Chapter 2


Registration is a mandatory requirement for health practitioners who wish to use one of the protected titles (such as ‘medical practitioner’ or ‘nurse’) under the National Law. The Australian Health Practitioner Regulation Agency (AHPRA) manages the registration and renewal processes for practitioners and publishes a national register, which is a list of every registered health practitioner in Australia.
This chapter gives an overview of the registration process and outlines the issues identified by inquiry participants, including:
registration standards and related processes;
supervised practice requirements;
overseas-qualified health practitioners;
specialist registration and areas of practice; and
unregulated professions.

Registration processes

AHPRA manages the registration process for the 16 regulated professions. There are several types of registration, including general registration for practitioners who meet the eligibility and qualification requirements set out in sections 52 and 53 of the National Law, and specialist registration for practitioners who meet the required standards to use a ‘specialist title’ within a profession. For example, in the general field of dentistry there are 13 recognised specialisations, such as oral surgery and forensic odontology.1
In 2019-20, there were 801 659 registered health practitioners in Australia.2 Table 2.1 (on the next page) provides a list of the regulated professions and their accompanying protected titles.
Each profession has its own standards (developed by the respective national board) that applicants must meet in addition to the five core standards for all professions: criminal history, English language skills, recency of practice, continuing professional development and professional indemnity insurance.3
The assessment of a complete application can take six to eight weeks, depending on the time of year. A specialist application, where a general registration is already held, has a processing time of approximately two weeks. Student assessments are usually made two weeks after AHPRA receives a graduate’s results from their education provider.4
Following a successful assessment, individuals are informed of the outcome and listed on the national register of practitioners.
Table 2.1:  Register of practitioners and protected titles
Protected title
Aboriginal and Torres Strait Islander Health Practice
Aboriginal and Torres Strait Islander health practitioner
Aboriginal health practitioner
Torres Strait Islander health practitioner
Chinese Medicine
Chinese medicine practitioner
Chinese herbal dispenser
Chinese herbal medicine practitioner
Oriental medicine practitioner
Dental therapist
Dental hygienist
Dental prosthetist
Oral health therapist
Medical practitioner
Medical Radiation Practice
Medical radiation practitioner
Diagnostic radiographer
Medical imaging technologist
Nuclear medicine scientist
Nuclear medicine technologist
Radiation therapist
Nursing and Midwifery
Registered nurse
Nurse practitioner
Enrolled nurse
Midwife practitioner
Occupational Therapy
Occupational therapist
Pharmaceutical chemist
Physical therapist

Registration standards

The national boards are responsible for setting the registration standards, codes and guidelines describing the requirements and expectations of registered health practitioners and students in their respective fields of practice.5
In addition to developing the five core registration standards, national boards can ‘endorse’ the registration of suitably qualified practitioners. An endorsement of registration recognises that a person has additional qualifications and expertise in an approved area of practice and/or for scheduled medicines.6
The registration standards for each profession are reviewed at least every five years or when a national board deems appropriate and necessary.7
Many submitters to this inquiry were supportive of the common registration standards but raised concerns about the registration standards for specific professions.8 For example, the Australian Psychological Society highlighted that there have been recent changes to the training accreditation pathways for psychologists, and said a review is required to reflect these changes.9
Any change to the registration standards for regulated professions requires approval from the Ministerial Council. When changes are proposed, the national board must undertake a consultation process, a regulatory impact assessment, and a patient health and safety impact assessment.10

Continuing professional development

Each regulated profession has requirements for the education, training and continuing professional development (CPD) practitioners must undertake to maintain their registration.
The committee heard there is limited access to CPD in rural and regional areas, and that the workload and costs of CPD are increasing.11 One submitter informed the committee:
At present to renew registration evidence of continuing professional development (CPD) gained over a three year cycle is needed. A doctor may need to accrue 150 credits over three years. AHPRA proposes that this should change to 50 credits per year. This is fine for metropolitan practitioners who have ready access to CPD close to home, but not so for remote practitioners. Travelling for a course that might take a doctor away for a week, in the current system might accrue 80 credits, but if in the proposed arrangement 30 excess credits can’t be carried forward for another year, this unfairly penalises rural and remote doctors.12
Several submitters also commented that CPD requirements for some health practitioners are excessive in comparison with other professions, such as the legal profession.13
For example, most registered practitioners are required to complete 20 hours per year of CPD, with psychologists required to do 30 hours and medical practitioners required to do 50 hours.14 The Medical Consumers Association submitted that:
Professional development requirements for psychologists in particular are wholly disproportionate to any possible benefits to their clients or themselves… NSW solicitors, by contrast, only need complete 10 CPD hours annually.15


The committee received evidence that there can be lengthy delays in the registration process, which may leave a practitioner without employment for a significant period of time while they wait to begin supervised or independent practice.16
The Pharmacy Guild of Australia (the Guild) noted delays often occur over the summer period, which is a peak period of demand for community pharmacies. The Guild said these delays reduce the ability for community pharmacies to meet demand, particularly in regional and remote locations where the workforce is limited.17
The Australian Nursing and Midwifery Federation (ANMF) also commented that ‘unacceptable delays’ in the registration process cause significant difficulties, particularly for students and recent graduates trying to secure places in transition support programs, and for workplaces in managing staffing.18
AHPRA noted the following common reasons for delays in finalising a registration:
insufficient evidence or documentation;
waiting on information from third parties; and
waiting on board or committee approval.19
AHPRA also reported that in 2020-21, the median time to decide the application for registration was two days, the average was 17 days, and it took on average nine days to finalise a graduate’s registration.20


