Options for regulation of unregistered health practitioners Decision Regulation Impact Statement



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Appendix 16

Summary data of views of respondents



Question

Response

Number of responses

Organisation

Please estimate of the number of unregistered health practitioners practising in your field.

Between 1000 and 2000 Reiki practitioners

4

URN, RAA, ARC, RA

1408 Speech Pathologists registered in QLD

1

SPBQ

2209 International Board Certified Lactation Consultants

1

LCANZ

11,413 members with 15,000 (est.) in industry

1

ATMS

60 members with another 35 non-members (est.) in Australia

1

IBPA

Around 1200

1

ANZATA

Over 3000 members nationally

1

ESSA

Approximately 5500 sonographers (including trainees)

1

MRPBV

942 members

1

RAoA

30,000 massage therapy practitioners Australia-wide

1

AMT

5900 members

1

ANTA

Approx 2000 audiologists and 500 audiometrists

1

HCIA

Between 100–200 unregistered cardiac scientists in QLD

2

QPCS

Between 18,000 and 20,000 social workers

3

AASW

Approximately 7000 personal care assistants in SA

1

ANMFSA

Approximately 19,000–20,000 paramedics Australia-wide

2

PA, CAA

Nearly 2000 audiologists

1

AA

Between 3000 and 15000 naturopaths and western herbalists

2

NRF, ARONAH

4,540 accredited sonographers and 595 sonography students (Nov 2010)

1

ASA

Approx. 700 homeopaths registered with professional associations

2

AHA, AROH

Est. 320 Orthotist/Prosthetists in Australia

1

AOPA

Est. up to 600 sleep technologists in Australia

1

ASTA

Est. 15,000 full time and 27,500 part-time pharmacy assistants

1

PGA

Approx. 75 to 100 medical photographers and illustrators

1

AIMBI

Approx. 850–900 shiatsu massage therapists in Australia

1

STAA

At least 600 practising orthoptists in Australia

1

AOB

117 clinical members and 140 working towards it

1

PACAWA

27,000 counsellors Australia wide (includes some registered practitioners)

2

PACFA, ARCAP

Up to 900 respiratory scientists working in Australia

1

ANZSRS

Approximately 13,000 medical laboratory scientists practice in Australia

1

AIMS

Approximately 650 members

1

AHyA

3,189 unregistered dental technicians

1

OHPA

84,746/60,000 personal care workers in residential/community aged care

1

ACQ

157 certified infant massage instructors

1

IAIM

3,270 optical dispensers (2006 census data)

1

ADOA

4,500 members, representing 85% of the profession

1

DAA

2650 dental technicians in Australia

1

ADPA

383 registered music therapists

1

AMTA

1000 – 1500 anaesthetic technicians nationwide

1

ASAPA

Approx. 7000 counsellors/psychotherapists in Australia

1

ACA

8,197 massage therapists practising in Australia

1

AAMT

Between 4,000 and 5,000 naturopaths practising in Australia

1

CMA

What do you think are the risks associated with the provision of health services by unregistered health practitioners?

Incorrect or damaging information/advice

7

VAHLC

Inconsistent, non-evidence based practice

6

SPA, AFMA, HSC

Practitioners without tertiary training

1




Lack of practice standards/inconsistent standards

7

MRPBV, PACAWA, HQCC, HSC

Lack of appropriate training/barriers to entry

21

NCC, RAA, ANZATA, ANZCP, AA, SPA, ASTA, AACMA, BUPA, ANZSRS, AIMS, AMTA, ASAPO, NHAA, HQCC

No complaints process

6

MRPBV, NFR, DAA, ADPA, HSC

No professional standards/organisation to guide practice

6

RAA, ESSA, ARONAH, PACAWA

Lack of title protection

6

SPBQ, AASW

Lack of professional ethics/ethics issues

4

SPA, PACFA, IBPA

Misleading clients in potential results of treatment

12

URN, RAA, ANZATA, ARC, AA, AHA, AACMA, RA, CMA

Consumers unable to pursue malpractice compensation

1




Improper or no follow-up care even when referred

1




Practitioners not accountable

7

DAA, AMTA, HQCC, HSC

Practitioners abusing position of power and trust

1

SPBQ

Unqualified practitioners

5

ATMS, TOHCC, NFR, AFMA

Practising outside scope of practice

9

VAHLC, AMT, NFR, ASA, AIMS, ADPA, RA

Practising with a lapsed qualification

1




Incorrect use of medical devices

5

ASTA, ANZSRS

Risks are low [for my profession]

