Understanding the 10 Year Moratorium for IMGs in Australia

What Is the 10-Year Moratorium?

The term “10-year moratorium” refers to Medicare billing restrictions imposed under Section 19AB of the Health Insurance Act 1973.

The legislation applies to:

• Overseas-trained doctors (OTDs)
• Foreign graduates of accredited medical schools (FGAMS)

If you fall into either category, you cannot automatically access a rebatable Medicare provider number. Instead, you must satisfy specific legislative requirements before you can bill Medicare for professional services.

Importantly, the moratorium does not prevent you from practising medicine. Many IMGs are fully registered with the Medical Board of Australia and legally able to work. The restriction relates specifically to accessing Medicare rebates, which is fundamental to many senior medical positions across Australia.

Why Medicare Provider Numbers Matter

Medicare is Australia’s publicly funded healthcare system. A rebatable Medicare provider number allows doctors to bill Medicare for professional services provided to eligible patients.

Without a rebatable provider number:

• You will not be able to bill patients through Medicare
• Employers may not be able to generate income from your clinical work
• Certain roles may become financially unviable

Doctors may still receive a Medicare provider number that is limited to “refer and request” functions. This allows them to request pathology and diagnostic imaging and refer patients to other practitioners, but not claim Medicare rebates for the services they personally provide.

This is why Medicare eligibility is such a major consideration for internationally qualified specialists and GPs.

The Legislation Behind the Moratorium

Although commonly referred to as the 10-year moratorium, the legal framework is broader than a single rule.

Two sections of the Health Insurance Act 1973 govern Medicare eligibility for many IMGs:

• Section 19AB, which imposes Medicare restrictions on overseas-trained doctors and foreign graduates.
• Section 19AA, which places additional Medicare eligibility requirements on many doctors once they become Australian permanent residents or citizens.

Understanding how these two provisions interact is essential when planning your career in Australia.

Section 19AB – The 10 Year Moratorium

Section 19AB restricts access to rebatable Medicare provider numbers for 10 years from the date of your first medical registration in Australia.

During this period, doctors generally require an exemption before they can access Medicare billing rights. The most common exemption is working in an approved workforce shortage location. 

For General Practitioners, this usually means practising in a Distribution Priority Area (DPA). 

For Specialists, it generally means working within a District of Workforce Shortage (DWS).

These workforce distribution programs are designed to direct medical services towards communities experiencing shortages of healthcare professionals.

IMGs who remain temporary residents continue to be subject to Section 19AB indefinitely. This restriction remains regardless of whether specialist registration has been obtained.

Understanding Section 19AA – Medicare Eligibility After Permanent Residency

Section 19AA applies broadly to doctors who first registered to practise medicine in Australia on or after 1 November 1996, unless they:

• hold specialist registration; or
• are participating in an approved training or workforce program.

Many IMGs initially arrive in Australia on temporary visas and are subject only to the restrictions imposed by Section 19AB. However, once they become Australian permanent residents or citizens, they must also satisfy the requirements of Section 19AA.

If you become an Australian permanent resident or citizen and do not yet hold specialist registration, you will usually need to participate in an approved Section 3GA training or workforce program at an eligible location to maintain access to rebatable Medicare provider numbers.

Importantly, Section 19AB does not cease to apply. The 10-year moratorium continues to run until 10 years have elapsed from the date of first medical registration in Australia.

How Sections 19AA and 19AB Work Together

One of the most common misconceptions is that obtaining Australian permanent residency removes Medicare restrictions.

In reality, many IMGs become subject to both legislative provisions simultaneously.

For example:

• An IMG arrives in Australia on a temporary visa and is subject to Section 19AB.
• After several years they obtain permanent residency.
• Section 19AA now also applies.
• Unless they already hold specialist or GP recognition, they generally need to participate in an approved Section 3GA program to maintain Medicare eligibility.
• Meanwhile, the original 10-year moratorium under Section 19AB continues until the full 10-year period has expired.

Rather than replacing one another, Sections 19AA and 19AB often operate together.

Why Does the Moratorium Exist?

The policy was introduced to address unequal distribution of the medical workforce across Australia.

Historically, both Australian-trained and overseas-trained doctors tended to concentrate in metropolitan areas such as Sydney, Melbourne and Brisbane, while many regional, rural and remote communities experienced ongoing doctor shortages.

The policy was introduced as part of a workforce distribution framework aimed at improving access to medical services in underserved communities. Today, workforce planning continues to rely heavily on designated shortage locations.

Where can IMGs Work?

The most common way IMGs obtain access to a rebatable Medicare Provider Number during the moratorium is by working in an approved workforce shortage location.

Distribution Priority Areas (DPA)

Distribution Priority Areas are primarily relevant for General Practitioners.

A DPA is a location where the availability of GP services is considered insufficient to meet community needs.

GPs who are subject to the 10-year moratorium generally need to work in a DPA-approved location to obtain a rebatable Medicare provider number.

Districts of Workforce Shortage (DWS)

Districts of Workforce Shortage are primarily relevant for specialist medical practitioners.

A location receives DWS status when there is an identified shortage of a particular specialty relative to the healthcare needs of the local population.

Specialists working within eligible DWS locations may qualify for Medicare provider number access despite remaining under the moratorium.

Because workforce shortages change over time, both DPA and DWS classifications are regularly reviewed by the Australian Government.

While DPA and DWS pathways are the most common, other exemptions may be available depending on individual circumstances.

These can include:

• approved workforce programs
• Section 3GA training pathways
• academic appointments
• spousal provisions
• other legislative exemptions.

Eligibility varies considerably, making individual advice important before accepting employment. 

There are also certain positions where Medicare billing is less relevant, and a provider number may not be required. For more detailed information on DWS and DPA read our guide.

Key Takeaways

The 10-year moratorium is often viewed as a barrier to practising medicine in Australia. In reality, it is a workforce distribution policy designed to improve access to healthcare in communities with the greatest need.

For most IMGs, the legislation does not prevent them from practising – it influences where they can work and how they access Medicare benefits.

Understanding the interaction between:

• Section 19AB
• Section 19AA
• Distribution Priority Areas (DPA)
• Districts of Workforce Shortage (DWS)
• Section 3GA training pathways

is essential for making informed decisions about employment, specialist training and long-term career planning.

Every doctor’s circumstances are different. Visa status, registration pathway, specialty, permanent residency and workforce location can all affect Medicare eligibility.

If you’re unsure how the 10-year moratorium applies to you, our team can help you understand your options and identify suitable opportunities across Australia. Contact us today for a confidential discussion.

About the Author 

Hayley has over a decade of experience in medical recruitment, where she has developed a deep expertise and understanding of the unique challenges and complexities that doctors face when relocating to Australia. Assisting in permanent, fixed-term, and locum placements across all medical specialties, she guides doctors through the complex journey of regulatory and migration processes, ensuring each candidate has a smooth transition into their new role.