When health practitioners wish to re-enter the profession after a break from practising they are required to reregister with AHPRA. Each national board has different requirements for this process.
The committee received evidence that the re-registration process for qualified health practitioners is onerous and imposes a significant workload on the practitioner and their supervisor. This is a particular concern in femaledominated occupations where significant numbers leave the workforce for extended periods of time.21
Submitters and witnesses told the committee the requirements to reenter the workforce act a disincentive, and this contributes to workplace shortages. The ANMF commented that:
A commonly required condition is that a member completes a refresher or re-entry program, even though there are very few programs available in Australia for nursing or midwifery refresher or re-entry… The [Nursing and Midwifery Board of Australia] therefore needs to review the re-entry policy to ensure that there are appropriate and achievable pathways that allow previously registered nurses and midwives to re-enter the professions.22
Associate Professor Carol McKinstry, the President of Occupational Therapy Australia, told the committee the biggest barrier to re-entry is supervision:
While we think that, yes, supervision is important, it's that the person reentering or wanting to re-register has to source supervision, so they are given, if you like, temporary or not full registration. Therefore, it's hard to find employment. It's a sort of a catch 22. Our profession is made up of women—over 90 per cent women—so we do have women coming in and out of the workforce. If they're absent for long periods, then they do need to go through this process. We just feel that it is a bit onerous at the moment and we'd like to streamline it a little bit, particularly to try and make it more attractive for people to re-enter the workforce.23

Student registration

Under the National Law, all students enrolled in an approved program of study or undertaking clinical training must be registered as a student with the respective national board. Registration is required for the duration of study or training, and is organised on the student’s behalf by the education provider.24
Inquiry participants raised concerns about the inconsistency of requirements between universities; the role of universities in providing students with information about registration requirements; and the relevancy of courses to the registration standards.25
The Australian Psychological Society (APS) submitted that some universities do not allow students to commence their studies until registration is approved, whereas others allow students to start studying but they require registration before starting a placement. They also said that AHPRA’s inefficient registration processes can lead to delays for students in starting their studies and placements.26
Several submitters also commented on the need for universities and education providers to inform and educate students about registration requirements.27 For example, AHPRA’s Community Reference Group submitted that:
Universities need to balance teaching the ‘body of knowledge’ with the registration standards and requirements. Although exposure to the role of Aphra and the National Boards is part of the education program, work ready approaches mean registration needs to be understood and prepared for in a way that means students understand and are ready for registration at the earliest time.28
The Australian College of Nurse Practitioners’ submission said education providers should focus on registration when they are developing courses. It reported that several courses fail to produce students who can satisfy the registration standards and therefore they are unable to commence practice.29
Similarly, the ANMF recommended student registration be brought into line with practitioner registration, including undergoing identity, criminal history and English language proficiency checks. This would avoid situations where students undertake a lengthy and costly course, only to discover their registration is not accepted or delayed due to an adverse disclosure in their application.30
Moreover, submitters suggested that student registration data, together with enrolment and retention numbers, could be very useful for national workforce planning, and for identifying programs that have high attrition rates.31
AHPRA informed the committee that an Education Provider Reference Group has recently been established to improve its engagement with education providers. This forum provides an opportunity for education providers to provide advice to AHPRA on developments in the implementation and operation of the National Scheme that relate to students and graduates.32

COVID-19 registration

In response to the COVID-19 pandemic, AHPRA established a pandemic response sub-register as a temporary measure. The sub-register enabled health practitioners who had held general or specialist registration in the past three years to return to practice.33
For example, retired health practitioners who were properly qualified, competent and suitable were able to be listed on the pandemic sub-register to assist in the pandemic response.
In early April 2021, at the request of the Commonwealth Government, and with the support of all health ministers, AHPRA extended the sub-register for a further 12 months for retired nurses, doctors and other registered health practitioners. This also occurred for Aboriginal and Torres Strait Islander health practitioners, medical practitioners, midwives, nurses and pharmacists.34
For other professions, such as diagnostic radiographers, physiotherapists and psychologists, the sub-register closed as planned on 19 April 2021.35

Supervised practice

A practitioner may be required to work under supervision as a condition of registration in some professions, and supervision may also be imposed as a condition on a practitioner as a result of a notification.36
Inquiry participants recognised that supervised practice is important to ensure practitioners are qualified and suitably skilled to perform their duties, however, they highlighted several issues with the current supervised practice arrangements. This included: the availability and funding of supervision; impact of supervision requirements on employment and workforce shortages; and the standards for supervision arrangements.37

Availability of supervisors

Submitters commented that it can be difficult to find a suitable supervisor, which is exacerbated in rural and regional areas, and it has flow-on effects for practitioners’ employment and for the health workforce as a whole.38
The Australian Acupuncture and Chinese Medicine Association submitted that practitioners in rural and remote areas find it difficult and prohibitively expensive to comply with the supervision requirements.39
Occupational Therapy Australia told the committee that experienced clinicians are often disinclined to supervise occupational therapists with whom they do not work directly.40
Similarly, the Australian Nursing and Midwifery Federation told the committee that ‘… supervision poses a major burden for our members and their employers everywhere’41 and that:
Some members who have been granted re-entry [to the workforce] to practice with supervision conditions have been told by health services that their service does not offer positions with a period of supervised practice.42
The Australian and New Zealand College of Anaesthetists also said there is no compensation for practitioners who act as supervisors, which can be a disincentive to taking on the role.43