6

PACFA, ARCAP, AHyA, ACA, HCIA

Increased community mistrust of established professions

2

AIMBI

Breaches of privacy

1

VAHLC

Failure to refer

6

VAHLC, AHA, RA, NHAA, CMA

Inappropriate interactions with clients/professional boundary issues

2

VAHLC, AMT

Improper infection control

5

VAHLC, PA, ASA, AACMA, ADPA

Failure to address mental health needs e.g. psychosis

2

ANZATA, HSC

Volunteer organisations

1




Alternative medicine

1




False positive or false negative results

2

MRPBV, CCWA

Sexual assault/misconduct

8

AMT, ARC, TOHCC, ASA, AHA, AACMA, RA, AAMT

Unsafe work environment

1

ARC

Professional reputations are at risk by unregistered practitioners bringing profession into disrepute

2




Undetected or overlooked underlying medical conditions/deterioration in conditions

5

AHA, AOB, QPCS, CPSA, CMA

Misdiagnosis/inaccurate interpretation of results

9

ASA, ASTA, AOB, QPCS, ANZSRS, NHAA

Failure to avoid drug interactions or to observe contraindications

2

CHCA

Financial loss/exploitation

5

ARONAH, AHA, CCWA, HSC

Additional burden/cost for community due to delayed/incorrect diagnosis

2

ARONAH

Unscrupulous practitioners isolating clients from other sources of emotional support

2

AFMA

Exploitation of mental health consumers/vulnerable clients

7

SPA, AASW, SASH

Harm to new clients by known offenders/unethical practitioners who continue to practice

1




Psychological risks and PTSD potentially affecting fitness to practice

1

PA

Environmental risks in EMS environment

1

PA

Risks associated with supply of ingestible substances such as herbs

3

NFR, NHAA, CHCA

Lack of cooperation/distrust between registered practitioners and CAM therapists

1

NFR

Physical, mental or financial harm

2

DSCWA, AASW

Unregistered practitioners performing restricted procedures

1

APA

De-registered practitioners who continue to work in a similar area as an unregistered practitioner.

6

APA, HSUE, AACMA, PACAWA, ARCAP, SASH

Unprofessional and predatory conduct

1

HSUE

Poor quality materials

1

ADPA

Poor quality/accuracy of work

1

ADPA

Suicide as a result of harmful psychotherapy techniques

1

AFMA

Failure to request or verify informed consent

2

RA, NHAA

Fraudulent documents with no practitioner registry to verify

1

ASAPO

Direct damage (burns, scarring) cause by IPL or lasers

1

CPSA

Similar to registered practitioners (for strong self-regulated professions)

1

CMA

To what extent have the risks associated with these activities been realised in practice?

Patients advised to follow unnecessarily restrictive/faddish diets

2

DAA

More evident in private practice than public health system

1




Patient dissatisfaction with outmoded treatment by unqualified practitioners

1




Serious harm done to hospital and community based children by unregulated social workers

1




The true extent of the damage is unknown

1




The AASE can provide this data

1




Unprofessional unregistered practitioners identified as such can move from state to state

1




Very little

1




Fraudulent product claims/promotion

2

AHA

Obstetric ultrasound transgressions including tardy reporting to medical practitioners (resulting in loss of pregnancy) and injury to patients

1

MRPBV

Cases of sexual assault/misconduct

8

AMT, TOHCC, NFR, SASH, HSC

Untrained counsellors and therapists have inflicted irreparable damage

2

AFMA

Inaccurate interpretation of results leading to lengthened hospital stays

1




Practitioners with mental health problems

1




Harm caused by laser machines used by beauticians

1

TOHCC

Failures to protect children in state care

1




Practitioners working under the influence of drugs or alcohol

1

ANZATA

Unproven treatments for children with Autism Spectrum Disorder

1

DSCWA

Complaints of unqualified practitioners undertaking ophthalmic procedures

1

AOB

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