Options for regulation of unregistered health practitioners Decision Regulation Impact Statement



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10

RAA, RAoA, AHyA, DAA, IBPA, ACA, HCIA

To help unregistered practitioners become recognized for prior learning

1




Public education program

13

AMT, AA, STAA, AMTA, AFMA, RA, ACA, CCWA, HCQ, NTDH

Strengthen TGA and ACC powers to crack down on unlawful claims and deceptive advertising

1




Transparent and unbiased safety net for consumers

2

AAMT

Probity checks administered in partnership with professional organisations

2

ATMS

Government authentication/support of professional associations

6

ATMS, NCC, NIB, SPA, AHA, ARCAP, AIMS

Legal recourse for patients who suffer through malpractice or negligence

1

ATMS

National registration for counsellors and social workers

1




Regulatory boundaries and a transparent, consistent regulatory framework

2

NCC, AMT

Require all government health employees to belong to peak professional body

1

ESSA

Certainty for consumers that service will be of a high quality/certain standard

4

MRPBV, NIB, AMTA, NTDH

Require practitioners claiming a health benefit to belong to peak professional body

4

NIB, SPA, AHA, CMA

Require practitioners to display their local health care complaints process for consumers/patients

1

NIB

Ensure all mental health practitioners have compulsory training

2

AFMA

Requiring doulas who are effectively practising midwifery to be registered

1




Protect health, safety and wellbeing of Australian public

9

SPA, ARONAH, ASA, AOPA, HSUE, AAMT, HSC

Maintain a wide range of services while ensuring minimum standards are met

1




Develop a process by which unfit persons can be banned from delivering a health service

4

ACAA, HSUE, AURA

Ensure the ongoing viability of the health sector

2

ASA, CMA

Protection of the public from inappropriate treatments and financial exploitation

2

CPWA, DAA

Ensure that all 'health professionals' follow a recognized code of conduct

1

AIMBI

Ensure that deregistered practitioners don't continue to provide health services in a similar area

2

AACMA, ARCAP

Provide limited registration for registered practitioners practising out of scope

1

AACMA

Prevent practitioners from practising interstate if malpractice is proven in another state

1

STAA

Include components and materials of dental prostheses in the TGA

1




Prevent harm to mental health clients, their families and communities through regulation, supervision and intervention.

1

AFMA

Reduce client exposure to questionable health practices and protect public assets

1

ASAPO

Ensuring anyone using IPL/laser technology meets minimum standards of training

1

CPSA

Clear articulation of minimum standards to be met by unregistered providers.

2

HSV, NTDH

A national database about complaints made against unregistered practitioners

1

NTDH

Adopt a sensible definition of a health service

1

HCIA

Avoid duplication of existing consumer protection

1

HCIA

Do you think there is a case for further regulatory action by governments in this area?

Yes

52

URN, ATMS, NCC, ESSA, ANZATA, MRPBV, RAoA, AMT, TOHCC, PA, ANZCP, AA, ARONAH, ASA, HSUE, AOB, AASW, BUPA, AIMS, DAA, AMTA, ASAPO, NHAA, CPSA, AAMT, CCWA, CMA, AURA, SASH, HSC, NTDH

No

4

PACFA, IBPA

What do you think of the various options?










Option 1: No change

This option is negligent of Health Ministers

1




Changes need to be made to protect the public

2

ATMS

This option will perpetuate the problem

1




Appropriate for our profession which has standard international certification

1

LCANZ

Best option

3

ARCAP, ACA

Option 2: A voluntary code of practice for unregistered health practitioners

Has not been shown to work in other industries

1




Would not have any effect/unenforceable

13

SPBQ, ATMS, RAA, ANZATA, MRPBV, ARONAH, DSCWA, EREMT, HCSCC, HQCC, HSC

Difficult as some professions have multiple professional bodies

1




Yes

6

AAH, AAPHAN, PACFA

Does not provide clear, transparent guidelines

1

NCC

Unregistered professional bodies should be required to have code of practice

1

ESSA

This option does not offer adequate protection to the public

2

HSC

Self-regulatory codes already exist within the pharmacy structure

1

PBA

Government could work with professional associations to reduce the number and severity of cases that require a stronger intervention

1

AASW

This option asks professional associations to investigate complaints made against their members while trying to uphold member interests

2

NHAA, NTDH

Option 3: A national statutory code of conduct for unregistered health practitioners