Impact on the workforce

The difficulties practitioners report in obtaining a supervisor can create flowon effects to workplace arrangements. Occupational Therapy Australia submitted that experienced therapists are often ‘disinclined’ to undertake supervision requirements for a practitioner they do not already work with or know.44
In regards to supervision requirements, the Queensland Nurses and Midwives’ Union recommended that consideration be given to:
… ensuring the process is not unnecessarily difficult such that competent practitioners are dissuaded from participating as supervisors, and, potential supervisees are lost to the workforce due to an inability to fulfil the conditions applied.45

Administrative burden

Several submitters informed the committee that supervised practice is a difficult process and can cause delays for successful registration.46 For example, Optometry Australia described the current process as ‘difficult and stressful’ to navigate, and that delays in the approval of a supervisor by the national board can negatively impact a practitioner’s future employment and career.47
This concern was also raised by the APS:
Long delays often occur for provisionally registered psychologists to become fully registered due to infrequent Board meetings and a backlog in case-loads. In addition, confusing administrative forms and stated ‘wait times’ being missed, contribute to further delays which can cause stress, frustration and financial impacts.48
Further issues in relation to supervision are discussed in the next chapter.

Review of supervised practice requirements

AHPRA told the committee that 13 national boards (excluding pharmacy and psychology) are finalising a supervised practice framework to enable a consistent, responsive and risk-based approach to supervised practice.49
The proposed framework provides four levels of supervised practice, but not all levels are to be used depending on the purpose of the supervised practice. This includes:
direct supervision;
indirect supervision with a supervisor physically present at the workplace;
indirect supervision with a supervisor accessible by phone or other means; and
remote supervision, where the supervisor is not present at the workplace.50

Overseas-qualified health practitioners

The national boards are responsible for assessing the eligibility and suitability of overseas-trained health professionals seeking registration under the National Scheme. To obtain registration, practitioners must be assessed as having qualifications and experience substantially equivalent to a boardapproved qualification, and meet the core registration standards for that profession.51
Assessment against the core registration standards may be varied to reflect the context of applications, for example, by conducting international criminal history checks and English language proficiency tests.52
The committee received a breadth of evidence regarding overseastrained health professionals (also known as international medical graduates or ‘IMGs’). The issues raised included the impact on workforce shortages, timeliness and duplication of the registration process, and English language requirements.
These issues were also raised between 2010 and 2012, when the House of Representatives Standing Committee on Health and Ageing inquired into the registration processes and supports for overseastrained doctors. That committee’s final report made 45 recommendations, and made the following observation:
… it is clear that whilst IMGs generally have very strong community support, they do not always receive the same level of support from the institutions and agencies that accredit and register them.
… it is my sincere hope that the report’s recommendations will help to resolve the administrative difficulties faced by many IMGs, and ensure that those wishing to practise medicine and call Australia home in future may do so with certainty and clarity of what is expected of them.53

Workforce shortages

Many submitters and witnesses commented on workforce shortages in their professions, noting that these shortages are particularly acute in rural and regional areas.54
Occupational Therapy Australia (OTA) commented that more allied health providers are recruiting practitioners from overseas, but the costs involved can be prohibitive (estimated at $20 000 in visa application fees, administration, and training and supervision costs per recruit).55
A similar concern was echoed by the Pharmacy Guild of Australia. It said that international pharmacists are critical to addressing shortages, especially in regional, rural and remote locations. However, the Guild said current visa classes are only short term, and they are an expensive way to address longterm staffing needs.56
Other submitters noted shortages within specialisations. The Royal Australian and New Zealand College of Psychiatrists (RANZCP) explained that the National Medical Workforce Strategy intends to steer away from a reliance on IMGs. However, RANZCP is concerned there is an undersupply of psychiatrists and significant challenges in recruiting and retaining practitioners, particularly in rural and remote areas.57
In light of these concerns, RANZCP suggested AHPRA needs to have greater awareness of the current workforce shortages when considering additional requirements for international medical graduates training.58

Timeliness and duplication of registration process

Inquiry participants commented on the impacts of onerous and lengthy registration processes, and the duplication of prerequisites that overseasqualified health professionals are required to meet in order to practice in Australia.59
OTA said the registration process for IMGs is long and laborious, and working during the waiting period is not permitted.60 Similarly, Associate Professor Vinay Lakra, President of the Royal Australian and New Zealand College of Psychiatrists told the committee:
… the number of times AHPRA changes the forms without us even knowing about it! You fill in a form and then you realise that, actually, that's an old form; that form has changed. These are small, little things, which then, of course, add delay.61
The Australian Psychological Society (APS) noted that migrants’ qualifications have to be assessed twice—once by the Department of Home Affairs and again by AHPRA for registration. APS said that this is an unnecessary duplication, and leads to delays, increased costs and stress for the practitioners.62
The OTA also commented on this issue, submitting that there are ‘multiple hoops’ involved in IMGs obtaining registration in Australia, including a skills assessment, resubmitting paperwork and obtaining a supervisor’s agreement—all for only ‘limited registration’.63
To improve these processes, the OTA suggested embedding the practice introduced during COVID19 that permitted the electronic lodgement of applications and documents and the provision of clear, consistent and flexible guidance about requirements for the certification of documents.64

