1
|
VAHLC
|
Would depend on the code/practicality
|
1
|
AMT
|
Should only apply to owners/operators who have contact with the public
|
1
|
|
Sanctions should apply to business owners only when they are found to have directly influenced the practitioner to break the code of conduct
|
2
|
HQCC
|
Do you have a preferred option for the legislative and administrative arrangements?
|
As per current NSW arrangements
|
6
|
URN, ARC, TOHCC, AACMA, ASAPO, CPSA
|
It should be a national body – for consistency/one point of contact
|
7
|
APA, AOB, AASW, QPCS
|
The TGA legislation could be expanded to include services
|
1
|
|
Existing State or Territory complaints and disciplinary processes
|
6
|
LCANZ, SARRAH, DSCWA
|
Self-regulation by a national body – this is the best way to govern a profession
|
1
|
|
Amendment to the existing National Law or supplementary legislation
|
2
|
ATMS, AHyA
|
As per current national registration
|
4
|
VAHLC, ANZCP
|
Should be nationally consistent, robust and adequately funded
|
1
|
ANZATA
|
Anyone practising as an Arts Therapist should be required to join ANZATA
|
1
|
NIB
|
National registration for therapists who have or can get a Medicare provider number
|
1
|
NIB
|
A peak health care complaints agency structure in each State or Territory
|
2
|
NIB, AMTA
|
Administrative arrangements need to be in cooperation with Professional Associations
|
3
|
RAoA, SPA, RA
|
As close as possible to national registration, as the public is not aware of the difference
|
1
|
|
A centralised administrative body and legislation to ensure that statutory powers are clear
|
2
|
SPA
|
Should be administered nationally through DOHA
|
1
|
ASA
|
Nationally uniform but state based administration/legislation with mutual recognition
|
6
|
AOPA, AMA, ACQ, NHAA, CCWA, HSC
|
The UK HPC code of conduct is a good model
|
1
|
ASTA
|
Professional organizations should be responsible for setting standards and investigation of complaints should be done by an independent third party
|
1
|
AAAPP
|
A national complaints commissioner
|
1
|
AIMS
|
Self-regulation by professions with a strong national body and government agency for all others
|
2
|
DAA, IBPA
|
Where feasible, could be included within the scope of existing consumer law
|
1
|
AURA
|
What do you think should be included in a national statutory code of conduct?
|
A relevant tertiary qualification/required level of training
|
2
|
ANZATA
|
Minimum training requirements, ethical practice standards, complaints management process, practice standards
|
4
|
AIMS, AURA
|
As with the NSW code
|
24
|
URN, ATMS, ARC, NFR, ARONAH, DSCWA, ASA, AHA, CPWA, STAA, AOB, AHyA, ACQ, DAA, RA, ASAPO, NHAA, HQCC, CCWA
|
Issues relating to health prevention strategies, including vaccination
|
1
|
|
Ethics, expected behaviour, patient privacy and confidentiality
|
1
|
|
Duty of care, infection control, CPD, ‘good character’ requirement
|
1
|
|
Whatever is in a professional association’s code of conduct
|
1
|
|
An updated list of modalities it refers to
|
1
|
RAA
|
A version should be available for practitioners to display
|
2
|
RAA, CPWA
|
A specified code of practice and required education and training needed
|
1
|
MRPBV
|
Provisions for evidence from traumatised/affected third parties to be taken into consideration
|
2
|
AFMA
|
Obligations on the practitioner and obligations in respect of patients' rights
|
1
|
|
Should capture employers' responsibility for their directly supervised practitioners
|
1
|
PA
|
Should include membership of a professional association
|
2
|
NFR, AIMBI
|
Advertising guidelines e.g. what can and can't be claimed
|
1
|
APA
|
Protection of title
|
2
|
AHA, AFMA
|
As per the UK HPC code of conduct
|
1
|
ASTA
|
Provision for health insurers to reserve the right to audit and access a health practitioner's records
|
1
|
BUPA
|
A requirement that practitioners keep records in English
|
1
|
BUPA
|
As per the NSW code with the addition of IPL/laser services
|
1
|
CPSA
|
A combination of various other professional codes of conduct e.g. APS, AMA, ADA
|
1
|
SASH
|
Do you have any comments on the NSW Code of Conduct for Unregistered Health Practitioners?
|
It’s good/effective
|
22
|
MSC, VAHLC, RAoA, ANTA, TOHCC, PA, ANZCP, DSCWA, AOPA, AMA, DAA, AMTA, ASAPO, CMA, SASH, HSC
|
Our organisation has adopted the NSW Code of Conduct for its members
|
1
|
AACHP
|
It is ineffective against false and misleading claims
|
1
|
|
You should not need more than one instance of professional misconduct for it to be considered a breach of the code
|
1
|
ESSA
|
Name should be changed from ‘unregistered’ to ‘self-regulating’ or other term
|
4
|
ANZATA, RA, AURA
|
Complementary therapy should be differentiated from alternative therapy
|
1
|
ARC
|
It is very broad and pitched at a lower standard than many professional codes
|
1
|
AMT
|
It is not sufficient for speech pathology
|
1
|
|
Should not be considered a substitute for registration
|
5
|
ARONAH, AASW, BUPA
|
Has limited capacity for active monitoring and feedback
|
1
|
PA
|
It has been largely ineffective to date
|
1
|
BUPA
|
Some elements are not relevant for counselling/psychotherapy
|
1
|
PACFA
|
Content has not been validated against the mitigation of potential risks
|
1
|
ANZSRS
|
Medical laboratory scientists should be added to the list
|
1
|
AIMS
|
Code should be amended to specifically refer to the supply of cosmetic contact lenses
|
1
|
AHPRA
|
What do you think are the strengths and weaknesses of the NSW Code?
