Updated Medicare Assignment of Benefit requirements came into effect on 1 July 2026.
These changes are relevant to dental practices that bulk bill eligible Medicare services, particularly services provided through the Child Dental Benefits Schedule, or CDBS.
What is an Assignment of Benefit (AoB)?
When a dental practice bulk bills a Medicare service, the patient assigns their Medicare benefit to the treating provider.
This means Medicare pays the benefit directly to the provider, and the provider accepts the Medicare benefit as full payment for that service.
The practice must have the patient’s agreement before submitting the bulk-billed claim. The claim itself is not sufficient evidence that the patient agreed to assign their benefit.
What has changed?
From 1 July 2026:
- The assignment agreement can be completed before or after treatment.
- Consent can be obtained electronically or on paper.
- Practices are no longer required to use an approved Medicare Assignment of Benefit form, provided their own agreement contains all required information.
- The practice must retain a copy of the completed agreement for two years from the date the claim is made.
- The previous “patient unable to sign” option is no longer accepted.
- Patients do not automatically need to be given a copy of the agreement, but the practice must provide one if the patient requests it.
The patient’s assignment must still be obtained before the Medicare claim is submitted.
What does “before or after treatment” mean?
Practices now have more flexibility around when consent is collected.
For example, a patient or parent may agree to the assignment:
• through an online form before the appointment
• while completing digital registration forms
• at reception before treatment
• through an EFTPOS terminal after treatment
• through a digital or paper form after the appointment
However, the completed assignment must be obtained before the practice submits the bulk-billed claim.
This means a practice cannot simply process the claim and try to obtain consent later.
Digital consent options
Electronic assignment may be obtained through:
• an email containing the assignment details, with the patient or parent responding to confirm agreement
• practice booking or registration software containing the required assignment information
• an SMS containing a link to an online assignment form
• a digital form where the patient or parent selects a checkbox to confirm agreement
• an electronic signature
• Medicare Easyclaim, where the patient or responsible person presses OK or YES on the EFTPOS terminal
The practice must be able to retrieve evidence of the agreement if it is later audited. Simply placing a general consent clause in the practice’s terms and conditions may not be sufficient unless the required assignment information is clearly provided and the patient actively agrees to it.
Can practices still use paper forms?
Yes.
Practices can continue using:
• the standard Services Australia Assignment of Benefit forms
• forms generated through practice management software
• the Medicare Online bulk-bill voucher
• the HPOS Assignment of Benefit form
• a practice-created paper form containing all required information
The approved Medicare forms are no longer mandatory, but they remain available and may be the safest temporary option while practices confirm that their software and customised forms meet the new requirements.
Who should provide consent for a child?
The person assigning the benefit is known as the assignor.
For a child receiving CDBS treatment, this will usually be the parent, guardian or another responsible adult who would otherwise have incurred the cost of the service.
A responsible person may include:
• a parent or guardian
• a person holding power of attorney
• a person holding a guardianship order
• next of kin
• another appropriate adult responsible for the patient
The treating dentist and members of the dental practice team cannot assign the benefit on behalf of the patient.
What if the patient or parent cannot sign?
Practices should no longer select or record “patient unable to sign.”
Where the patient cannot provide consent, an appropriate responsible person may be able to agree on their behalf.
If neither the patient nor an appropriate assignor has agreed, the assignment remains incomplete and the practice should not submit the service as a bulk-billed claim.
Temporary verbal consent arrangements
A 12-month transition period began on 1 July 2026.
During this transition, verbal assignment is being permitted where physical or electronic agreement cannot be obtained.
When using verbal agreement, the practice must:
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Explain the assignment details to the patient or responsible person.
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Confirm that they agree to assign the Medicare benefit.
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Enter “assignor verbally agreed” in the assignor signature field.
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Send the completed agreement electronically to the patient.
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Retain a copy for two years.
Verbal consent is described as a temporary measure. Practices should not rely on it as their standard long-term process when digital or written consent can reasonably be obtained.
Important: bulk billing means accepting the benefit as full payment
When a service is bulk billed, the provider accepts the Medicare benefit as full payment for that particular service.
