In April, the Australian Health Ministers’ Advisory Council (AHMAC) announced a review of the National Registration and Accreditation Scheme (NRAS).
Former director of WA Health Kim Snowball was appointed to independently lead the review. Mr Snowball has held a variety of senior leadership roles in both the public and private health sectors, and was previously director general of WA health. He has also served as chair of AHMAC. Anyone inside the health bureaucracy and COAG tents will have been drinking the neoliberal Kool Aid for many years. Not quite my idea of independent.
In any event he has delivered an entirely predictable consultation paper. The terms of reference included reviewing “the future sustainability of the National Scheme, with a specific focus on the addition of other professions in the scheme and funding arrangements for smaller regulated professions”.
Mr Snowball will now go through the process of receiving a mountain of submissions- including from the AASW, but his views are already crystal clear- the smaller professions are lucky to be in the scheme- and there is not much of a rationale for including anyone else. The review states,
“Many stakeholders have expressed surprise about the 14 health professions that were selected for inclusion in the National Scheme. The surprise relates to the fact some of the professions have a low regulatory workload, either because of the small number of registered practitioners or because the services they provide are unlikely to cause harm. This is further borne out by the relatively low number of complaints and notifications of professional misconduct relating to these groups. In fact, over 95 per cent of all and notifications relate to just five of the 14 regulated professions”
Regulatory Workload- Top 5 Professions
| Profession | Registrants | Proportion of total registrants | Notifications (complaints) |
Proportion of total notifications | Notifications per ‘000 practitioners |
| Medical | 95,690 | 16.2% | 4709 | 54.5% | 49.2 |
| Nursing and Midwifery | 345,955 | 58.4% | 1598 | 18.5% | 4.6 |
| Psychology | 30,561 | 5.2% | 471 | 5.4% | 15.4 |
| Pharmacy | 27,339 | 4.6% | 429 | 5.0% | 15.7 |
| Dentistry | 19,912 | 3.4% | 1,052 | 12.2% | 52.8 |
| Totals | 519,457 | 87.7% | 8259 | 95.8% |
The remaining 9 professions with lower workloads are these.
Lower Regulatory Workload Professions
| Profession | Registrants | Proportion of Total Registrants | Notifications (complaints) | Proportion of total Notifications | Notifications per ‘000 practitioners |
| Podiatry | 3,873 | 0.7% | 44 | 0.5% | 11.4 |
| Physiotherapy | 24,703 | 4.2% | 83 | 1.0% | 3.4 |
| Occupational Therapy | 15,101 | 2.5% | 50 | 0.6% | 3.3 |
| Chiropractic | 4,657 | 0.8% | 72 | 0.8% | 15.5 |
| Chinese Medicine | 4,070 | 0.7% | 30 | 0.3% | 7.4 |
| Osteopathy | 1,769 | 0.3% | 8 | 0.1% | 4.5 |
| Medical Radiation Practice | 13,905 | 2.3% | 26 | 0.3% | 1.9 |
| Optometry | 4,635 | 0.8% | 42 | 0.5% | 9.1 |
| Aboriginal and Torres Strait Islander Health Practice | 300 | 0.1% | 4 | <0.1% | 13.3 |
| Totals | 73,013 | 12.3% | 359 | 4.2% |
The top five account for 87.5%of the registrants and 95.5% of all complaints. The reviewers reaction to this data?
“The Review was tasked to ‘examine the cost effectiveness of the National Scheme (including structure and functions), including where efficiencies might be gained and the impact of the model on the small professions’. Arguably, the above analysis represents over-regulation of the remaining nine professions, which account for just 12.5 per cent of registrants and less than 5 per cent of notifications. If this over-regulation could be addressed, a significant fall in regulatory costs could be achieved.” (my emphasis)
Translated into English? It would be nice to off load this group, but since we are stuck with them, we should work out a way of regulating them at less cost.
The implications for social work? Our numbers would put us in the low risk, over-regulated category. We would be nowhere near the numbers of psychology- we have a greater proportion of female members, and a lesser proportion in private practice. Our numbers would probably be closer to occupational therapy.
The reviewer in his wisdom is suggesting that 11 million dollars could be saved by “the formation of a single Health Professions Australia Board to carry regulatory responsibility for the nine professional groups, replacing the existing nine National Boards.”
In effect there may be no guarantee that all professions would have even one of their members on this Board. This will not go down well with those nine professions, but the proposal could be sweetened by passing the savings on via lower registration fees for the members of those professions. As things stand those professions are significantly cross subsidising the regulatory work needed for the top 5.
The probability of social work being included in NRAS? Consider these paragraphs from the Review.
“At the time the National Scheme was conceived the Council of Australian Governments (COAG) established threshold criteria relevant to risk to assist in assessing the need for statutory regulation of unregulated health occupations.
These criteria must be applied to the consideration of any future entrants into the National Scheme. It is also important that the risk profile for additional professions carefully considers the context in which the practitioners operate. For example, if the majority of practitioners are in employment – rather than self-employed – then an additional layer of regulation already exists. The COAG criteria have been described as ‘gateway criteria’ required to be met prior to further regulatory impact assessment in accordance with the COAG best practice regulation requirements, assessed by Office of Best Practice Regulation.
Inclusion in the National Scheme, and the additional regulation that it imposes, must only occur where community safety is at significant risk and no alternative, more cost-effective means of regulating the profession is available.” (my emphases)
In summary – social work does not meet the COAG risk criteria. Additionally, only a minority of our members are self employed. Therefore COAG would think self regulation is more cost effective.
We need to honor our commitment to see through to conclusion this convoluted never-ending process. But we must not forget why we are doing this, (the safety of the people we work with). That means actively pursuing plan B- combining with other professions to form a large self regulation umbrella.
The paper was a very detailed, direct and informative document. From my reading of the document as a social worker it appears it would be somewhat miraculous to see the social work profession being registered formally anytime soon and that perhaps the implementation of title as the Australian Association of Social Workers (AASW) has implemented might herald the need ultimately for the Association and its membership to wake-up to the reality of the apparent low chance of formal government regulation of the profession and instead purse a different model as an informal ‘self-registered-self-titled’ profession using innovation and actions elsewhere. The clock is ticking.