This should be implemented at the absolute minimum

9

SPBQ, SARRAH, ADPA, ASAPO, NHAA, CMA

Yes

73

URN, AACHP, APMA, NATCOM, ATMS, NCC, APCCH, HCCC, SNTR, VAHLC, RAA, ANZATA, RAoA, ANTA, AAPHAN, TOHCC, ACAA, PA, ANZCP, AA, ARONAH, AREMT, AROH, AMA, CPWA, AANSW, HSUE, AIMBI, AACMA, LBHCC, ACQ, AHPRA, IAIM, MBK, PIAC, AFMA, RA, CHCA, AAMT, HCSCC, HQCC, CHF, CCWA, UV, HCQ, HSC, NTDH

Better but not ideal

1

AAH

Should apply to unregistered practitioners who have not joined professional body

1

ESSA

Will not improve matters without public education and training standards

2

MRPBV, AMT

Option 3 only addresses the most serious cases of poor and negligent practice

1

AASW

On balance, do you have a preferred option? What are your reasons?

National codes have a consistent approach

4

DSCWA

Option 3 will provide better public protection

5

VAHLC, CCWA

National registration

12

AASW, BUPA, OHPA, ANF, AAMT, CMA

Option 3 would standardise codes across [state and territory] borders

2

URN, RAA

Option 3 could be augmented through probity checking

1

ATMS

National registration

9

SARRAH, MRPBV, NFR, ASTA, QPCS

Option 3 provides the most relevant option

1

NCC

A combination of options 2 & 3

5

ESSA, RAoA, AMT, AAPHAN, ANZCP, APA, AHA, STAA, AHyA, DAA, NHAA, AURA, SASH, HCIA

Option 3 should be further developed to include accreditation of training

2

ANZATA

Option 3 would assist in the accumulation of data and contribute to community awareness

1




Government certification of self-regulating professions who form the National Alliance of Self-Regulating Professions

2

AA, ASA

Option 3 with further consideration of additional professions for inclusion in the national scheme

7

ARONAH, ANZSRS, PIAC, CHCA, HCQ, CHPO, NTDH

A statutory code of conduct will complement the Australian Consumer Law to strengthen health complaints mechanisms.

1

CAV

A combination of options 2 & 3 with further consideration of additional professions for inclusion in the national scheme

2

AOPA, AIMS

A national statutory code endorsed by AHMAC

1

CPWA

Option 2 with additional requirement of compulsory registration with national professional organisation

1

PACAWA

Option 2

3

PACFA, APDA, IBPA

Option 2 – restrictively regulating counselling and psychotherapy removes consumer choice

1

ARCAP

Option 3 with all unregulated mental health practitioners being regulated under the National Scheme

1

AFMA

Option 3 plus a national database of health practitioners who meet minimum standards

1

ASAPO

Option 1

1

ACA

Option 3, with 'services provided using laser or IPL technology' specifically included in the code

1

APSA

What do you think are the costs and benefits of the three options?

The costs of doing nothing are already more than the cost of doing something

6

PA

The benefits outweigh the costs to the patient/clients

5

VAHLC, APA, ASAPO

Costs are justified if they provide consistency and quality for the profession

1




Costs would be small

5

NCC, ANZATA, MRPBV, CMA

There would be a bureaucratic cost for little benefit

5




There would be an initial set up cost

2

URN

Initial set up costs for registration would be large but over time system would run itself

1




Unsure of costs

1




Benefits would be safer practitioners and increase in consistency

2

ATMS

Costs would be endless

1




Option 3 would be the highest cost but best benefits

4

TOHCC, HSC

A panel to investigate complaints would be cost effective

1




Routine cost of maintaining a national register and government enforcement of Code

9

ATMS, NCC, PA, ANZCP, AOB, AIMS, ASAPO, NHAA

An annual fee linked to a national register and professional association membership

1

RAA

Subsidising existing work of professional organisations

1

AMT

Duplication of existing State and Territory functions

1

AMT

Initial establishment cost of code – could form part of function of AHPRA

1




Regulation of unregistered therapists will lower the cost of mental health care in the long run

1




Costs of investigating alleged breaches

4

DSCWA, APA, AOB, IBPA

Development and implementation of regulatory framework

1

APA

Education campaign to inform public and health professionals

1

APA

The scheme should be cost-neutral for practitioners, unless they are sanctioned

1

HSUE

Cost should be measured in more than just money eg. loss of patient trust

1

AIMBI

Cost of Option 3 would be less than statutory registration of all practitioners

1

CHCA

If you are a practitioner, can you advise of what additional costs you think you would incur with the introduction of a statutory code?

Legitimate practitioners already pay membership fees

6

AA, AASW

National association fees would rise

5

SASH

Membership, renewal, training, insurance.


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