19AA Follow Up

Last year, we wrote a blog about 19AA and the 3GA programs. If you missed that one, it is a good idea to do a recap prior to reading this one as potentially this one will not make as much sense if you haven’t. It can be found here: https://peoplemedical.com.au/19aa-oh-how-you-surprised-us-2/

In a nutshell, 19AA of the Health Insurance Act 1973 was introduced in 1996 to recognise and support general practice as a vocational specialty, as well as to provide a framework for achieving long term improvements in the quality of doctors working in Australia.

All medical practitioners are subject to restrictions of section 19AA of the Act if they:

  • held medical registration by an Australian Medical Board on or after 1 November 1996 and
  • are Australian permanent residents or Australian citizens and
  • do not hold continued recognition by the Royal Australian College of General Practitioners or the Australian College of Rural and Remote Medicine, or by a recognised specialist college.

Basically, 19AA requires any Non-Vocationally Registered (Non-VR) Australia permanent resident or citizen to be registered on an approved 3GA program to be able to gain access to Medicare benefits.

This restricts both people born in Australia and those who have become Australian.

Remember, this is only if you want to claim Medicare benefits.

We have been getting a lot of questions recently about doctors who need to work with the system to work in General Practice, and so this blog is addressing the most common situations we’re seeing. These are:

  • I’m looking for my first job in Australia, I’m a PR/Citizen, but I have less than 2 Years GP experience. What do I do?
  • I’m living in the city and I don’t want to move rural. I’m a PR/Citizen, what do I do?
  • I’m seeking my first job in Australia and I’ve been offered a job after hours- will this fulfil my 19AA criteria?
  • I think I’m eligible for an exemption from 19AA- how do I know?
  • My spouse is a skilled migrant, can I get a 19AA exemption?

Keep in mind these are just the common questions we get, and we thought it might be helpful to clarify. Every situation can be a little different, so don’t hesitate to contact us if you’re not sure or want clarification. That is what our team is here for!


I’m looking for my first job in Australia, I’m a PR/Citizen, but I have less than 2 Years GP experience. What do I do?

Your options are going to require you to step into the hospital system, and work towards gaining General AHPRA Registration. Once you have this, you can look at the following options:


AGPT – Australian General Practice Training

This program has an intake in April each year, with results released in August and commencing the following January. It is a 4-year program; however, you can get RPL for the first year. You should look at the eligibility and plan your path before you start the journey.

Link: http://www.agpt.com.au/Junior-doctors/Australian-General-Practice-Training–AGPT–program/New-Applicants/Eligibility


ACRRM Independent Pathway

This program requires you to complete a “RPL” or “recognition of prior learning” before applying to be on the program. The program itself is quite expensive, however the training you get and the access to support is exemplary. This pathway encourages you not only to become a GP fellow but to become more of a GP proceduralist. There are two intakes for this program each year. Check the link out for more information.

Link: http://www.acrrm.org.au/training-towards-fellowship/overview-of-fellowship-training/pathways/acrrm-independent-pathway/eligibility


RLRP-Short Term

At this stage, only NSW & VIC provide a detailed short term RLRP program for those doctors who do not meet the 2 years of GP experience assessed requirement. Both states have different requirements however both agree that you should have 2 years Australian hospital experience. Both programs have the expectation that you will enter AGPT, ACRRM IP or RVTS at the end of the program.


AMDS- Clinic Based

A doctor who has not worked in Australia is most likely to get Level 1 or Level 2 Supervision, which does not allow doctors to provide on call services. However; a clinic based AMDS will provide access to a 3GA program and some may provide supervision to you. Be aware that a clinic that is open after hours, is not necessarily an AMDS clinic. This is an individual and specific accreditation that the practice must apply for.


I’m living in the city and I don’t want to move rural. I’m a PR/Citizen, what do I do?


If you hold General AHPRA Registration, you can work for either a clinic based or on call doctor service. On call GP work is considered 50% of the actual time worked (so if you work for a year, it will be assessed by RACGP as 6 months) however you can have up to 2.5 years of GP time assessed of After Hours. You will still require a minimum of 6 months Australian based in-hours experience however.



This program is for extenuating circumstances. We’re talking circumstances in the form of a life threatening medical condition, or a court order. Family circumstances aren’t considered. This is a very difficult program to get onto and you need a very good reason to use it.


ACRRM Independent Pathway

Take a look at the above paragraph about this program. To add to this, there is no guarantee that you will be able to stay in the city with this program. You must meet various requirements and if your RPL does not demonstrate you’ve completed your rural component, you will have to go rural.

Doctors, we understand that you make a life where you are, that jobs for partners in regional areas aren’t always easy to get or possible to get. We understand that the resources and facilities may not be the same or that there may be a fear of what rural really means. Sometimes, though, you need to make the choice of whether living in the city is most important to you, or whether you want to be a GP. We know it isn’t fair however unfortunately- that is the system that we are working with.

I’m seeking my first job in Australia and I’ve been offered a job after hours- will this fulfil my 19AA criteria?

It is important to make the distinction between working after hours and a 3GA accredited clinic. After Hours, does not always mean “AMDS” and it must be AMDS to meet the 3GA requirements. Your clinic will know if it is an AMDS- ask before you sit for your PESCI.


I think I’m eligible for an exemption from 19AA- how do I know?

There is only one exemption from 19AA, which is SAPP (Special Approved Placements Program). As we’ve said above, this is an incredibly hard program to get onto. More info can be found in the link: http://www.health.gov.au/internet/main/publishing.nsf/Content/special-approved-placements-program


My spouse is a skilled migrant, can I get a 19AA exemption?

No. A “spousal exemption” gives you an exemption from 19AB, requiring you to work in a DWS. If you are also restricted by 19AA, you will be required to meet 19AA regardless of your spouse.


Changing from PR to 457

As 19AA only affects permanent residents and citizens, you may consider returning to a temporary visa. There are some circumstances where a permanent resident can apply for a temporary visa although unfortunately this is not possible for citizens. This should only be looked at as a very last option, as it is not a usual process with the department and could be quite a costly exercise for you. You would need to apply for a 457 visa (or another temporary visa that you are eligible for), which cannot be done online so you would first need to seek permission from DIBP to lodge the application, be provided with the form and then lodge it via a paper application. When you later achieve your fellowship, you would need to reapply for permanent residency and there is no guarantee that you would be eligible for PR again later down the track. Make sure you speak to a registered migration agent or lawyer prior to making this decision.


Working without accessing Medicare

19AA refers to doctors accessing Medicare benefits. A General Practitioner can work without accessing Medicare- it means patients won’t be able to claim a rebate as well.



Doctors, I have a lot of you telling me that it is not fair- that you are being punished for showing your dedication to Australia and becoming PR / Citizen. Remember that this also affects doctors who are born in Australia as well.

The point of the act is to ensure that doctors are working towards achieving their fellowship, and that they have the support they need to practice.

A question I often ask my doctors, is that if you’ve not worked as a General Practitioner before, or only for a short time, how can you ensure that you are providing quality medicine when you are in a brand-new health system, on your own? The training programs are designed to support you and to ensure you have a good mentor onsite so that you learn the Australian health system and you are safe and secure in your practice. This is for your benefit, as well as the benefit of the clinic and most importantly- your patients.

Returning to the hospital system may seem like a step back, but recognise it for what it is- the opportunity to have a supported step into the Australian healthcare system.

While it is challenging to get offered a job in the hospital it is not impossible- our Facebook lights up each day with doctors who have succeeded in gaining a job offer and who are asking for our help with their paperwork.

Persevere, keep your hope and do not give up.

MARA 1678793

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