Australians are increasingly raiding retirement savings to fix their teeth. New guidance from AHPRA and the ATO warns against abusive models. What’s really going on – and what should change?

Why this matters

Australia’s cost-of-living crisis has collided with the nation’s dental access gap. Public waiting lists are long and eligibility criteria are strict; fully-private care is not cheap. As a result, more Australians are dipping into superannuation on “compassionate” medical grounds to pay for dental work.

My recent analysis of news coverage found the public narrative skewing negative: stories of people losing money, unexpected tax bills and the long-term hit to retirement balances were common, while the structural drivers — unmet dental need and system design — received less attention.

A sharp warning from regulators

On 16 October 2025, the Australian Health Practitioner Regulation Agency and the Australian Taxation Office issued a joint warning. Their target: business models and practitioner behaviours that push patients toward “overly expensive or unnecessary” procedures paid for by early release of super. The warning reminds clinicians that providing, or facilitating, financial advice outside one’s scope risks regulatory action and — importantly — that clinical documents must be accurate and not used to game eligibility rules.

What the ATO actually allows

Despite the marketing language some patients encounter online, the bar for early release is high. The ATO permits access on medical grounds only where treatment is necessary to treat a life-threatening illness or injury, or to alleviate acute or chronic pain or acute or chronic mental illness. Applications require specific medical reports on an ATO form and evidence the treatment is scheduled and cannot be met by other means. Cosmetic or purely elective procedures do not qualify.

The scale of withdrawals

The numbers are not trivial. ATO statistics show approvals under medical/dental categories have surged over recent years, with dental procedures a large share of approved amounts. Media reporting this month put total early-release approvals across medical reasons at more than $1.4 billion in 2024–25, with dental-related requests doubling over two years. Whatever the exact split by procedure, the direction is clear: compassionate access for health care is growing fast – and dental care is a big driver.

The clinical and ethical tension

From a clinician’s perspective, the need is real. Untreated dental disease causes pain, infection and lost workdays; it worsens chronic conditions and can precipitate hospital admissions. For some patients, timely care prevents escalation and higher system costs. Yet early release of super is not a health policy; it is a stop-gap measure that shifts today’s healthcare costs onto tomorrow’s retirements. My media analysis shows this trade-off repeatedly lands on individuals, not systems, with patients portrayed as forced into hard choices rather than supported by coherent policy. While the ATO is clear that the early compassionate release of super is not intended to facilitate cosmetic treatment, in reality many of the applications for early super access are to support extensive, cosmetic and elective treatments.

Problems the warning is trying to fix

The AHPRA/ATO intervention targets three behaviours that harm patients and public trust:

1. Over-treatment and inflated quotes. Packages marketed as “full mouth makeovers” bundled with finance, pitched as “super-friendly”, risk breaching both clinical and consumer law standards if not medically necessary.
2. Scope creep into financial advice. Clinicians (and third-party brokers) straying into how to access super, or implying guaranteed approvals, expose patients to tax and retirement risks – and expose themselves to sanctions.
3. Document gaming. Misrepresenting pain, urgency or mental health impacts in reports to meet criteria is both unethical and sanctionable.

What patients need to know

If you’re in pain and considering super to fund dental care:

• Check eligibility first. The ATO rules are strict; many advertised procedures shouldn’t qualify. Start with the ATO page and talk to your dentist about the clinical necessity and alternatives – not a broker.
• Ask for options. Public hospital triage for those who are eligible, staged care or lower-cost alternatives (e.g., stepwise treatment) may reduce the immediate bill without raiding retirement savings.
• Beware of “too easy” claims. If a clinic promises “simple” super access, be cautious. Fast-tracked approvals today can mean tax surprises and much less super tomorrow.

What practitioners should do

Most dental professionals act ethically. The few who don’t put patients and the profession at risk. The guardrails are straightforward:

• Stay in scope. Provide accurate clinical reports; do not give financial advice or coach patients to fit criteria.
• Be transparent about costs and alternatives. Offer itemised plans, second opinions and staged-care pathways.
• Document necessity, not desire. Distinguish urgent, pain-relieving care from elective or cosmetic work.

Policy fixes that would help

Relying on super as a de facto safety valve for dental access is poor policy. Three reforms would reduce the pressure:

1. Expand public dental access for pain and infection. Targeted funding to shorten urgent-care waits would directly cut demand for early release of super. Even better would be the development of an appropriately funded dental service for all Australians through Medicare. We’ve explored some of the factors and considerations for how this might happen and our research shows Australian dental practitioners would support the expansion of Medicare to include more dental services.
2. National rules for third-party “super brokers”. Clear licensing (or prohibition) of commissions on health-related super applications would remove perverse incentives.
3. Transparent data and audits. Regular publication of procedure-level approval data, coupled with random audit and penalties for misrepresentation, would deter abuse while informing planning. The ATO data doesn’t currently give any insight into the nature of the treatment being undertaken through early super access; we only know anecdotally from consumer and practitioner reports that many treatments being funded through early super access don’t actually meet the ATO’s requirements.

The bigger picture

Dental care is essential healthcare. When people must choose between pain relief now and poverty later, the system — not the patient — has failed. The AHPRA/ATO warning is welcome and necessary. But warnings alone won’t fill cavities or rebuild broken teeth. Australia needs a dental access policy that doesn’t force households to mortgage their future retirements to treat today’s infections.

The views expressed in this article may or may not reflect those of Pearls and Irritations.