The Bottom Line
- 19AA is the “who can bill Medicare” rule (specialist registration / working towards it).
- 19AB is the “where you can bill Medicare” moratorium for OTDs/FGAMS (typically DPA/DWS) for ~10 years.
- For GPs, “DPA” is the map you live or die by; check it before signing anything.
- A spousal exemption is real — but it is discretionary, location-specific, and paperwork-heavy.
Think of it like this
19AA determines whether you can access Medicare benefits at all (eligibility). 19AB determines where you can access Medicare benefits (geography) until your moratorium is completed. Many IMGs are subject to 19AB; Australian citizens/permanent residents without the right pathway can still be caught by 19AA.
The 10-year moratorium (19AB) applies to overseas trained doctors and foreign graduates of an accredited medical school who want to provide Medicare-rebatable services. In plain terms: you may be clinically able to work anywhere, but you cannot “bill Medicare” everywhere until you complete the moratorium — usually by working in priority locations. For general practice, those priority locations are defined using Distribution Priority Area (DPA) classification; for other specialties, similar shortage concepts are used (e.g., DWS depending on role/specialty).
Common failure mode
The classic disaster is signing a lease near a “great practice” and only later learning the site is not eligible (or no longer eligible) for your restriction category. Make DPA/DWS verification a pre-condition of committing financially.
Spousal exemptions exist under 19AB(3) and are intended to allow a restricted doctor to work at a specific practice location near a spouse’s primary place of employment (where criteria are met). This is not a blanket “free pass”: it is tied to a location, requires documentation, and is evaluated against eligibility criteria. If you are planning family-based location constraints (e.g., metro), treat the spousal exemption process as a formal project: evidence pack, timelines, and a backup plan.
Your “evidence pack” checklist (spousal exemption)
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