Registration and Regulation
Qld Registration Board
Sept 2012
Queensland members may
already be aware that the State Government recently made the decision to
discontinue Queensland Registration Board. Below are the letters
informing the Association of this decision and the SPA's response to the
government.
Letter from Dr Michael Cleary, Deputy Director-General, Health Service and Clinical Innovation Division
Letter to the Hon Campbell Newman, Premier of Queensland
Speech Pathology Australia is firmly in support of registration continuing in Queensland while at the same time continuing to lobby for inclusion in the National Registration and Accreditation Scheme. The decision to remove registration of speech pathologists in Queensland is of major concern for a number of reasons, including:
- There was no
consultation with Speech Pathology Australia (as the profession's peak body) at
either the state or national level.
- There was no
consultation with the speech pathology profession across Queensland, employer
groups, nor more widely with the general public and other stakeholders.
- There was no consultation with the Speech Pathologists Board with respect to the reasons and implications of the decision and required processes to prepare for transitional arrangements.
The Association has specific concerns if this decision remains, which include:
- A high number of registered
speech pathologists are not members of Speech Pathology Australia and therefore
will be left practising without any regulatory framework – Speech Pathology
Australia can only assure the public of the ethical and professional competency
standards of members – and not non-members.
- Some registered
speech pathologists do so under a conditional registration, with limitations
imposed on the areas or scope of practice – this cannot be regulated under
Speech Pathology Australia's membership eligibility and these practitioners may
not meet these eligibility criteria.
- The Registration
Board has powers to assess and monitor medical conditions of practitioners that
may impact adversely on their ability to practise safely and competently –
Speech Pathology Australia does not have powers or mechanisms to deal with
'impaired practitioners'.
- There has been no
consultation around transitionary arrangements, with it not determined how
practitioners under ethical investigations or breaches will be dealt with.
- There is no information around whether current health, competence or ethical concerns of certain registrants will be disclosed to Speech Pathology Australia or a relevant government body.
- There may not be sufficient time allowed to obtain appropriate certification including a 'Blue Card' and 'Yellow Card'.
- Some speech pathologists currently practising in Queensland may not be able to obtain provider status with Medicare, Private Health Insurance Funds and FaCHSIA, if they cannot successfully apply for practising membership of Speech Pathology Australia.
Speech Pathology Australia believes removing registration of the profession in Queensland will result in less protection of the public and reduced assurance of receiving a safe and competent speech pathology service. This is of a specific concern given the profession's client group being inherently vulnerable and therefore having a specific need for protection through a legislative framework that regulates the practice and conduct of speech pathologists.
Speech pathologists and stakeholders are encouraged to voice their concerns about this issue and can take the following steps:
- Members can express
their concerns by writing to your local Member of Parliament and also copy-in
the Health Minister (a template letter can be downloaded here:
Exemplar letter to state member of Parliament)
- Members are
encouraged to also speak with your employer who can raise this matter through
their professional channels.
- Members of the public and/or consumer groups can also express their concern by writing or speaking with their local Member of Parliament.
For more information:
Details of this Queensland Government decision, the background and rationale provided, along with information and FAQs for registrants and employers, can be viewed on the Speech Pathologists Board's website at: www.speechpathboard.qld.gov.au/
For further information members are encouraged to contact your Branch President, Petrea Cornwell: This e-mail address is being protected from spambots. You need JavaScript enabled to view it , or to contact National Office on This e-mail address is being protected from spambots. You need JavaScript enabled to view it
Self-Regulation
April 2012
The profession calls for government authorised robust self-regulation.
Speech Pathology Australia continues to support the profession’s inclusion in the National Registration and Accreditation Scheme (NRAS), as this is considered to be the ‘gold standard’ of protection of the public. To this end, a further letter and submission was tabled with the National Health Workforce Principal Committee last year. That submission reinforced our previous arguments as to why it is believed to be in the public’s interest for the profession of speech pathology to fall under the National Registration and Accreditation Scheme (NRAS). However, the Australian Health Workforce Ministerial Council subsequently published in a Communiqué that no further professions (with the exception of paramedics) would be considered for inclusion until there has been further investigation of the future directions of national registration and options around regulation of the unregistered professions. It has been made clear through other informal sources within government and the Registration agency, AHPRA, that no other professions will be included in the foreseeable future.
This decision is particularly concerning given that we are aware that, outside Queensland, approximately 30 percent of practising speech pathologists operate outside a regulatory framework as they are not members of SPA nor practice in Queensland. Similarly, other professions who currently do not fall under the Registration Scheme, while having differing penetration levels of membership, also have a portion of their profession not operating under any regulatory scheme.
For these reasons, Speech Pathology Australia believes it is highly important that the government look at a broad national framework of professional regulation which could be three?fold including statutory registration, authorised self-regulation, and other options such as negative licensing for those professions that don’t fall under the first two mechanisms.
Speech Pathology Australia, along
with a number of other professions with existing robust self-regulation
mechanisms in place, has indicated to the government, that where a number of
professions do not come under NRAS, then there needs to be equal recognition
and import given to self-regulation schemes that can mirror the requirements of
registration. Consequently, the current self?regulating professional bodies
(including SPA) have formed an alliance (National Alliance of Self-Regulating
Health Professions) and recently developed a proposal which outlines a
framework whereby there would be nationally recognised and government
authorised self?regulation of specified professions as part of an overarching
single regulatory system. This proposal has recently been forwarded to
government bodies and initial meetings have been scheduled to discuss the
model.
The proposal and information sheet can be viewed by clicking the following links: "Harnessing Self-Regulation" proposal and an Information Sheet
Regardless of the outcome, the Association continues to support that the registration of speech pathologists in Queensland is maintained.
