Same as the system applying to registered practitioners
7
|
ESSA, AMT, ARC, ANZCP, STAA, ANZSRS
|
Court hearing
|
1
|
|
Professional Organisations should deal with complaints in the first instance
|
4
|
RAoA, AA, SPA
|
Should be managed by a clinical board /( with direction from the Ministerial Council)
|
2
|
ASTA
|
Tribunal hearings with the power to 'name and shame' lying with the commissioner
|
1
|
TOHCC
|
As per NSW scheme
|
3
|
ACAA, ACQ, ADPA
|
A Commissioner in the first instance and a tribunal for more serious breaches/appeals
|
5
|
CPWA, CPSA, HSC
|
Practitioners should have a right of a appeal before prohibition order is made
|
2
|
AOPA, HCQ
|
Orders issued through State and Territory HCEs, except in jurisdictions where HC does not have power to issue orders
|
1
|
HSUE
|
Tribunal hearings, with the possible exception of repeat offenders
|
1
|
AIMBI
|
Peak bodies are best placed to hear complaints about its members
|
1
|
ACA
|
Through existing formal mechanisms
|
1
|
AURA
|
Should be a separation of powers between the investigating and prosecuting functions
|
1
|
HCQ
|
What ‘relevant offences’ (if any) should provide grounds for a prohibition order to be issued?
|
Non-communication or failure to refer
|
2
|
AAMT
|
Providing information that is not evidence-based
|
2
|
DAA
|
Any offences that normally apply to a registered practitioner
|
4
|
URN, PA, AREMT
|
Any proven harm to a person either physical or mental
|
5
|
RAA, CMA, SASH
|
False and misleading claims
|
7
|
RA, AAMT, CCWA
|
Discouraging conventional and life saving treatments
|
1
|
|
Providing services without a valid qualification
|
2
|
ASA
|
Gross misconduct/sexual offences/fraud
|
10
|
ASA, CPWA, AASW, RA, AURA, SASH
|
Financially profiting from useless/dangerous treatments/financial misconduct
|
3
|
SARRAH
|
As per NSW code
|
6
|
ATMS, NCC, ANTA, TOHCC, AIMS
|
All offences which cause (or potentially cause) harm to the public
|
4
|
VAHLC, AMT, ARONAH
|
Those defined in the Public Health Act, Fair Trading Act or Australian Consumer Law
|
3
|
ESSA, ANTA, ARC
|
Risk to public safety
|
5
|
SARRAH, ANZCP, ANZSRS, DAA
|
Failure to maintain professional standards
|
2
|
ASA
|
The practice of types of unproven therapy known to cause harm
|
1
|
|
Any breach of the code of conduct
|
4
|
ANZCP, DSCWA,NHAA
|
Should include offences that don't necessarily pose a direct threat to public health and safety
|
1
|
AIMBI
|
As per NSW code, but broadened to include criminal offences
|
1
|
AOB
|
Prohibition orders should be a last resort after supervisory and educational activities
|
1
|
ACA
|
What other grounds should apply before a prohibition order may be issued?
|
Unethical behaviour
|
4
|
ASA
|
Sexual misconduct
|
6
|
SARRAH, AMT, AAMT, SASH
|
Practising under the influence of drugs/alcohol
|
4
|
AMT, ASA, CPWA
|
Financially exploiting clients
|
4
|
CPWA, NHAA, SASH
|
Misinforming clients/making false claims
|
3
|
CPWA, AAMT
|
Keeping poor patient records
|
1
|
|
Providing harmful/potentially harmful treatments to the public
|
5
|
AMT, AIMS
|
Any grounds that would normally apply to a registered practitioner
|
3
|
LCANZ, URN, CHF
|
Should be possible to issue prohibition orders pre-emptively, subject to procedural fairness, as a result of a professional association’s findings
|
2
|
ATMS, NCC
|
Working outside scope of practice
|
6
|
AMT, ARONAH, APA, AMA
|
Failure to comply with statutory requirements e.g. privacy laws
|
1
|
AMT
|
Should be possible to issue interim prohibition orders during an investigation if there is a serious risk to health and safety.
|
2
|
AREMT, CHF
|
Practitioner being found guilty of a criminal offence
|
4
|
AOPA, CPWA, STAA, AAMT
|
Practising while suffering from certain physical or mental conditions
|
2
|
CPWA, ANZSRS
|
Breaching code should be sufficient, not necessary to demonstrate risk to health and safety
|
1
|
CCWA
|
How do you think a regulatory scheme to investigate and prosecute breaches of a national statutory code of conduct for unregistered health practitioners should be funded?