|
Section 11 is open to misinterpretation and requires re-wording/clarification
|
2
|
URN, ARC
|
No mechanism to stop false and misleading claims if “no serious patient care issues”
|
1
|
|
No option for anonymity of complainant
|
1
|
|
Section 5 should be expanded to include all forms of serious illness/chronic pain
|
2
|
APMA, HCQ
|
It fails to address the issue of religious organisations who offer harmful/exploitative counselling/psychological services
|
2
|
|
Only comes into effect ‘after the event’
|
13
|
NFR, ARONAH, AHA, ASTA, AASW, QPCS, ANF, AFMA, ASAPO, AAMT
|
Needs to encourage professions to become self-regulating
|
1
|
|
Consumers need to be made more aware of their choices/ability to complain
|
3
|
MSC, ARONAH, ASTA
|
Addition of probity checking is desirable
|
5
|
ATMS, NCC, NFR, ARONAH, HCQ
|
Replace the word ‘Alternative’ with ‘Complementary’
|
1
|
RAA
|
‘Adequate clinical basis’ needs to be reworded/clarified
|
5
|
RAA, AOPA, AMTA, AFMA, CCWA
|
Does not protect the public from someone who hasn’t done the required amount of training
|
16
|
ANZATA, NFR, AHA, AOPA, ASTA, QPCS, DAA, AFMA, NHAA, CMA, HCQ, HSC
|
Does not cover owner/operators
|
1
|
RAoA
|
It is too broad/generic
|
6
|
AMT, ARONAH, AOPA, BUPA, AODA
|
The specificity of the code to a particular profession could be made clearer by working through professional associations
|
1
|
|
Should include some provision for notifiable conduct
|
1
|
|
Some terms require further definition/specificity e.g. 'suitable period'
|
1
|
|
Strength: it is low cost and all encompassing
|
2
|
NFR, ANZSRS
|
No profession-specific provisions
|
2
|
NFR, ARONAH
|
No working with children check
|
1
|
NFR
|
No provision for student practitioners
|
1
|
NFR
|
Lack of attention to minor offences/only deals with major issues
|
1
|
ARONAH
|
Jurisdictional confusion between criminal and regulatory action
|
1
|
ARONAH
|
Should ensure protection against claims to cure long term disabilities
|
1
|
DSCWA
|
The definition of Health Professional needs to be monitored/expanded
|
2
|
AOPA, AOP
|
All key terms in the Code need to be clearly defined
|
1
|
BUPA
|
It's a minimalistic approach with components of risk management missing
|
1
|
ANZSRS
|
Strength: the language is easy to understand for consumers
|
1
|
AIMS
|
Strength: it is all-encompassing and mentions ethical considerations
|
1
|
AIMS
|
The definition of masseur does not reflect current professional titles used
|
1
|
AAMT
|
No protection of title
|
1
|
CMA
|
Doesn’t cover CPD
|
1
|
HCQ
|
Section 10 (financial exploitation) should be strengthened
|
1
|
HCQ
|
Section 16 (insurance) should be strengthened
|
1
|
HCQ
|
Do you think it provides a good model?
|
It’s a good starting point
|
12
|
URN, RAoA, PA, AOPA, RA, ASAPO, AAMT, CHF, CMA
|
Yes
|
17
|
ATMS, NCC, ANZATA, ARC, ACAA, ARONAH, DSCWA, AIMBI, AACMA, AIMS, AHyA, AMTA, NHAA, AURA, SASH
|
It doesn’t go far enough as a regulatory framework
|
2
|
AMT
|
It's good but public awareness of the system needs to increase
|
1
|
|
No, as it doesn't address the issue of minimum standards
|
7
|
QPCS, ANZSRS
|
Do you have a preferred option for the mechanism through which prohibition orders should be issued, that is, via an administrative order decided by a Commissioner, or via a tribunal or court hearing?
|
Tribunal –
|
17
|
SARRAH, PA, NFR, ARONAH, DSCWA, AHPRA, PIAC, IBPA, AMTA
|
- it would provide a more rounded decision
|
2
|
ANZATA
|
- it would allow for natural justice
|
1
|
|
No real preference as long as there are adequate avenues for appeal
|
3
|
ASAPO, SASH
|
System similar to TGACRP for minor breaches that can be elevated for major breaches – cost effective, timely, transparent and anonymous
|
1
|
|
An administrative order process through a commissioner
|
21
|
ATMS, NCC, HCCC, URN, SARRAH, PA, NFR, DSCWA, ASA, AHA, AACMA, AIMS, AFMA, NHAA, CCWA
|
Anyone accused of misconduct should have the opportunity to defend themselves
|
1
|
|
|
