Endorsement

The public interest case for area of practice endorsement

There are significant public interest arguments for allowing area of practice endorsement to be used for the regulation of the psychology profession. In approving the nine areas or practice, Ministerial Council agreed with the Board that the public benefit of area of practice endorsements for the psychology profession outweigh the costs of additional regulation.

An endorsement function allows the Board to take an active role in promoting the psychological welfare of the community, through ensuring quality of services and the provision of adequate training and supervision for the psychology profession.

The public benefit in maximising the endorsement mechanism is demonstrated by the following:

Requiring an advanced qualification

Ministerial Council determined that there is public benefit in having access to psychologists who choose to undertake additional formal education in the nine approved areas of practice.

Area of practice endorsement is a regulatory mechanism under the National Law. It enables a notation to be included on the public register to allow the public, employers and others to identify practitioners who have completed an approved qualification and supervised experience in an approved area of practice. The advanced training is in addition to the minimum level of training required for general registration. This additional training may focus on delivery of specific treatments, using more complex techniques, or delivering services that require judgments and carry risk in specified advanced areas. Additional training is required for effective provision of these services.

The National Law covers both registration and accreditation functions. The advanced training must be accredited and then approved by the Board as a qualification for registration. For the psychology profession the Board has delegated the accreditation function to the Australian Psychology Accreditation Council (APAC).

Determining the required professional competencies

The Board can ensure that the public is protected by determining what professional competencies are required for an area of practice endorsement and how the competencies can be achieved.

The standard for endorsement competence is met by completing a Board approved education and training sequence after achieving general registration. In meeting the Area of practice endorsement registration standard, the Board is able to assure the public that a psychologist has done additional training and supervision in a specific area of practice and has met the competency standard.

Aligning areas of practice endorsement with community need

Consumers and public safety are at the centre of psychology regulation. Aligning areas of practice endorsement with community need and ensuring that each area of practice is fit for purpose as a regulatory tool is one way to protect the public.

Promoting consumer choice, and matching consumer need with help

An area of practice endorsement function provides the public with assurance that psychologists who have advanced qualifications are trained to a consistent and acceptable level of competency. Endorsements in areas of practice promote consumer choice and makes it simpler to match consumer need with the appropriate help. This is particularly important for clients who are seeking help in times of stress or crisis. For example, if a child who was an elite athlete and needed help with confidence during competitions, a sports and exercise psychologist could be selected (or referred to by another health professional) as they have completed advanced training in performance. For a consumer who was suspected to have early onset dementia and needed an assessment, a clinical neuropsychologist could be selected (or referred to) because of their advanced training in psychometric assessment.

Understanding the reasons psychology wasn’t granted specialist title in 2010

There were five main reasons specialist title was not approved for psychology at the beginning of the national scheme:

1. The public interest case was not made. Specialist title requires increased regulation, and the profession was unable to convince Ministerial Council that there was enough need for increased regulation. Only one state (WA) had specialist title prior to the National Scheme, with the rest of the country effectively utilising a self-regulatory model (via membership of the relevant Australian Psychological Society (APS) College). This suggested that the profession was developing and identifying specialised practice without the need for statutory regulation. In addition, in WA there was no restriction on practice by reason of having specialist title, and there was no separate specialist register. This meant that WA specialist title was more aligned with endorsement not specialist registration under the National Scheme.
   
   
2. There was no national standard for the accreditation of programs that led to a qualification as a specialist. The Australian Psychology Accreditation Council (APAC) did not have accreditation standards for specialisation (or endorsement) until 1 January 2019. (There were entry requirements into the APS Colleges via APS College Course approval guidelines, but this was an assessment for membership of a professional organisation and was conducted by the APS not APAC).
   
   
3. Specialties in psychology are less well established and bounded than in other professions such as medicine and dentistry. For example, a medical practitioner on the specialist register might work as an anaesthetist or a neuro-surgeon, but not usually as both. For psychology, there is overlap between the competencies and work for some areas of practice endorsement. Psychologists with different endorsements might undertake the same work. For example, both a clinical psychologist and health psychologist have expertise for working in inpatient eating disorder programs. Most members of the public could readily describe the difference between the work roles of an anaesthetist and a neuro-surgeon but might struggle to describe the difference between a clinical and health psychologist.
   
