End-to-end help for medical centres recruiting overseas-trained doctors — AMC, Ahpra, PESCI, visa sponsorship, and the complex Section 19AB exemption pathway for practices outside Distribution Priority Areas.
The AMC. Ahpra. Home Affairs. The Department of Health, Disability and Ageing. Services Australia. Each one has its own forms, timelines, and dependencies. Done in the wrong order — and they often are — the entire process stops dead.
Even after the doctor is registered, has a visa, and is in Australia, they still cannot bill Medicare without a Section 19AB exemption granted for your specific clinic address. For practices outside Distribution Priority Areas, this is the most common point of failure.
A clinic recruits a strong overseas candidate. Sponsors a visa. Brings the doctor over. Only then discovers there's no viable 19AB exemption pathway for their location. The doctor sits at the practice, unable to bill. Recruitment spend is wasted. Sometimes the doctor leaves.
We solve this so practices don't waste recruitment spend on doctors who can't ultimately bill Medicare at their location.
Seven workstreams, run in the right sequence so nothing stalls.
Identifying whether your candidate fits the Standard, Competent Authority, or Specialist Pathway. Mapping a realistic timeline to their first billable patient — before you commit recruitment spend.
Coordinating EPIC verification, AMC exam scheduling (CAT MCQ and Clinical / WBA), Limited Registration applications, the supervised practice plan (SPPA-30), and supervisor declarations (DFLP-00).
Preparing position-specific documentation for the Pre-Employment Structured Clinical Interview with RACGP, ACRRM, or AMC. Ensuring the role and address match the doctor's intended placement to avoid re-PESCI.
The specialist piece, and the part that quietly fails most IMG recruitments at non-DPA practices. We assess which exemption pathway realistically fits — Replacement, Prior Negotiations, Spousal, After-Hours, Locum, or Discretionary — prepare the supporting evidence bundle, and liaise directly with the Department of Health (19AB@health.gov.au) and Services Australia.
Standard Business Sponsorship setup, nomination, and the right visa subclass (482, 494, or 186) — sequenced correctly against Ahpra registration so Home Affairs doesn't bounce the application.
Coordinating Fellowship Support Program (FSP), RVTS, or other approved program enrolments to satisfy Section 19AA. Without this, no Medicare access regardless of 19AB.
Preparing the HW019 application bundled with the 19AB exemption request, supporting letters, employment contracts, and practice documentation. Submitted in one clean package, not five fragments.
After fifteen years of running this process, the failure modes are predictable. We know them all because we've fixed them all.
Home Affairs wants the Ahpra registration number on the visa application. If the visa goes in first, it gets held up. We sequence Ahpra first, visa second.
PESCI is position-specific. If the doctor passes for one role and your scope changes — different address, different specialty mix — they may need a new PESCI. We make sure the submission accurately describes the role you'll actually employ them in.
The most expensive trap. The doctor is registered, has a visa, has arrived — and still can't bill Medicare because there's no viable 19AB exemption category for your address. We resolve this before you commit to recruitment.
Many practices focus on 19AB and forget the doctor also needs to be enrolled in a 3GA program to bill Medicare. If they're not Fellowed and not on FSP/RVTS/AGPT, no Medicare access regardless of 19AB.
The supervisor at your clinic must meet Ahpra's eligibility criteria. We confirm this before the job offer goes out, not after the doctor has already moved countries.
Services Australia treats the HW019 and the 19AB exemption as one package. Splitting them doubles the processing time. We bundle them properly.
Where the standard registration pathway doesn't apply and a Section 19AB exemption is required to bill Medicare. This is our specialism. We assess viability before you commit any spend.
Continuity-of-care recruitment where the Replacement category for 19AB exemption is typically the most viable pathway. We document the case for continuity and prepare the supporting evidence.
Practices becoming Standard Business Sponsors for the first time. We walk you through SBS approval, nomination, and the right visa subclass for the role and the candidate.
Book a free initial consultation. We'll walk through your practice, your candidate (if you have one), and the realistic pathway to provider number — including a candid view on whether 19AB will work at your address.
Book a free consultation →