|
Federally
|
17
|
RAA, NFR, AOPA, AIMBI, STAA, AASW, AHPRA, RA, CMA
|
Funded through professional organisations and paid for by members
|
4
|
ANZCP
|
Partially federally and partially by national associations/practitioners
|
10
|
ATMS, NCC, AHA, CPWA, QPCS, ANZSRS, DAA, ASAPO
|
Professional indemnity or other type of insurance
|
3
|
|
A new scheme would protect the public (thus should be partially funded by taxes) and improve professional standards (thus partially funded by professions)
|
1
|
|
Commonwealth should see public protection as a duty not an option
|
5
|
|
It should form part of current national scheme
|
5
|
URN, OHPA, AAMT
|
It would need to be publicly funded which may limit services available through complaints mechanism
|
1
|
SPBQ
|
Recovery costs should be sought if a practitioner is disciplined
|
6
|
LCANZ, NFR, HSUE, ANZSRS, AIMS, SASH
|
Medicare should be increased .5% to cover dental and complementary health care
|
1
|
|
The self-medication/vitamin industry should be required to pay a levy/tax
|
2
|
|
Registration fees/license to practise
|
3
|
ASA
|
Should be borne by practitioners
|
2
|
VAHLC, AOB
|
Commonwealth and/or State and Territory governments
|
28
|
ESSA, ANZATA, SARRAH, RAoA, AMT, ARC, ACAA, PA, AA, SPA, ARONAH, DSCWA, AMA, ASTA, HSUE, AACMA, PACFA, ACQ, IBPA, AMTA, AFMA, NHAA, HQCC, CCWA, SASH, HCQ, HSC
|
As per NSW scheme
|
1
|
MRPBV
|
By several jurisdictions
|
1
|
TOHCC
|
Do you have any other comments to make about these proposals?
|
Non-evidence based practice is a large problem, especially when anyone can provide health advice. It is impossible for consumers to differentiate between good and poor advice.
|
1
|
|
Naturopaths should be registered under the National Scheme.
|
4
|
ANPA, ARONAH, NFR
|
Social Workers should be registered under the National Scheme
|
12
|
|
There needs to be a more integrated approach to treating abused children and adults and those with a mental health diagnosis
|
1
|
|
I would like national registration and protection of title
|
1
|
|
Everyone should be registered
|
1
|
|
Speech pathologists should be registered
|
4
|
SPBQ, LBHCC, QCA
|
TGA should become Therapeutic Goods and Services Administration
|
1
|
|
The term ‘health practitioner’ can be misleading. There needs to be a clearly defined work role and job description.
|
1
|
|
Pseudo-medicine should not be legitimised through a regulatory scheme
|
3
|
|
The German and/or South African models should be followed.
|
1
|
|
Religious organisations purporting to offer health/counselling services should be included under the scheme.
|
1
|
|
Emergency Medicine should be registered
|
1
|
|
Sonographers should be registered
|
2
|
|
Tooth whitening and bleaching should only be done by registered dentists
|
2
|
ADA
|
Family members/concerned other should be able to make complaints
|
1
|
|
|
2
|
|
A database of professional bodies should be made publicly available
|
1
|
|
Governments should only accredit professional bodies if they confirm qualifications and require criminal history checks
|
1
|
|
Prohibition orders should be published
|
1
|
MSC
|
New category of ‘health coach/counsellor’ should be created
|
1
|
|
Probity checking should be introduced to insure any professional association is bona fide and effective
|
1
|
ATMS
|
Practitioners should be required to be members of a peak professional association
|
2
|
SNTR, RAA
|
The term ‘unregistered’ health practitioner has negative connotations and should be changed
|
8
|
RAA, ANZATA, RAoA, ANZCP, SPA, AROH, AOPA, AASW
|
Online and TAFE courses in Audiometry should be stopped
|
1
|
|
The generic approach will not significantly improve standards of practice
|
1
|
MRPBV
|
Therapists who engage in recovered memory therapy must be held accountable
|
1
|
|
Cardiac scientists should be registered
|
1
|
|
The Church of Scientology (which offers counselling and distributes drugs) should be included on list of practitioners under consideration
|
|
|
Personal care workers/assistants in nursing should be registered
|
2
|
ANMFSA, ANF
|
A nationally endorsed practice framework for personal care workers/assistants in nursing should be developed
|
|
|
A separate consultation process on the content of the Code of Conduct should be undertaken to ensure that viewpoints of all pre-hospital care practitioners are in included.
|
1
|
AREMT
|
Paramedics should be registered
|
1
|
CAA
|
Unregistered health professionals who are subject to a prohibition order should lose Medicare status
|
1
|
AMA
|
The proposals are minimalistic and focus on ethical conduct
|
1
|
ASTA
|
Pharmacy assistants are not health professionals and should be not included in any health regulatory scheme
|
1
|
PBA
|
There needs to be a distinction in legislation between established professions and 'quacks'
|
1
|
HSUE
|
The consultation should have included details of current self-regulation programs
|
1
|
AASW
|
Consideration needs to be given as to how the proposed code will fit in with existing association codes
|
1
|
BUPA
|
A national code of conduct should be an interim measure only, pending full registration
|
1
|
BUPA
|
The NSW Coroner's recommendations from the report into the death of Rebekah Lawrence (8 December 2009) regarding psychotherapists/counsellors should be actioned.
|
1
|
PACAWA
|
Dental technicians should be registered
|
3
|
LBHCC, CPSA, QCA
|
The unregulated use of psychotherapy may warrant further investigation
|
1
|
AHPRA
|
|