English language requirements

A migrant whose primary language is not English, and is not from one of six ‘recognised’ countries, needs to take a language test to demonstrate they meet the English language standard required for registration.65
Inquiry participants noted that there is a great deal of confusion about the English language requirements, as well as a lack of consistency between the regulated professions.66
For example, the Queensland Nurses and Midwives’ Union submitted that the current English standards are inconsistent and have several deficiencies, including:
the lack of health-specific language testing;
inconsistency between the nursing and midwifery board requirements; and
the inability of the national board to exercise discretion in determining the competency of practitioners’ language skills.67
The committee also received evidence that the current English requirements may be perceived as discriminatory and do not recognise practical experience in English-speaking countries.68
Amnesty International said the list of recognised countries does not include countries where the level of English is high, such as Sierra Leone, in comparison with some of the recognised countries, such as South Africa.69 Refugees, Survivors and ExDetainees (RISE) also said that the language test does not provide the intended assurance of English language competency.70
AHPRA informed the committee that the national boards have commenced a review of the English language requirements. The proposed revisions to the English registration standards were expected to be available for public consultation during the last quarter of 2021.71

Specialist registration

During the course of the inquiry, the committee received evidence about regulatory gaps with the categories of specialist registration, the difficulties of regulating across different professions, and within areas of practice.72
Specialist registrations apply in the dentistry, medicine and podiatry professions. ‘Specialist’ is a type of registration granted to practitioners who, in addition to the standard registration requirements for their profession, meet specialist eligibility requirements in one of the categories approved by the Ministerial Council.73

Concerns about the cosmetic surgery industry

Currently the title of ‘specialist plastic surgeon’ is recognised as a specialty practice within medicine, whereas ‘cosmetic surgeon’ is not, and therefore there are no additional registration requirements for medical practitioners who use this title.74
Concerns about the cosmetic surgery industry received significant public attention due to recent media reports. Following these reports the committee received a number of confidential submissions from patients of the cosmetic surgery industry as well as public submissions from former employees of cosmetic surgery practices.75 The committee also held an in camera hearing and heard from individuals affected by the cosmetic surgery industry and AHPRA representatives.
The committee heard concerns that patients have been ‘misled’ by the cosmetic surgery industry to believe that the medical practitioners that perform cosmetic surgery are registered surgical specialists under the National Scheme.76 The committee heard in camera, that patients did not understand the different registration requirements, or lack thereof, between a plastic surgeon and a cosmetic surgeon.
The committee also heard specific concerns about the conduct of medical practitioners performing cosmetic surgery, including poor infection control practices, dangerous working hours, improper advertising and promotion, and breaches of patient confidentiality.77
AHPRA told the committee that currently under the law they cannot stop a medical practitioner calling themselves a cosmetic surgeon, but they can look at concerns about the conduct of those people:
… if you are a patient who has received care from a registered medical practitioner which has not met the required standards, or you have concerns about that care, you can raise that concern with us, whether that person calls themselves a cosmetic surgeon or a plastic surgeon …78
Over a three year period (1 July 2018 to 30 June 2021), AHPRA received 16 226 notifications about medical practitioners, of which AHPRA identified 313 notifications relating to 183 practitioners that concerned ‘botched surgeries’ or a surgical outcome with a complication or resulting in injury. Of those notifications that specifically concerned cosmetic procedures, 52 per cent related to medical practitioners who are registered in a surgical specialty (mostly specialist plastic surgeons).79
During an in camera hearing, AHPRA acknowledged that recent media reports highlighted the significant issues in the cosmetic sector and that its complaints data is not providing AHPRA with a comprehensive overview of these issues.80

Regulating the use of the title ‘cosmetic surgeon’

The Australasian Society of Aesthetic and Plastic Surgeons (ASAPS) said AHPRA must address ‘the misleading and dangerous use of the unregulated title “Cosmetic Surgeon” as it implies it is a specialist registration.’81 ASAPS said that 81 per cent of Australians believe that if a practitioner uses this title then they are a registered specialist surgeon.82
ASAPS also suggested that AHPRA has not done enough to address concerns about medical practitioners performing cosmetic surgery within the scope of the existing legislation. Specifically, that the National Law already prohibits a person from using the title ‘specialist health practitioner’.83
The Australasian College of Cosmetic Surgery and Medicine (ACCSM) noted that the title ‘cosmetic surgery’ is not able to be recognised as a medical speciality under current regulations because any new speciality is required to reduce the overall burden of disease, ‘which cosmetic surgery obviously does not’.84
The ACCSM told the committee that it does not support registering the specialist title of ‘surgeon’ or ‘cosmetic surgeon’ in isolation, without linkage to competency-based accreditation in cosmetic surgery, although it agreed that the lack of regulation is unsafe and that ‘untrained doctors representing themselves as cosmetic surgeons is confusing and dangerous for patients’.85
Instead, the ACCSM proposed a competency-based National Accreditation Standard for cosmetic surgery. This would require any medical practitioner, including specialist plastic surgeons, performing cosmetic surgery to meet the accreditation standard and be recorded on a public register, which AHPRA would maintain.86 Dr Daniel Fleming, past president of the ACCSM, told the committee:
… the best way—to protect patients is to have an accreditation system specifically for cosmetic surgery for all doctors who perform it, whether they're plastic surgeons, cosmetic surgeons or from any other group. Critically, this system will involve that doctors are trained in basic surgical skills... It's very important; they know how to operate, but further they need specific cosmetic surgery training, because that does not exist at the moment.87

