Understanding DWS and 19AB Requirements for International Radiologists in Australia
What is Section 19AB?
Section 19AB of the Health Insurance Act places restrictions on certain overseas-trained doctors and foreign graduates of accredited medical schools accessing Medicare benefits in Australia.
For specialist radiologists subject to Section 19AB, access to Medicare billing generally requires employment in a District of Workforce Shortage (DWS) location, unless an exemption applies.
This restriction is commonly known as the "10-year moratorium" and applies from the date of first medical registration in Australia.
Who is affected?
Doctors may be subject to Section 19AB restrictions if they:
- Obtained their primary medical qualification outside Australia or New Zealand, or
- Completed their medical degree in Australia or New Zealand while holding temporary residency status.
These restrictions commonly affect
International Medical Graduates (IMGs),
Overseas Trained Doctors (OTDs), and
Foreign Graduates of Accredited Medical Schools (FGAMS).
What is a DWS?
A District of Workforce Shortage (DWS) is a location identified by the Australian Government as having insufficient access to specialist medical services compared with community need.
For non-GP specialists, including radiologists, the DWS system remains the primary workforce distribution mechanism.
DWS classifications are reviewed and updated regularly by the Department of Health and Aged Care.
Public vs Private Practice
Section 19AB restrictions primarily relate to Medicare billing.
Radiologists working exclusively within the public hospital system may often work in non-DWS locations because Medicare billing is not required.
However, some public hospitals may still require access to Medicare benefits where private patient work forms part of the role
Common 19AB Exemptions for Radiologists
Locum Exemption
A locum exemption may allow a radiologist to work outside a DWS location for a limited period, typically up to six months.
This can provide access to metropolitan and non-DWS positions while maintaining compliance with Medicare requirements.
Academic Exemption
Radiologists involved in teaching, research, or university-based appointments may be eligible for an academic exemption.
These applications generally require support from an approved university and approval from the relevant government authorities.
Spousal Exemption
A spousal exemption may be available where a radiologist needs to work within a reasonable distance of their spouse.
Eligibility depends on specific criteria relating to the spouse's occupation, visa status, or professional circumstances.
Other Exemptions
Additional exemptions may be available depending on individual circumstances and workforce needs.
Each exemption has its own eligibility requirements and supporting documentation.
When Does the 10-Year Moratorium Start?
The moratorium begins from the date of first medical registration in Australia.
It is based on elapsed time rather than continuous employment, meaning doctors do not need to work uninterrupted throughout the entire period.
Our tailored recruitment and compliance services are also fully scalable — available as standalone or bundled solutions.
When Do Restrictions End?
To become unrestricted under Section 19AB, doctors generally must:
- Complete the applicable moratorium period (taking scaling reductions into account); and
- Become an Australian citizen or permanent resident.
Once both requirements are met, Medicare access is no longer restricted by Section 19AB
How Do I Check DWS Status?
The Australian Government Health Workforce Locator allows doctors and employers to determine whether a location currently holds DWS status.
As DWS classifications can change, it is important to verify the status of a location before accepting a position or submitting a Medicare provider number application.
How can we help?
Navigating DWS requirements, Medicare provider numbers, AHPRA registration, college assessment pathways, and 19AB exemptions can be complex.
As specialists in radiology recruitment, we assist international radiologists with:
- DWS and Medicare eligibility assessments
- Fellowship and specialist pathway advice
- AHPRA registration guidance
- Public and private radiology opportunities
- Locum and permanent positions across Australia
- 19AB exemption applications and supporting documentation
Whether you're considering a move to Australia or exploring your next radiology opportunity, we can help identify roles that align with your registration pathway, career goals, and lifestyle preferences.
Benefits at a glance
Public Sector
- Professional development: Allowance $21,000 per year/3.6 weeks per year
- Regional and rural allowance 5% (regional only)
- Recruitment and retention allowance 25% (regional only)
- Salary Sacrifice offered
- 5% leave loading
- 5% superannuation
Private Sector
- Generous renumeration package
- Annual leave: 4-6 weeks
- Public holidays: 11 days
- CME: Allowance and leave varies
- No oncall
Guy Hawkins
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Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales
Guy Hawkins
President of Sales