19AB & IMGs | DWS / DPA | 10 Year Moratorium

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Date Updated: 2026-10-07

This blog is to help you understand what 19AB is, what DPA is, how to reduce your 10 year moratorium and what exemptions there are from the 19AB restrictions.

What is the 19AB Restriction?

Under 19AB of the Health Act, medical practitioners who didn’t complete their degree in Australia or New Zealand to work in a Distribution Priority Area (DPA) for 10 years to allow their patients to receive Medicare rebates. This requirement is known as the 10-year moratorium.

Basically—if you want your patients to get a rebate from Medicare and you did not complete your degree in Australia or New Zealand, this 19AB requirement applies to you!

Who is restricted by 19AB?

Medical practitioners who did not complete their degree in Australia or New Zealand, and who wish to access Medicare rebatable services will be restricted.

It will also apply to Doctors who enrolled into their degree in Australia whilst they were a temporary resident.

What does DPA mean?

DPA stands for Distribution Priority Area.

This is an area where the general population’s need for medical services is not being met and they require more GPs within the area.

The classification of DPA areas is updated yearly and these changes are implemented in the first few months of the year.

If you need to check the DPA status of a practice or area, you can do so at the Health Workforce Locator See how to check the Health Workforce Locator here.

How is DPA Location determined?

The DPA system takes into account the level of Medicare billed GP services patients received, gender and age demographics, the remoteness of the area (MMM classification), and the socio-economic status of patients living in an area.

An area is automatically classified as DPA when it is:

classified under the Modified Monash Model (MMM) as MM 2 to 7
in the Northern Territory

Other areas are classified as DPA when the level of health services available to the population does not meet a service benchmark.

Reducing or ‘Scaling Down’ the 10 Year Moratorium

There are two ways to reduce your moratorium.

Scaling means that the more rurally you work, the quicker your moratorium reduces. This works on the RA model rather than the MMM model. To be eligible you’ll need to have a rebatable provider number and be billing over $5000/month. See the table below.

Once you have submitted your Medicare billing data and reached the threshold, Medicare automatically applies scaling credits. You can check your scaling status through your Health Professional Online Services (HPOS) account. Please note that you will not be eligible to the 5-Year IMG Recruitment Scheme if you receive scaling credits.

The 5-Year IMG Recruitment Scheme, previously the 5-year OTD Scheme, is an initiative initiated by the Rural Workforce Agencies that lets you reduce your moratorium time by working in an eligible rural area for a certain duration or obtaining permanent residency and Fellowship during your time on the program. You will also reduce your moratorium to between 3 – 5 years based on what category you’re eligible for.

Category A is for MM 5 – 7 locations that are exceptionally difficult for GP recruitment and retention. This will reduce your moratorium to 3 years.
Category B is for practices who are in an MM 4 – 7 that are experiencing very difficult GP recruitment and retention. This will reduce your moratorium to 4 years.
Category C is within locations which are MM 2 – 7 and can demonstrate difficulty with GP retention and recruitment. This will reduce your moratorium to 5 years.

To be eligible, you’ll need to:

Hold or obtain appropriate registration with the Medical Board of Australia
Able to obtain a Medicare provider number at the required location
Intend to seek or currently possess Australian permanent residency and/or citizenship
Will provide at least 7 sessions a week as part of their placement (in a MM 2 – 7 location, depending on the category)
Intend to join or are currently participating in a training program which will enable them to gain specialist registration in general practice while working in the chosen practice for the length of their Scheme agreement

Please note that working on this scheme will make you ineligible for the scaling credits which means you do one or the other. If you start the 5-Year IMG Recruitment Scheme, prepare to be there for the entire time required!

How to know when your moratorium ends?

You can call Medicare, email the team at 19AB, or check your PRODA account.

To view your moratorium scaling in your PRODA account, login into your PRODA account, and select ‘Track and Scale’ from the main menu. You will then need to select ‘Track and Scale – scaling details’ to see more information. Read more here.

19AB Exemptions

Unlike 19AA, you can receive an exemption from 19AB and be allowed to work in a Non-DPA area.

There are various 19AB exemptions, so it is important to check your eligibility. We have outlined the available exemptions below:

Locum Exemption

A Locum Exemption will be available if you are providing locum services at a practice.

You will be granted a 19AB exemption for the practice for a maximum of 6 months, as long as you have not previously provided services at the practice. After 6 months, you can commence locum services in another practice or change to a DPA practice.

