On 30 May 2025, Ahpra and the Dental and Medical Boards of Australia issued a joint statement expressing serious concern about reports of patients experiencing financial harm after accessing substantial superannuation funds for treatment. Practitioners were warned that inappropriate involvement in CRS processes would attract regulatory action.
Legal Isn’t Always Ethical
Providing factual clinical support for CRS applications is not improper, but where practitioners cross into facilitating applications, requesting myGov credentials, or tying treatment plans to super access, ethical and legal lines may be crossed. These situations raise issues around informed financial consent, patient vulnerability, privacy, and clinical justification.
What Regulators Are Watching
Ahpra and the Boards have flagged specific concerns:
- High volumes of CRS support letters without proper clinical assessment
- Misleading documentation used to justify access
- Upfront payments tied to treatment funded by super
- Pressure tactics or encouragement to access CRS
- Requests for patient myGov login details
Ahpra’s CEO was clear: “Practitioners are on notice that we will take action to protect the public.”
Key Standards at Stake
Under the Dental and Medical Board Codes of Conduct, and the ADA Code of Ethics, practitioners must:
- Act in the patient’s best interests, not for personal gain
- Provide treatment that is evidence-based and clinically appropriate
- Ensure financial consent is clear, informed and documented
- Maintain patient privacy and respect boundaries, especially around financial information
Practical Risk Management
To avoid regulatory and reputational risk, practices should:
- Avoid handling CRS applications – Provide factual reports only. Do not log in or complete applications.
- Never request myGov credentials – This raises serious privacy and security concerns.
- Ensure clear financial consent – Provide written estimates with all fees, payment options, and refund terms.
- Separate clinical advice from financial matters – Don’t suggest CRS as a solution or tie it to treatment decisions.
- Review marketing and communication – Eliminate upselling, urgency-based tactics, or language that implies super access is expected.
A Time to Review and Reset
Now is the time for practices to pause and ask:
- Are your consent and billing processes robust?
- Do staff understand the limits of your role in CRS?
- Is your documentation defensible under scrutiny?
Patients accessing super are often financially and emotionally vulnerable. Practitioners must take care not to steer those decisions, directly or indirectly.
Conclusion
Health practitioners who maintain ethical, transparent, and well-governed systems have little to fear from increased scrutiny. But those who conflate care with commercial interests, or blur the line between clinical and financial involvement, do so at considerable risk.