The practice cannot charge the patient an additional fee for the same bulk-billed service, regardless of how the extra charge is described.
Practices providing a combination of bulk-billed and privately billed services should ensure the patient clearly understands which services are being bulk billed and which services will attract a private fee.
What dental practices should do now
1. Contact your practice software provider
Ask your provider to confirm:
• whether the software has been updated for the 1 July 2026 requirements
• how patient or parent consent is recorded
• whether the required assignment information appears before consent is given
• where the completed agreement is stored
• whether records can be retrieved for an audit
• whether the software still uses the “patient unable to sign” option
• whether a copy can be provided to the patient on request
Do not assume an automatic software update has addressed every requirement.
2. Review the CDBS workflow
Map the process from eligibility checking through to claim submission.
Determine:
• who explains bulk billing to the parent or guardian
• when assignment consent is requested
• how consent is recorded
• who checks that the agreement is complete
• when the Medicare claim is submitted
• where the record is stored
• how the practice responds if consent is declined
There should be a clear check before submission confirming that valid assignment consent has been obtained.
3. Update forms and digital paperwork
Review:
• new-patient forms
• CDBS consent forms
• online booking forms
• treatment consent forms
• SMS and email links
• paper Assignment of Benefit forms
• front desk checklists
• Medicare claiming procedures
A general treatment consent form is not necessarily the same as an Assignment of Benefit agreement. The patient or parent must understand that they are assigning the Medicare benefit to the provider.
4. Train the front desk and clinical team
Team members should understand how to explain the process in plain language.
A simple explanation could be:
“Because we are bulk billing this eligible service through Medicare, we need your agreement for Medicare to pay the benefit directly to the dentist. There will be no additional charge for the service we are bulk billing today.”
The team should also know that consent cannot be assumed simply because the family has previously used CDBS at the practice.
5. Stop using “patient unable to sign”
Remove this option from written procedures, training documents and manual workarounds.
Where the patient cannot agree, determine whether an appropriate responsible person can provide the assignment. If valid agreement cannot be obtained, do not submit the bulk-billed claim.
6. Keep records for two years
The completed assignment agreement must be retained for two years from the date the Medicare claim is made.
Check that your document-retention process covers:
• electronic forms
• paper forms
• email confirmations
• SMS-linked forms
• Easyclaim confirmations
• verbal assignments used during the transition period
The practice should be able to produce the agreement if Services Australia conducts a compliance review.
7. Audit a small sample of claims
Select several CDBS claims submitted since 1 July 2026 and check:
• Was assignment consent obtained before the claim was submitted?
• Can the completed agreement be located?
• Does it identify the patient, provider and services?
• Was the correct parent, guardian or responsible person recorded?
• Is the consent date clear?
• Could the practice provide the record during an audit?
This will help identify gaps before they become a wider compliance issue.
8. Keep monitoring the transition arrangements
The government has announced a 12-month transition period, and further guidance may be released as the regulatory changes are implemented.
Practices should continue checking Services Australia and the Department of Health, Disability and Ageing for updates rather than treating the current verbal-consent arrangement as permanent.
Key message for practice managers
The new process offers greater flexibility, particularly through digital and pre-appointment consent.
However, flexibility does not remove the practice’s responsibility to:
clearly explain the assignment
obtain active agreement
obtain it before submitting the claim
record who provided the agreement
retain evidence for two years
ensure no additional charge is made for the bulk-billed service
Now is the time to review your CDBS workflow, speak with your software provider and make sure every team member understands the updated process.
Official references:
• Services Australia – Assignment of Benefit for bulk-bill claims
• Services Australia – New Assignment of Benefit consent requirements from 1 July 2026
• Department of Health, Disability and Ageing – Assignment of Medicare Benefits for Bulk Billing FAQs
• Medicare Benefits Schedule – Note AN.0.12, Assignment of Benefit arrangements
Disclaimer: This information is provided for general educational purposes only and is not legal, financial or Medicare claiming advice. Requirements may vary depending on your practice systems, claiming method and individual circumstances. Dental practices should review the current Services Australia and Department of Health guidance, confirm requirements with their software or claiming provider, and seek professional advice where needed.
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