19AB Exemptions Explained

What are 19AB Restrictions?

Section 19AB of the Health Insurance Act applies to all Overseas Trained Doctors (OTD/IMG/FGAMS) who gained their first medical registration in Australia on or before 1 January 1997. There is a requirement for all general practitioners trained outside of Australia to work in a Distribution Priority Area for their first 10 years of medical registration in Australia.


The DWS classification model has been replaced by the new Distribution Priority Areas (DPA) classification from 1st July, 2019. These changes apply to GPs and Bonded Doctors. For non-GP specialists, the District of Workforce Shortage (DWS) system remains in place.

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19AB and DPA Requirements

If you are an OTD you need to be a temporary resident or have your fellowship with the RACGP to be eligible for a 19AB exemption.

Working in a DPA location is one of the most common 19AB exemptions used to allow OTD/IMG/FGAMs to work in Australia as GPs.

This requirement is enforced through the Medicare provider number program. In order to bill patients through the Medicare system you will need a provider number, and in order to get a provider number (if your medical degree is not from Australia), you will need a 19AB exemption.

Understanding 19AB Exemptions

There are various 19AB exemptions available to overseas trained General practitioners.
Here is a quick summary of the most common 19AB exemptions:

19AB DPA Exemption

Unless other 19AB exemptions apply, International Medical Graduates (IMGs) are required to work in an area deemed to have a shortage of medical practitioners for the first 10 years. These locations are called Distribution Priority Areas (DPA).

Alecto always keeps up to date with DPA changes, connects with practices across the country and sources the best DPA GP job opportunities.

DPA GP Jobs in Australia

19AB Locum Exemption

A 19AB locum exemption is a very popular way to circumvent DPA restrictions. It is possible to work anywhere in Australia as a locum, however only for a period of up to 6 months.

We have a few clients with multiple practices in the same city, so it is possible to have a 12-month contract, with 2 x 6-month placements. Scheduling these can be tricky, but if your dates are relatively flexible, it is possible.

Locum GP Jobs in Australia
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19AB Replacement Exemption

Distribution Priority Areas are updated annually. While some locations gain DPA status, others lose their DPA classification.

The 19AB replacement exemption applies when a GP who held an unrestricted 19AB exemption leaves a practice that operates in a location no longer deemed as DPA. This situation allows for the recruitment of a replacement GP.

Alecto constantly source the best 19AB replacement opportunities and we also assist GPs with registration documents required by Medicare.

19AB Replacement GP Jobs

19AB Academic Exemption

19AB academic exemptions are available to overseas trained doctors (OTDs) and foreign graduates of an accredited medical school (FGAMS). It is suitable for GPs with a genuine interest in teaching medical students. This type of exemption needs to be approved by a listed university and by Medicare.

Academic Exemption GP Jobs

19AB Spousal Exemption

You may qualify for a 19 AB spousal exemption to practice within a reasonable distance to your husband or wife if your spouse meets certain criteria, such as:

  • Your spouse is a medical practitioner and holds an unrestricted provider number (either holds a valid 19AB exemption or isn’t restricted by section 19AB).
  • Your spouse is a skilled migrant and has obtained a skilled occupation visa during the last 10 years. He or she also needs to be employed, pursue a volunteering position, or undertake a training placement in line with the occupation the skilled occupation visa was granted for.
19AB Spousal Exemptions

19AB After-Hours Exemption

It is possible to work anywhere in Australia in an after-hours capacity. It applies to working hours from 6pm to 8am weekdays, all weekend and public holidays.

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Who is affected by Section 19AB restrictions?

Overseas Trained Doctors (IMG/OTDs) and foreign graduates of an accredited medical school (FGAMS) who are restricted by Section 19AB of the Health Insurance Act 1973 (the Act) will be affected 19AB restrictions.

This means that if you obtained your primary medical degree in another country or commenced your degree in Australia before you were a citizen, then you could be subject to 19AB restrictions.

What is the purpose of Section 19AB and DPA?

Section 19AB restrictions and Distribution Priority Areas are a key mechanism that the Australian Government uses to achieve an equitable distribution of medical services across Australia.

How to apply for a 19AB Exemption?

Excluding spousal exemptions, all other 19AB exemption requests are being processed alongside your Medicare Provider Number application, by submitting all the necessary supporting documents. Services Australia will then submit your application for a 19AB exemption to the Department of Health on your behalf.

The benefit of working with GP recruitment specialists like Alecto, is that we will guide you through the entire process, ensuring that all necessary documents ready for your 19AB exemption application.

For assistance related to your 19AB Exemption application, please get in touch.

How long does it take to get a 19AB exemption approved?

The complete process (from finding a job through to receiving a Medicare provider number) can take a few months, so the sooner you get started the better. The actual Medicare application process for your 19AB exemption can take a maximum of 6 weeks to be approved. In practice, we are often able to get these approved in around 3 weeks for our GPs.

When does my 10 year Moratorium start?

International Medical Graduates (IMGs) have a restricted Medicare Provider Number for 10 years and are therefore required to work in a Distribution Priority Area until the 10-year moratorium is completed -unless other 19AB exemptions apply.

Your 10-year moratorium starts when you are first awarded medical registration in Australia. It’s important to note, that you do not need to have held continuous registration for 10 years.

➜ Learn more about the 10-year moratorium

How are DPA determined?

Unlike District of Workforce Shortage (DWS), the new DPA classification system for General Practitioners is not based on a GP-to-population ratio.

Instead, the new system considers factors such as gender, age and socio-economic status of patients in a GP catchment area.

So, how are DPA determined?

  • Inner metropolitan areas are automatically considered non-DPA.
  • An area is automatically classified DPA if it falls into MM 3 – 7 (Modified Monash Model)
  • Northern Territory is automatically deemed DPA
  • Locations which have a shortage of health services are generally deemed DPA if health services don’t meet a specific benchmark.

Which areas have DPA Status?

The Department of Health created a useful tool to check the DPA status of a specific location.

Access the Health Workforce Locator tool.

Health-related geographic distribution classifications are updated by the Distribution Working Group (DWG) and typically take effect on 1 July each year. However, under special circumstances, for example when a community experiences an unexpected health workforce shortage, a DPA classification review can be submitted.

At Alecto, we follow DPA classification changes closely and therefore we are frequently updating records of DPA changes.

View a summary of the most recent updates of the DPA Map.

What happens if an area loses its DPA status after I accept a job but before I get my Medicare provider number?

As per the guidelines issued by the Department of Health, they will give you a 19AB exemption (DPA) provided that the area was a DPA at the time you were negotiating the contract.

More Questions regarding 19AB?

If you have any more questions about 19AB restrictions, exemptions or finding an attractive GP in Australia, please get in touch with our Registration Manager Christina Panayi on +61 423 165 120 or [email protected]

At Alecto Australia we are very experienced with 19AB, 19AA and DPA having worked in the industry for years and specialising in all types of exemptions.

We have a number of DPA vacancies across Australia, including rural and regional locations, as well as more sought-after metro DPA positions in Perth, Melbourne, Sydney and Brisbane. To see what’s available right now, visit our GP jobs page.

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