The lowdown on 19AB, DPA, DWS, MMM and Scaling

Your guide to Medicare jargon and restrictions under the Health Insurance Act 1973

5 min | Medical Careers

Obtaining a visa and medical registration in Australia means entering a world of acronyms! With different rules, and regulations depending on where, when and how you completed your medical training, and where and how you’re planning to work in Australia, it’s a lot to get your head around. 

Our resident Regulatory Consultant Ebony Kouka is here to help translate the jargon and get you on the path to your dream medical career in Australia. 


Which one am I - An OTD, IMG or FGAMS? 

Overseas Trained Doctors (OTDs) and International Medical Graduates (IMGs) have the same definition. That is, you did not complete your primary medical degree in Australia or New Zealand. 

You’re a Foreign Graduate of an Accredited Medical School (FGAMS) if you completed your primary medical degree in Australia or New Zealand as a temporary resident. 


What is 19AB and who does it affect?  

IMGs/OTDs and FGAMs are restricted under section 19AB of the Health Insurance Act 1973. That means, to receive Medicare benefits, you must work in a Distribution Priority Area (DPA) if you’re a GP, or a District of Workforce Shortage (DWS) if you're a non-GP specialist, for up to 10 years from the date you first received medical registration in Australia. This restriction is generally referred to as the ‘10-year moratorium requirement’. 

If you’re working in the public system, you can work anywhere in Australia, as these restrictions only relate to private billings. However, some public hospitals will still require you to have access to Medicare benefits to enable you to work with private patients within the public system.  


What is DWS and DPA? 

The DWS and DPA are classification systems that identify locations in Australia with a shortage of medical practitioners. This is determined on a national level and involves calculating things such as Medicare billings by age demographics, socio-economic status, and the remoteness of the location. 

DPA and DWS locations are reviewed and updated yearly by the Department of Health (DoH).  


What does MMM mean? 

MMM stands for Modified Monash Model which is another type of classification system used to identify whether a location falls into the categories of city, rural, remote, or very remote. The model measures remoteness and population size on a scale of MM1 (major city) to MM7 (very remote). 

 You can check the DPA, DWS and MMM status of a location by using the Health Workforce Locator. 


Can I be exempted from having to work in a DPA/DWS location? 

There are various exemptions available under section 19AB, each with specific eligibility criteria and evidence requirements. Refer to this list for details on available exemptions. 


Is it possible to fast-track the 10-year moratorium? 

Yes! You can decrease the amount of time you have to work in a DPA/DWS by up to five years. This can be done through scaling. Working in remote locations grants you scaling credits’. Put simply, the more remote the area you work in, the more scaling credits you are eligible for.  


What are the eligibility requirements for scaling? 

IMGS/OTDS and FGAMS can reduce their 10-year moratorium through scaling if all the following apply: 

  • You are working in an eligible regional or remote area under section 19AB. 
  • You are claiming Medicare benefits for services as part of your employment. 
  • Your monthly billing threshold is $5,000. 

Once you've submitted your Medicare billing data and reached the threshold, scaling credits are automatically applied by Medicare. 


How does the scaling system work? 

The Australian Statistical Geographical Classification – Remoteness Area (ASGC-RA) is used to calculate the scaling credits as follows: 



Monthly scaling benefit (where billing threshold is met) 

Reduced moratorium period 

RA 1 

Major cities 


Not reduced 

RA 2 

Inner regional 

3.37 days 

9 years 

RA 3 

Outer regional 

13 days 

7 years 

RA 4 


20.3 days 

6 years 

RA 5 

Very remote 

30.4 days 

5 years 


You can check the ASGC-RA classification of a location by using the Health Workforce Locator. 


How can I keep track of my scaling credits? 

Through your Health Professional Online Services account, you can: 

  • View your current scaling credits 
  • View the date you are eligible for the class exemption from 19AB 
  • Check the end date of your moratorium. 


What happens when I complete the 10-year moratorium? 

To satisfy the moratorium requirement and become unrestricted, you need to:

  1. Have held AHPRA registration for up to 10 years (you do not need to have worked for the whole 10 years and this period may be reduced through scaling as above-mentioned)
  2. Have become an Australian citizen or Permanent Resident

Only once both criteria are satisfied will you become unrestricted, meaning that you can work and bill anywhere in Australia.


What if I become an Australian Citizen or Permanent Resident before I complete the 10-year moratorium? 

If you became an Australian Citizen or Permanent Resident before attaining vocational recognition in your specialty, you would be restricted under section 19AA of the Health Insurance Act 1973. This means your Medicare access will cease until you obtain fellowship with an Australian specialist college or are enrolled on an approved 3GA training program. 

There are no exemptions under s19AA.

Have more questions or want to know how you can work as a Medical Practitioner in Australia? 

Get in touch today. 

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