The 10-year Medicare moratorium doesn't mean rural-only. These exemption pathways let IMGs work in metropolitan areas and bill Medicare.
10 years
Medicare moratorium period
New IMGs cannot bill Medicare in metro areas for 10 years — unless they work in Distribution Priority Areas (DPAs) or qualify for exemptions.
6
Exemption pathways available
Multiple exemption categories allow IMGs to work in cities like Sydney and Melbourne while billing Medicare — even during the 10-year moratorium.
Where IMGs can work without exemptions
Distribution Priority Areas are locations identified by the government as having a shortage of doctors. IMGs can work in these areas and bill Medicare without needing an exemption. DPAs include most of regional and rural Australia, plus some outer metropolitan areas.
Use the official Health Workforce Locator to check if a specific address or postcode is classified as a DPA. Classifications can change annually, so always verify before making decisions.
Health Workforce Locator →Each exemption has specific eligibility requirements
Work evenings, weekends, public holidays in any location
Work evenings (after 6pm), weekends, and public holidays in any location — including Sydney, Melbourne, and Brisbane — and bill Medicare. Most popular exemption for IMGs wanting to work in metro areas.
Exemption based on spouse employment location
If your spouse works in a specific location, you may qualify to work in the same area regardless of DPA status.
For approved academic positions
Available for IMGs in recognised academic or teaching roles at universities or teaching hospitals. Must be approved by Services Australia.
Fellowship programs and supervised positions
Includes certain fellowship programs, supervised training positions, and approved medical placements.
Short-term locum work
Available for short-term locum contracts, whether through a locum agency or direct placement arrangements.
Exemptions for specific circumstances
Rare exemption for unique situations where restricting an IMG would not be in the public interest.
Most IMGs use the after-hours exemption to work in metro areas. You can bill Medicare for consultations after 6pm on weekdays, all day on weekends, and on public holidays — in any location including Sydney, Melbourne, Brisbane, and other major cities.
Important distinction: The after-hours exemption solves Medicare billing access in metro areas — it does not unlock the AGPT General Pathway. Only a spousal exemption enables AGPT General in MM1 locations. After-hours work also does not count toward GP fellowship training hours (RACGP Standards 4th Ed). For GP training, you need minimum 14.5 daytime hours/week at an approved practice.
Doctors on the workforce track (Limited Registration, Area of Need) also interact with Section 19AB, but access different Medicare items than GP-track doctors.
MP items, not GP items: Workforce doctors bill using Medical Practitioner item numbers (52-65 series) rather than the GP items (23, 36, 44 series). The after-hours exemption still applies, but to the MP item set.
Timing nuance — 19AB window ≠ MBS loading: The 19AB after-hours exemption window (when you can bill Medicare at all) is not the same as the MBS after-hours loading periods (when items attract higher rebates). There can be gaps where Medicare access exists but after-hours loading does not apply, or vice versa. Always confirm specific billing windows with Services Australia.
Area of Need and 19AB: Workforce doctors typically require an Area of Need designation to obtain Limited Registration. The 19AB exemption is a separate requirement for Medicare billing access. Both must be in place to bill Medicare in metropolitan areas. In DPA locations, 19AB exemption may not be needed.
Use our interactive explorer to see which exemptions apply to your situation.
This estimate is indicative only. Individual circumstances vary. Confirm with official sources before acting.