   
4. Endorsement was seen to fit the psychology profession better than specialisation. A single register allows for more flexibility and means that psychologists could hold more than one endorsement and move between endorsements over the course of a career. Specialisation would mean less flexibility and result in a higher level of oversight that seemed out of proportion to the actual risks to the public from psychology practice.
   
   
5. There was a lack of agreement in the profession about necessary qualifications for specialisation. The psychology profession had varying views regarding qualification requirements, scope of practice, specialist titles, impact on workforce supply, Medicare rebate mechanisms and timing of implementation.

For more information see the Board’s statement from February 2010:

• Psychology Board of Australia statement on area of practice endorsement - February 2010 (259 KB, PDF)

Understanding area of practice endorsement transition provisions and when they ended

Area of practice endorsement did not exist in Australia before 1 July 2010, when the national scheme began.

Prior to the national scheme - only Western Australia (WA) had any mechanism for formally recognising advanced qualifications and practice (specialist title registration). This system had been in place for about 30 years. No other Australian regulator operated a similar system. In other states and territories, the only pathways for recognition of qualifications were via professional organisations such Colleges of the Australian Psychological Society (APS), or through industrial relations mechanisms where specific titles were used for senior practitioners (such as clinical psychologist in the health department), or via approval to provide clinical psychology Medicare services (clinical psychology only).

At the start of the national scheme in July 2010, the Board instituted several transitioning provisions for area of practice endorsement. The purpose of the transition provisions was to allow psychologists who had previously obtained recognition of their postgraduate qualifications and training (or equivalent), or were actively seeking such recognition, at the time the national scheme commenced in 2010 to become endorsed. This included the following provisions:

• registrants from WA were transitioned into the relevant area of practice endorsement under section 281 of the National Law
• members of the nine APS Colleges (at 1 June 2010) who gave the APS permission to give their details to the Board, were transitioned into the relevant area of practice endorsement
• members of the APS, who were undertaking an Individual Bridging Plan (IBP) for entry into one of their Colleges had more time to complete their IBP and apply for an area of practice endorsement
• psychologists recognised by Medicare as providing clinical psychology services were transitioned into the clinical area of practice endorsement, and
• specific transition provisions for students enrolled in a higher degree on 1 June 2010.

The transition period ended on 30 June 2013. Given that there was no area of practice endorsement registration category prior to the national scheme, and the transition period was over three years, these transition provisions were considered generous.

Since the end of the transition period, an area of practice endorsement in any of the nine areas of endorsement are only available to a person who applies to the Board and meets the qualifications and supervised practice standard of the Board outlined in the Area of practice endorsements registration standard.

Understanding how the area of practice endorsement transition provisions were in the public interest

Area of practice endorsement did not exist in Australia until the beginning of the national scheme in 2010. Once the Ministerial Council approved area of practice endorsement for psychology, the Board needed to determine whether each individual psychologist would have to apply for endorsement and be assessed against the Area of practice endorsements registration standard, or if there could be transition arrangements.

To provide clients with essential access to treatment, and provide a fair and equitable transition for psychologists, the Board determined that there would be a three-year transition period. The Board adopted the policy that psychologists with WA specialist title, APS College membership and Medicare recognition as a clinical psychologist did not have to apply for endorsement but could transition to the relevant endorsement. Since the criteria in 2010 for WA specialist title, APS College membership and Medicare recognition as a clinical psychologist had many parallels with the Endorsement Standard, this was seen to be of low-risk to public safety. This meant that:

• Clients had immediate access to psychologists with endorsement from the beginning of the scheme. There were 5884 psychologists with an area of practice endorsement in December 2010.
• Clients were not subject to breaks in their treatment due to long queues and delays in processing thousands of applications for endorsement arriving at the beginning of the national scheme. This would have required significant additional resourcing by the Board over several years, the significant cost of which would have been passed on to registrants
• Psychologists with older qualifications (undertaken before APAC was formed in 2003), or those who had been assessed with equivalent qualifications for APS college membership or for Medicare purposes could continue to provide services to their clients.
  Since the Area of practice endorsement standard requires an APAC-accredited qualification, and there is no option for recognised prior learning (RPL) in the standard, some psychologists would not have been able to meet the endorsement standard. Effectively this could have meant that some psychologists would have held APS College membership and/or Medicare eligibility but not be eligible to hold the relevant endorsement. Such a situation would have been very confusing to the public.
• Psychologists who fell within the transition provisions were not required to complete an application for area of practice endorsement, reducing administrative burden and costs for both psychologists and Ahpra.