Parallel to this
activity is that Council has agreed to certain recommendations to strengthen
self?regulation processes within the Association. These recommendations will be
progressively rolled out. Certain aspects have been informed by the
requirements for registration where the Association has mapped our
self-regulation processes against that required of registered professions.
Council has also given preliminary consideration to the option of extending
credentialing/certification to non-members (on a fee for service basis). This
is in preparation of being able to extend self-regulation of the profession
beyond only members of SPA, a key feature if regulation of the whole profession
is to occur.
National Registration and/or Self-Regulation-
a further push for inclusion in National Registration rejected
October 2011
As members will be well aware, and as highlighted in the Association’s strategic plan, the profession has continued to seek inclusion in the National Registration and Accreditation Scheme. To this end, a recent further letter and submission was tabled with the National Health Workforce Principal Committee. This submission reinforced our previous arguments as to why it is believed that it is in the public’s interest for the profession of speech pathology to fall under the National Registration and Accreditation Scheme (NRAS). Despite our further lobbying, a meeting of the Australian Health Workforce Ministerial Council and subsequent published Communiqué has indicated that no further professions (with the exception of the paramedics) will be considered for inclusion until there has been further investigation of the future directions of national registration and options around regulation of the unregistered professions.
This decision has occurred as a result of the Government’s parallel work around regulation of unregistered professions and the high number of professions seeking registration for possibly the wrong reasons, that is, to receive professional recognition and status that the registered professions are perceived as now being afforded.
Speech Pathology Australia (SPA) believes
it is highly important that the Government look at a broad framework of
professional regulation which could include statutory registration,
self-regulation, and other options such as negative licensing for those
professions that don’t fall under the first two mechanisms. SPA, along with a
number of other professions with robust self-regulation mechanisms currently in
place, has indicated to the government, that if the profession is not included
in the NRAS, then there needs to be equal recognition and import given to
comparable self-regulation schemes. It is vital therefore that the Association
continues to strengthen its existing self-regulation mechanisms with Council
discussion and direction occurring in this regard (see also the report on
emerging changes in relation to the PSR program on this page). An important
piece of work also occurring is the mapping of our profession’s standards,
certification and credentialing functions against the statutory requirements of
NRAS. In this way, in the absence of being a registered profession, we will be
able to demonstrate that the profession is regulated well and the public can be
assured of appropriate standards and quality of practice. SPA will continue to
work with the professions included in the National Alliance of Self-Regulating
Professions (of which SPA is a member) to influence and inform the Government’s
work in this area.
Lobbying Campaign for National Registration
2009-2010
Background
In 2007 the Council of Australian Governments (COAG) announced there would be a National Registration and Accreditation Scheme for Health Professions. This would initially apply to all health professions that were already registered in all states and territories. Those professions only partially registered were invited to forward submissions for inclusion in the national scheme and was required to give evidence against the established criteria used to determine if a profession requires regulation.
The profession of speech pathology, following extensive consultation, agreed to make a submission for inclusion in the scheme. The joint submission from Speech Pathology Australia and the Speech Pathologists Board of Queensland was submitted in October 2008. In May 2009 it was announced that three additional professions would be included in the scheme, however speech pathology and other professions including occupational therapy would not be included.
In late August 2009, it was further announced by the Australian Health Workforce Ministerial Council (AHWMC) that occupational therapy would be included for 2012, but there was no reconsideration of the speech pathology profession. This issue is considered of high importance for the speech pathology profession as it is believed that it is both in the interest of the public and the profession, that speech pathology come under this national registration framework. Regulatory systems provide the public with an assurance that registrants have met the exacting standards regarding qualifications required to be registered as a speech pathologist. This measure, combined with the restriction of professional title afforded by legislation, provides consumers with a statutory benchmark about who is entitled to offer their services as a speech pathologist.
Regulation of the speech pathology profession through the nation-wide registration and accreditation scheme would address the genuine risks of physical, social and emotional harm inherent in the speech pathology role and will contribute to building and maintaining public confidence in services provided by appropriately qualified speech pathologists.
What do we want members to do?
Members are urged to write to your state local members of parliament to put forward the profession’s position that speech pathology should be included in the National Registration and Accreditation Scheme.
A ‘proforma’ letter to local MPs in your state electorate has been developed for your use. You are welcome to modify this letter to suit your personal circumstances in regard to any direct contact you may have with local politicians. This letter has been written with the purpose of contacting state politicians who should raise this issue with their state health minister or opposition health spokesperson. This is to support national office correspondence and direct lobby of each state health minister.
A Summary document has also been developed outlining the arguments against the AHMAC/Intergovernment Agreement criteria for speech pathology to be included in the scheme. This document should be attached to your letter.
The main Submission and Supplementary Information material are also attached for general reference.
Supporting documents
Constituent letter (proforma) to MPs of your state electorate
Joint Submission including supplementary information in support of Submission (November 2008)
How to contact my local MPs
The following links are provided to access the names and contact details of members of parliament in your state/territory. Be sure to search on Members of the State Legislative Assembly and Legislative Council as appropriate.
NSW- http://www.parliament.nsw.gov.au/prod/PARLMENT/members.nsf/V3Home
Vic- http://www.parliament.vic.gov.au/mps.html
SA- http://www.parliament.sa.gov.au/Members/
Qld- http://www.parliament.qld.gov.au/view/legislativeAssembly/introduction.asp#subnav
Tas- http://www.parliament.tas.gov.au/
ACT- http://www.parliament.act.gov.au/members/index.asp?assembly=6
