19AA & 19AB Explained: The Moratorium Guide: IMG guide for UK practice (2026)

Key points

19AA is the “who can bill Medicare” rule (specialist registration / working towards it).
19AB is the “where you can bill Medicare” moratorium for OTDs/FGAMS (typically DPA/DWS) for ~10 years.
For GPs, “DPA” is the map you live or die by; check it before signing anything.
A spousal exemption is real — but it is discretionary, location-specific, and paperwork-heavy.

Think of it like this

19AA determines whether you can access Medicare benefits at all (eligibility). 19AB determines where you can access Medicare benefits (geography) until your moratorium is completed. Many IMGs are subject to 19AB; Australian citizens/permanent residents without the right pathway can still be caught by 19AA.

The 10-year moratorium (19AB) applies to overseas trained doctors and foreign graduates of an accredited medical school who want to provide Medicare-rebatable services. In plain terms: you may be clinically able to work anywhere, but you cannot “bill Medicare” everywhere until you complete the moratorium — usually by working in priority locations. For general practice, those priority locations are defined using Distribution Priority Area (DPA) classification; for other specialties, similar shortage concepts are used (e.g., DWS depending on role/specialty).

The DPA workflow (what to do before you accept a job)

Step 1 — Confirm your restriction status early

Ask your recruiter/employer (in writing) whether you are restricted by 19AA and/or 19AB and what evidence they are basing this on. Do not rely on “everyone says it’s fine.”

Step 2 — Check the location on the official maps

Check whether the practice catchment is DPA (for GP) and understand that classifications change. Screenshot/save the classification at the time you negotiate.

Step 3 — Understand MMM vs DPA (do not confuse them)

MMM describes remoteness (MM1–MM7). DPA is a needs-based classification identifying GP shortage locations; it can be influenced by MMM but is not the same thing.

Step 4 — Build your Medicare pathway into the contract

Your contract should reflect (a) supervision and billing model, (b) the exact location, and (c) what happens if the location loses DPA status during onboarding.

Step 5 — Provider number / Medicare admin is not “later”

Treat provider number, Medicare billing setup, and exemption paperwork like credentialing — it is a launch-critical dependency.

Common failure mode

The classic disaster is signing a lease near a “great practice” and only later learning the site is not eligible (or no longer eligible) for your restriction category. Make DPA/DWS verification a pre-condition of committing financially.

Spousal exemptions exist under 19AB(3) and are intended to allow a restricted doctor to work at a specific practice location near a spouse’s primary place of employment (where criteria are met). This is not a blanket “free pass”: it is tied to a location, requires documentation, and is evaluated against eligibility criteria. If you are planning family-based location constraints (e.g., metro), treat the spousal exemption process as a formal project: evidence pack, timelines, and a backup plan.

Your “evidence pack” checklist (spousal exemption)

Proof of relationship (as required by the application form/guidance).
Spouse’s primary employment evidence (contract/letter, work address, start date).
Your proposed practice details (site address, role, supervisor details).
A written rationale focused on proximity and practicality (not preference).
A contingency location that is unquestionably eligible (in case of refusal).

19AA & 19AB Explained: The Moratorium Guide