Proposed law reform and review of the industry

As a part of the consideration of the ‘Tranche 2’ reforms to the National Law, it is proposed to restrict the use of the title ‘surgeon’ to provide better information for the public about the qualifications of surgeons. This proposal is subject to further consultation and is expected to proceed separately to the rest of the Tranche 2 reform package.88
The communiqué from the COAG Health Council89 in November 2019 about these reforms states:
The use of the title “surgeon”, including by way of “cosmetic surgeon”, by medical practitioners, non-specialist surgeons or those without other appropriate specific training can cause confusion among members of the public. Ministers agreed that further consultation should be undertaken on which medical practitioners should be able to use the title “surgeon”.90
On 30 November 2021, AHPRA and the Medical Board of Australia announced an external review of the cosmetic industry, including mechanisms to strengthen the regulation of practitioners in the industry. The review will be led by the Queensland Health Ombudsman and panel members include the National Health Practitioner Ombudsman, the Chief Medical Officer for the Australian Commission on Safety and Quality in Health Care, and the Chief Executive Officer of CHOICE. The review is expected to report in mid-2022.91

Concerns about podiatric surgery

The Royal Australasian College of Surgeons (RACS) also voiced concerns about the circumstances where a non-medical profession overlaps into the area of surgical practice. RACS noted that podiatric surgery has been recognised as a speciality of podiatry, but it is concerned that the use of this term could be misleading as ‘podiatrists are not doctors and do not have a medical degree’.92
RACS further highlighted that the accrediting authority for podiatric surgery, training and education is not the Medical Council of Australia, as it is for all other surgical specialities, but rather it is the non-medical Podiatry Accreditation Committee. RACS said this causes confusion for patients and can lead to poorer outcomes in comparison with work by specialist orthopaedic surgeons.93

Areas of practice endorsement

Another sub-category of registered practice, similar to a specialist registration, is an area of practice endorsement (AoPE). It identifies practitioners who have completed an approved postgraduate qualification and supervised training in an area of practice and/or for scheduled medicines.94
Practitioners with an AoPE can use the title associated with that area of practice. For example, in the field of psychology, a practitioner can be endorsed to practice as a forensic psychologist or as a health psychologist.95
The APS stated that greater awareness, clarity and education are required about the use of AoPEs, especially for the ‘clinical’ area of practice endorsement in psychology. The APS submitted that it is confusing for patients when the phrase ‘clinical’ is used to describe a psychologist working in a clinical setting, rather than how it is meant under the area of practice endorsement.96

Unregulated professions

There are several professions not regulated by AHPRA, such as social work, audiology, and aged care and personal care work. As practitioners in these fields are unregulated, there is no standard or code to hold them to account, and no requirement for a minimum level of qualifications.97
For a new profession to be included in the National Registration and Accreditation Scheme (NRAS), approval is required by the Ministerial Council and is subject to a formal regulatory impact assessment.98
The committee received evidence, particularly from those in the social work and aged care sectors, that these unregulated professions require oversight and should be regulated.99
The Australian Association of Social Workers told the committee that anyone can call themselves a social worker regardless of whether they have any training or qualifications. It said this poses a significant public risk as social workers ‘support people across a range of issues including mental health, family violence, child abuse, elder abuse, disability, housing, poverty, alcohol and other drugs’.100
Similarly, the Australian College of Nursing (ACN) advocates for all health care and personal care workers to be regulated to bolster public trust in the health and aged care systems.101 ACN estimated that 70 per cent of aged care staff may be unregulated and said mechanisms are required to ensure the safe, ethical and professional conduct of these workers who are ‘… often involved with the most intimate aspects of patient care, such as bathing, toileting and putting patients to bed …’102
The Australian Nursing and Midwifery Federation expressed similar concerns:
Our members have long expressed concern that care workers, particularly but not only those employed in nursing homes, are not regulated. These concerns, raised by registered and enrolled nurses and by care workers themselves, relate to the current lack of consistency across educational preparation requirements and competence, and even a minimum English language standard.103
AHPRA noted that approval for new professions to be considered in the NRAS is a matter for health ministers, not AHPRA or the national boards.104

