NSW State Insurance Regulatory Authority’s new guidelines

13 December 2023

About the Guidelines

The Guidelines specify SIRA’s service and billing expectations for services delivered by health and health-related service providers in the WC and CTP schemes, including counselling service providers. The guidelines can be found on the Regulation of health and related services providers page of the SIRA website.

Significant new requirements for counsellors include:

  • a code of conduct for providers working in the schemes
  • new requirements around telehealth
  • new invoicing requirements

The Guidelines are part of SIRA’s approach to health and related provider regulation that commenced with the 2022 amendments to the State Insurance and Care Governance Act 2015 and the State Insurance and Care Governance Regulation 2021.  The Act provides the power to issue a direction, for the Regulation to specify the circumstances in which a direction is given, and for SIRA to issue Guidelines.

What this means to PACFA members

SIRA acknowledges that the vast majority of providers in the schemes do the right thing, however there are outliers with patterns of poor practices such as overcharging which SIRA needs to address.  SIRA does not intend to use this regulatory framework to intervene in individual patient care.

Unless there is a risk of harm, SIRA’s general response to non-compliance will be to start with communication and education - engaging with the provider to help them come into compliance. If the provider continues to not comply, ultimately SIRA can issue a direction to a provider and has the power to suspend or exclude a provider from working in the schemes. 

The requirements for counsellors

Different parts of the Guidelines apply to different providers and apply differently in the WC and MA schemes.  These are the parts of the Guidelines that apply to counsellors:

 Scheme  Parts that apply to counsellors
  • Part 2: Requirements for telehealth services
  • Part 5: Billing Requirements
  • Part 6: Invoicing requirements (excluding pharmaceutical services)
  • Part 1: Code of conduct
  • Part 2: Requirements for telehealth services


Part 8 of the Guidelines also sets out which parts apply by provider and by scheme. 

SIRA made a number of changes to the Guidelines in response to feedback raised during consultation. Further detail on changes in response to feedback can be found at the Outcomes tab here.

SIRA appreciates those who took the time to participate in the consultation on the draft Guidelines.

If you have any further questions about the Guidelines, please contact [email protected]