← Insights / COMPLIANCE 7 min read

Medicare Assignment of Benefit: What Imaging Practices Need to Do Before 1 July 2026

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From 1 July 2026, every bulk-billed imaging service requires a signed Assignment of Medicare Benefits (AoB) agreement. The most practical place to capture that signature is check-in, before the scan happens.

The old DB4e and DB020 approved forms are retired on that date. Verbal assignment ends permanently. And unlike pathology, which gets a 12-month transition period for old referral forms, there is no transition period for imaging. Services on or after 1 July need a compliant agreement, including resubmissions and adjustments for services rendered before that date.

If your check-in process is not updated before 1 July, you are at risk of billing non-compliance from day one.

What Needs to Change at Check-in

The core change is straightforward: you need to put a form in front of the patient at check-in, capture their signature, and keep it on file.

There is no prescribed template. You can design your own form, use a Services Australia template (to be published before 1 July), or have your practice management software capture the data set electronically. What matters is that the agreement contains the required information and is signed before the patient goes through.

Most practices will use pre-service assignment at check-in. This means capturing the signature before the scan, using a “basic service description” rather than a specific MBS item number. For example, “CT of the chest” is sufficient. If the service rendered turns out to differ from that description (the referral changes, additional sequences are added), a new post-service agreement referencing the actual MBS item numbers is required.

Post-service assignment is the alternative: the signature is captured after the scan and must reference the specific MBS item numbers. Most practices will avoid this workflow because it requires a second patient interaction after the scan.

What the Agreement Must Contain

Your check-in form (paper or digital) needs to capture:

  • Patient name
  • Date of assignment
  • Assignment type (pre-service or post-service)
  • Whether the assignor is the patient or another person
  • The practitioner’s name and provider number
  • Either a basic service description (pre-service) or the specific MBS item number/s (post-service)

The practice does not need to countersign. Only the patient or their authorised assignor does.

What Counts as a Valid Signature

A physical or electronic signature is required. Verbal consent no longer counts.

Paper forms with a handwritten signature work. Electronic signatures must meet the Electronic Transactions Act 1999: they must reliably identify the person, indicate consent through a deliberate action, and be auditable. A touchscreen signature at check-in, a checkbox in a patient portal, or a typed name in a digital form would likely qualify. A staff member verbally noting consent in the record does not.

Who Can Sign on Behalf of a Patient

Not every patient can sign for themselves. If a patient is a child, elderly, incapacitated, or otherwise unable to sign, the following people can act as the assignor: a parent, carer, partner, relative, friend, or someone with Power of Attorney.

Your own staff cannot act as the assignor due to conflict of interest, unless they are also the patient’s parent or carer in a non-professional capacity. Front desk staff need to understand this before 1 July.

If Your Software Is Not Ready

Contact your practice management software vendor now and ask directly: will the system capture a compliant AoB agreement before 1 July?

If they cannot commit to a timeline, build a paper fallback. Paper forms using the new data set are legally acceptable. Digital is preferable for audit purposes, but it is not mandated. A paper process at check-in is better than a non-compliant one.

Record Keeping

Every completed AoB agreement must be retained for two years from the date the Medicare claim is made. You do not need to submit them to Services Australia routinely, but they can be requested during a compliance audit. You must provide a copy to the patient on request.

Checklist: Before 1 July 2026

  • Update your check-in process to capture a compliant patient signature before the scan
  • Confirm your AoB agreement form (paper or digital) captures the full required data set
  • Remove DB4e and DB020 forms from circulation
  • Brief front desk staff on the new process and who qualifies as an assignor
  • Confirm your software vendor is ready for the new requirements
  • Build a paper fallback if your software is not confirmed as ready
  • Set up a two-year record retention process for completed agreements

Further Information

Full regulatory detail is in the Health Insurance Amendment (Assignment of Medicare Benefits and Other Measures) Regulations 2025. Services Australia will publish example AoB agreement templates on its website before 1 July 2026. The Department of Health has also published a frequently asked questions document covering the changes in detail. For direct enquiries, contact the Department of Health, Disability and Ageing at AssignmentofBenefit@health.gov.au.


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