Committee view

The committee acknowledges the importance of the registration process and registration standards to ensure that health practitioners are fully qualified and suitable to practice under a protected title.
The committee notes that across the breadth of evidence received, inquiry participants were in general agreement and supported the five common registrations standards. The committee recognises that there is a range of views within each profession about additional registration standards—such as specialists and areas of practice endorsement—and much of the evidence received provides ideas on how to improve the standards in specific professions.
However it is apparent that some practitioners in rural and regional areas are experiencing real difficulties meeting the required standards for continuing professional development (CPD) and the committee encourages AHPRA to examine mechanisms to assist these practitioners to undertake CPD. The CPD requirements should not be unduly onerous, and must take into account accessibility and workforce issues experienced in rural and regional areas.
The committee echoes the views of many inquiry participants that any proposed changes to the registration standards should focus on public safety and be mindful of the administrative burden for practitioners.
The timeliness of the registration process for both Australianqualified and overseas-qualified health practitioners is clearly an issue. The committee encourages AHPRA and the national boards to consider ways to reduce the time taken to approve registrations.
In relation to student registration, the committee is concerned that there could be situations where individuals will only learn that they are ineligible for registration or experience significant delays in their registration after they have completed a course of study or training program.
The committee encourages AHPRA and the national boards to engage broadly with education providers, including through its Education Provider Reference Group, on practical ways to support students understand and prepare for the registration process and requirements. This could include consideration for a preliminary registration process.
The committee is pleased that the English language requirements for overseasqualified health practitioners is currently being reviewed and will be open for public consultation.
The committee was gravely concerned to hear about the issues arising from the cosmetic surgery industry. While the committee welcomes AHPRA’s review of the industry, the committee is concerned that AHPRA, until recently, did not act on multiple complaints against some practitioners within this sector. The committee is hopeful that the inquiry announced by AHPRA will assist in identifying and addressing these issues.
The committee is also particularly concerned that the title ‘surgeon’ is currently unregulated, and practitioners using this title may not have any qualifications or experience in surgery or the specialised fields of surgery. The committee considers this to be a substantial risk to public safety.

Recommendation 1

The committee recommends that proposed reforms to the National Law to regulate the use of the title ‘surgeon’ undergo broad consultation and be progressed as a priority by the Ministerial Council.
The committee is also concerned about the existing barriers to re-enter the workforce following a period out of practice, for example, to raise a family. The committee notes that this is of particular concern in female-dominated professions such as nursing and midwifery. In the committee’s view, the approach taken by AHPRA and the national boards to create a pandemic response sub-register provides a potential model for re-registration more broadly.

Recommendation 2

The committee recommends that AHPRA and the national boards introduce a more flexible re-registration model across professions that would enable health practitioners to more easily re-enter the workforce after a period of absence.
Evidence presented to the committee on a number of unregulated professions, such as social workers, aged care workers and personal care workers, requires further consideration. The committee acknowledges that any regulatory requirements requires careful consideration of the workforce issues specific to those professions, including the potential impact on the workforce, and the level of training and supports required.

Recommendation 3

The committee considers there is a substantial case for regulation of currently unregulated professions including social workers, aged care workers and personal care workers and recommends the Ministerial Council consider whether these professions should be included in the National Regulation and Accreditation Scheme.

  • 1
    There are other categories of registration including: limited registration, non-practising registration, and student registration. See Australian Health Practitioner Regulation Agency (AHPRA), Fact Sheet: Registration Types, 20 April 2010, p. 1.
  • 2
    AHPRA, Annual report 2019-20, p. 2.
  • 3
    AHPRA, Registration Standards, (accessed 2 November 2021).
  • 4
    AHPRA, Applying for Registration, (accessed 20 October 2021).
  • 5
    AHPRA, Consultation process of National Boards, July 2020.
  • 6
    AHPRA, Glossary,, (accessed 22 October 2021).
  • 7
    AHPRA, answers to written questions on notice (received 20 September 2021), p. 8.
  • 8
    See, for example, Australian Psychological Society (APS), Submission 5, p. 4; Australian Acupuncture and Chinese Medicine Association (AACMA), Submission 3, p. 1; Australian College of Nursing (ACN), Submission 12, p. 2; Australian Nursing and Midwifery Federation (ANMF), Submission 25, p. 5; Royal Australasian College of Surgeons (RACS), Submission 30, p. 2; Australian Medical Association (AMA), Submission 7, p. 14; Dr John Quinn, Executive Director Surgical Affairs, RACS, Committee Hansard, 8 July 2021, p. 4.
  • 9
    APS, Submission 5, p. 4.
  • 10
    Section 25 of the National Law provides for the processes involved in making changes to registration standards. See AHPRA, Procedures for the development of registration standards, codes and guidelines, June 2020; AHPRA, answers to written questions on notice (received 20 September 2021), p. 8.
  • 11
    See, for example, AMA, Submission 7, p. 3; Name withheld, Submission 45, p. 2; Health Professionals Australia Reform Association, (HPARA) Submission 70, p. 3; Medical Consumers Association (MCA), Submission 115: Attachment A, p. 7; Australian Association of Psychologists incorporated (AAPi), Submission 73, p. 4; Optometry Australia (OA), Submission 20, p. 1.
  • 12
    Name withheld, Submission 45, p. 2.
  • 13
    See, for example, HPARA, Submission 70, p. 3; AMA, Submission 7, p. 3; MCA, Submission 115, Attachment A, p. 7; Name withheld, Submission 45, p. 2. The CPD requirements of each national board are listed in the Registration Standards for each profession and published on each board’s website. These detail the number of credits, points or hours practitioners must complete each year. See AHPRA, Continuing Professional Development,, (accessed 8 November 2021).
  • 14
    AHPRA website, Continuing Professional Development,, (accessed 8 November 2021).
  • 15
    MCA, Submission 115: Attachment A, p. 7.
  • 16
    See, for example, PGA, Submission 21, p. 5; Ms Claire Bekema, Acting National Manager, Policy and Regulation, PGA, Committee Hansard, 8 July 2021, p. 23; Ms Annie Butler, Federal Secretary, ANMF, Committee Hansard, 8 July 2021, p. 19; Name withheld, Submission 50, p. 3; Occupational Therapy Australia (OTA), Submission 27, p. 3; Confidential Submission 120, [p. 1].
  • 17
    PGA, Submission 21, p. 5; Ms Bekema, PGA, Committee Hansard, 8 July 2021, p. 23.
  • 18
    Ms Butler, ANMF, Committee Hansard, 8 July 2021, p. 19.
  • 19
    AHPRA, answers to written questions on notice (received 20 September 2021), p. 9.
  • 20
    AHPRA, answers to written questions on notice (received 20 September 2021), p. 9.
  • 21
    See, for example, OTA, Submission 27, p. 2; Queensland Nurses and Midwives’ Union (QNMU), Submission 8, pp. 2–3; ANMF, Submission 25, p. 8; Associate Professor Carol McKinstry, President, OTA, Committee Hansard, 8 July 2021, p. 41.
  • 22
    ANMF, Submission 25, p. 8.
  • 23
    Associate Professor McKinstry, OTA, Committee Hansard, 8 July 2021, p. 41.
  • 24
    AHPRA, Submission 78, pp. 9–10.
  • 25
    See, for example, APS, Submission 5, p. 6; QNMU, Submission 8, p. 4; Australian College of Nurse Practitioners (ACNP), Submission 13, p. 2; ANMF, Submission 25, p. 12; Universities Australia, Submission 26, p. 2.
  • 26
    APS, Submission 5, p. 6.
  • 27
    QNMU, Submission 8, p. 4; ACNP, Submission 13, p. 2; AHPRA, Submission 78, Attachment 2, p. 4.
  • 28
    AHPRA Community Reference Group, Submission 78: Attachment 2, p. 4.
  • 29
    ANCP, Submission 13, p. 2.
  • 30
    ANMF, Submission 25, p. 11
  • 31
    ANMF, Submission 25, p. 12; Universities Australia, Submission 26, p. 2.
  • 32
    AHPPRA, Submission 78, p. 10.
  • 33
    AHPRA, Submission 78, p. 18.
  • 34
    AHPRA and the national boards, Submission 78, p. 18–19.
  • 35
    AHPRA and the national boards, Submission 78, p. 19.
  • 36
    See also discussion from paragraph 3.131 in Chapter 3 on the challenges of supervised practice when, as a result of notification process, it is imposed as a condition of practice.
  • 37
    See, for example, AACMA, Submission 3, p. 4; ANMF, Submission 25, p. 9; OTA, Submission 27, p. 3; QNMU, Submission 8, p. 8; Australian and New Zealand College of Anaesthetists (ANZCA), Submission 34, p. 1; APS, Submission 5, p. 5; OA, Submission 20, p. 2; PGA, Submission 21, pp. 5–6; Ms Butler, ANMF, Committee Hansard, 8 July 2021, p. 20; Ms Rachel Phillips, Chair, Psychology Board of Australia, Committee Hansard, 22 September 2021, p. 49.
  • 38
    See, for example, AACMA, Submission 3, p. 4; ANMF, Submission 25, p. 9.
  • 39
    AACMA, Submission 3, p. 4.
  • 40
    Occupational Therapy Australia, Submission 27, p. 3.
  • 41
    ANMF, Submission 25, p. 9.
  • 42
    ANMF, Submission 25, p. 9.
  • 43
    ANZCA, Submission 34, p. 1
  • 44
    OTA, Submission 27, p. 3.
  • 45
    QNMU, Submission 8, p. 8.
  • 46
    See, for example, OA, Submission 20, p. 2; ANZCA, Submission 34, p. 1; APS, Submission 5, p. 5.
  • 47
    OA, Submission 20, p. 2.
  • 48
    APS, Submission 5, p. 5.
  • 49
    AHPRA and the national boards, Submission 78, p. 6. AHPRA’s submission notes that the Pharmacy and Psychology Boards did not participate as they have long-standing supervised practice frameworks developed to address profession-specific needs, including the role supervisors play in facilitating safe practice of psychology and the legal obligations of pharmacists set out in state and territory medicines and poisons legislation and pharmacy premises legislation.
  • 50
    AHPRA and the national boards, Submission 78, p. 6.
  • 51
    AHPRA and the national boards, Submission 78, p. 9.
  • 52
    AHPRA and the national boards, Submission 78, p. 9.
  • 53
    House of Representatives Standing Committee on Health and Ageing, Lost in the Labyrinth: Report on the inquiry into registration processes and support for overseas trained doctors, March 2012, pp. ix and xii.
  • 54
    See, for example, OTA, Submission 27, p. 2; PGA, Submission 21, p. 6; Royal Australian and New Zealand College of Psychiatrists (RANZP), Submission 28, p. 3; MCA, Submission 115, p. 7; Ms Butler, ANMF, Committee Hansard, 8 July 2021, p. 20.
  • 55
    OTA, Submission 27, p. 3.
  • 56
    PGA, Submission 21, p. 6.
  • 57
    RANZP, Submission 28, p. 3.
  • 58
    RANZP, Submission 28, p. 3.
  • 59
    See, for example, OTA, Submission 27, p. 3; APS, Submission 5, pp. 5–6; Associate Professor Vinay Lakra, President, RANZCP, Committee Hansard, 8 July 2021, p. 10; Confidential Submission 110, [p. 1].
  • 60
    OTA, Submission 27, p. 3.
  • 61
    Associate Professor Lakra, RANZCP, Committee Hansard, 8 July 2021, p. 10.
  • 62
    APS, Submission 5, pp. 5–6.
  • 63
    OTA, Submission 27, p. 4.
  • 64
    OTA, Submission 27, pp. 3–5.
  • 65
    The six recognised countries are: Australia, Canada, New Zealand, Republic of Ireland, South Africa, United Kingdom and the United States of America. See: AHPRA, Registration Standard: English Language Skills, 1 July 2015, p. 5.
  • 66
    See, for example, QNMU, Submission 8, p. 3; Ms Butler, ANMF, Committee Hansard, 8 July 2020, p. 20.
  • 67
    QNMU, Submission 8, p. 5.
  • 68
    See, for example, Amnesty International, Submission 15, pp. 4–6; RISE, Submission 22, pp. 1-2.
  • 69
    Amnesty International, Submission 15, p. 4.
  • 70
    RISE, Submission 22, pp. 1-2.
  • 71
    Answers to written questions on notice, received from Australian Health Practitioner Regulation Agency (AHPRA), 20 September 2021, p. 9.
  • 72
    See, for example, Mr Patrick Tansley, President, Australasian College of Cosmetic Surgery (ACCS), Proof Committee Hansard, 22 September 2021, pp. 2–7; Dr Robert Sheen, President, Australasian Society of Aesthetic Plastic Surgeons (ASAPS), Proof Committee Hansard, 22 September 2021, pp. 1–7; ACCS, Submission 126; ASAPS, Submission 71.
  • 73
    AHPRA, Fact Sheet: Registration Types, April 2010, p. 1; Specialist registrations are different to protected titles. Protected titles are the specific titles of health practitioners registered under the National Law, such as ‘registered nurse’ and ‘enrolled nurse’. In effect, ‘specialist’ is a higher level of a specific protected title, such as a ‘paediatric dentist’ who is a specialised ‘dentist’.
  • 74
    AHPRA, Fact Sheet: Registration Types, April 2010, p. 1.
  • 75
    Confidential, Submission 140; Confidential, Submission 141; Mr Justine Nixon, Submission 132; Ms Lauren Hewish, Submission 133.
  • 76
    ASAPS, Submission 71, p. 2.
  • 77
    Operation Redress, Submission 76, pp. 4–6; Mr Justin Nixon, Submission 132, [p. 2–4]; Ms Lauren Hewish, Submission 133, pp. 1–8; Confidential, Submission 140; Confidential, Submission 141.
  • 78
    Mr Fletcher, CEO, AHPRA, Committee Hansard, 22 September 2021, p. 41.
  • 79
    AHPRA, answers to questions on notice, 22 September 2021 (received 11 October 2021), pp. 5–6.
  • 80
    In Camera Committee Hansard.
  • 81
    ASAPS, Submission 71, p. 1.
  • 82
    ASAPS, Submission 71, p. 3.
  • 83
    ASAPS, Submission 71, Supplementary Submission, p. 3.
  • 84
    Mr Tansley, ACCSM, Committee Hansard, 22 September 2021, p. 2.
  • 85
    Mr Tansley, ACCSM, Committee Hansard, 22 September 2021, p. 2.
  • 86
    ACCSM, Submission 126, p. 4.
  • 87
    Dr Daniel Fleming, Past President, ACCSM, Committee Hansard, 22 September 2021, p. 5.
  • 88
    Health Chief Executives Forum, Submission 4, p. 8.
  • 89
    The former COAG Health Council is now known as the Health Council.
  • 90
    COAG Health Council, Communiqué, 31 October – 1 November 2019, p. 1.
  • 91
    AHPRA and the Medical Board announces review of cosmetic surgery checks and balances, (accessed 13 January 2022).
  • 92
    RACS, Submission 30, p. 3; Dr Quinn, RACS, Committee Hansard, 8 July 2021, p. 4.
  • 93
    RACS, Submission 30, p. 3; Dr Quinn, RACS, Committee Hansard, 8 July 2021, p. 4.
  • 94
    AHPRA, Fact Sheet: Endorsement of Registration, 20 April 2021 p. 1; AHPRA, Psychology Board of Australia: Endorsement, 2 December 2019, (accessed 22 October 2021).
  • 95
    AHPRA, Psychology Board: Endorsement, 2 December 2019, (accessed 22 October 2021).
  • 96
    APS, Submission 5, p. 4.
  • 97
    See for example QNMU, Submission 8, p. 7; ACN, Submission 12, pp. 1 and 5; ANMF, Submission 25, p. 20; Australian Association of Social Workers (AASW), Submission 6.
  • 98
    COAG Health Council, Communiqué, 11 September 2018, p. 1.
  • 99
    See, for example, AASW, Submission 6, pp. 3-5; ACN, Submission 12; ANMF, Submission 25, p. 20.
  • 100
    AASW, Submission 6, pp. 3-5.
  • 101
    ACN, Submission 12, p. 1.
  • 102
    ACN, Submission 12, p. 5.
  • 103
    ANMF, Submission 25, p. 20.
  • 104
    AHPRA, answers to written questions on notice (received 20 September 2021), p. 9.

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