendships you can build in our rural areas.

There are lots of people here to help take you through the options and we will wait patiently whilst you decide what it is that you want to do.

Need help with your application documents or have more questions? Email us at help@peoplemedical.com.au and we can help you with your concerns and documents or click the buttons below.

We Can Help You

Here at People Medical Consulting, we have a passion for guiding medical practitioners through their career pathways to Australia. We have extensive experience in assisting medical facilities in recruiting doctors from local and overseas who will best suit their requirements.

We provide Document Assistance for those requiring support for their PESCI with IME, ACRRM or RACGP, registration and all other mandatory AHPRA requirements, fellowship program related forms and letters, application for Medicare provider and prescriber numbers, application for 19AB or 19AA exemptions and preparation of employment documents.

If you’re looking for assistance, contact us at help@peoplemedical.com.au and we would be glad to help you.

Information from this blog has been taken directly from:

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