Replacement Exemption

If you replace a doctor that had an unrestricted 19AB exemption, leaves the practice/area and closes their Medicare Provider Number, you are allowed to have a Replacement Exemption.

In applying for a Replacement 19AB Exemption, we suggest that the leaving doctor to sign a written statement or statutory declaration stating that:

they have closed their provider number for that location
they are leaving the catchment area
will not be using a Medicare provider number that has been issued to them in that catchment area until their 10-year moratorium has ceased.

Spousal Exemption

You will be eligible for a spousal exemption if your partner is a medical practitioner that is not restricted by 19AB or if your partner is a skilled migrant.

To be granted a Spousal Exemption you will need to be working within a close proximity to your partner- the same Catchment area from the Health Workforce Locator Map is a strong indicator of success.

Prior Employment Negotiations

If you have commenced negotiations for employment at the practice prior to the area losing DPA status, you will be eligible for a 19AB exemption. For this, you will need to provide proof to Medicare of the negotiations.

After Hours Exemption

If you are working in an after-hours clinic or during the after-hours periods only, you will be eligible for a 19AB exemption during these periods. This means you will be able to work between 6pm and 8am Monday to Friday, and any time Saturday, Sunday and public holidays.

Discretionary Exemption

You will be eligible for Discretionary Exemption which allows you to access to Medicare benefits in any location if you have medical reasons or exceptional circumstances, specifically:

medical reasons – if you are the primary carer for a close family member who has a serious medical condition that can’t be managed in a DPA location
exceptional circumstances – an unforeseen, unavoidable and uncommon event, such as border restrictions related to the COVID-19 pandemic.

Academic Exemptions

You will be eligible for an Academic Exemption if you:

Have satisfied the 19AA requirements
Have an academic appointment with an Australian medical school, and
Perform clinical services as part of your academic appointment

Please note that this does not apply to private practices without teaching responsibilities.

Other circumstances that can be considered as an exemption:

Unrestricted exemption for the same DPA/DWS catchment
- If you hold an unrestricted exemption for one practice, you can apply for access to Medicare benefits when working in other practices within the same DPA catchment.

Competent Authority Pathway exemption
- This exemption allows you to access Medicare benefits in the DPA locations (unless there’s exceptional circumstances) listed on your AHPRA registration if you are on the: Competent Authority Pathway, Specialist Pathway – area of need, or Specialist Pathway – specialist recognition.

Exemption following completion of a 3GA Program
- This exemption allows you to access Medicare benefits in any location if you continue to work at the practice where you obtained your Fellowship. You must have provided at least 12 months of continuous service at that practice and have obtained your Fellowship through an approved training or workforce program.

Who can apply?

The 19AB restrictions disable the access to Medicare benefits of a doctor who attained their medical degree in any country aside from New Zealand and Australia or a temporary resident who is currently studying to gain a medical degree in the country.

According to the Department of Health, you can apply for an exemption if you:

are employed in a Distribution Priority Area (DPA)
- See how to check the Health Workforce Locator here.
are on an approved workforce or training program
are employed at any area after regular hours which is specified as 6pm to 8am on a weekday, or any time on a weekend and public holidays

How do I apply?

To apply for 19AB exemptions, you should first complete the Medicare provider number application and attach supporting documents for the exemption.

Be aware of the different types of exemptions also since the new regulations state that certain exemptions must be given to 19AB while others go through Services Australia.

Where do I apply?

If you are applying for Spousal and Discretionary exemptions, you must submit your application to 19AB@health.gov.au with:

Spousal exemption: Spousal exemption application form
Discretionary exemption: An evidence of caring for an immediate family member with a medical condition requiring them to be in a metropolitan area or an evidence that the COVID-19 pandemic has affected a doctor’s ability to meet section 19AB requirements.

If you are applying for the other types of exemptions, you should send your application to provider.registration@servicesaustralia.gov.au.

Outcomes of the 19AB exemption applications will be provided within 28 days. For reconsiderations on the declined requests, you have 90 days to send your additional documents, reasons on why you should be exempted, and new information to support your exemption via email at 19AB@health.gov.au or directly contact the Department of Health for a review.

When can I apply?

Since your request for exemption is submitted along with your Medicare provider number application, you can apply when the application for Medicare provider number is open. Read more about the application of Medicare provider numbers here.

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 want to talk to someone about your pathway or practice management—book a consultation with us below, or if you need Recruitment or Document Assistance, contact us at help@peoplemedical.com.au or click the buttons below. We’d be glad to help you!

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Information from this blog has been taken directly from: