This chapter provides an overview of the National Registration and
Accreditation Scheme (NRAS) and the operation of the Australian Health
Practitioner Regulation Agency (AHPRA).
The National Registration and Accreditation Scheme (NRAS)
In 2006, the Productivity Commission reported on its examination of
issues impacting on the health workforce and solutions to ensure the continued
delivery of quality healthcare over the next decade. The Commission recommended
the establishment of a single national registration and accreditation scheme to
enable the Australian health workforce to deal with shortages and associated
pressures; to increase its flexibility, responsiveness, sustainability and
mobility; and to reduce red tape.
The Council of Australian Governments (COAG) considered the Productivity
Commission's recommendation and on 14 July 2006, COAG agreed to establish the NRAS,
with the nine health professions (later increased to 10) registered in all
jurisdictions at that time. COAG envisaged the scheme being implemented in July
The intention was to ensure that all health professionals were 'registered
against the same, high-quality national professional standards' and would allow
'doctors, nurses and other health professionals to practise across State and
Territory borders without having to re-register'.
The Australian Health Workforce Ministerial Council (AHWMC) submitted
that the objectives of the NRAS are to:
provide for the protection of the public by ensuring that only
practitioners who are suitably trained and qualified to practise in a competent
and ethical manner are registered;
facilitate workforce mobility across Australia;
facilitate the provision of high quality education and training
of health practitioners;
facilitate the rigorous and responsive assessment of overseas
trained health practitioners;
facilitate access to services provided by health practitioners in
accordance with the public interest; and
enable the continuous development of a flexible, responsive and
sustainable health workforce and enable innovation in the education of, and
service delivery by, health practitioners.
AHWMC went on to state that:
The greater consistency in registration and accreditation
across states and territories under NRAS provides assurance to members of the
public that all health practitioners are subject to the same high quality
professional standards regardless of where the health service is accessed. If a
health practitioner is deregistered or has conditions placed on the
registration, this now automatically applies across all states and territories,
as a result of the new national scheme.
The implementation of the NRAS was delayed until March 2008 when COAG signed
the Intergovernmental Agreement for a National Registration and Accreditation
Scheme for the Health Professions. The agreement aimed to 'help health
professionals move around the country more easily, reduce red tape, provide
greater safeguards for the public and promote a more flexible, responsive and
sustainable health workforce'. The agreement included a national register to
ensure health professionals banned from practising in one place would be unable
to practise anywhere else in Australia.
The Intergovernmental Agreement was to be implemented on 1 July 2010 and
would consist of 'a Ministerial Council, an independent Australian Health
Workforce Council, a national agency with an agency management committee,
national profession-specific boards, committees of the boards, a national
office to support the operations of the scheme, and at least one local presence
in each state and territory'.
The national agency as described in the agreement would have the
maintain up-to-date and publicly accessible national lists of
accredited courses and registered practitioners with entries relating to
individuals to include any conditions or restrictions on professional practice;
administer the resources of the scheme and ensure the scheme is
as efficient as possible;
act in accordance with any policy directions from the Ministerial
report annually to the Ministerial Council;
following agreement with the boards, set fees, and where there is
no agreement, this will be referred to the Ministerial Council;
at its discretion, contract or delegate functions, excluding
registration and accreditation functions, with any delegations reported to the
in consultation with the boards, develop and administer
procedures and business rules for the efficient and quality operation of the registration
and accreditation functions and the operation of the boards and their
committees, consistent with ministerial policy direction and the objects of the
in accordance with the objects of the legislation and any policy
directions of health ministers, set frameworks and requirements for the
development of registration, accreditation and practice standards by the
national boards to ensure that good regulatory practice is followed;
advise the Ministerial Council on issues relevant to the scheme;
establish a national office.
The national agency would maintain the national registers of health
practitioners and lists of accredited courses; provide secretariat support for
the agency management committee and boards, and any other committees constituted
under the scheme; and establish at least one presence in each state and territory.
As the Commonwealth does not have the power to regulate health
professionals, the legislative framework for implementation of the NRAS was
enacted by the state and territory legislatures. The initial legislation was
passed by the Queensland Parliament in November 2008. This legislation set up
interim administrative arrangements for the Scheme.
Consultation with stakeholders took place through the National Registration
and Accreditation Implementation Project (NRAIP). Following this consultation, in
May 2009 the AHWMC announced changes to the Scheme as originally proposed.
These changes included ensuring that accreditation functions are independent of
government; establishing both general and specialist registers for professions,
as well as separate registers for nurses and midwives; and requirements for
continuing professional development in relation to annual renewal of
The Health Practitioner Regulation National Law Act 2009 (Qld)
(National Law) received Royal Assent on 3 November 2009. It details the substantive
provisions for registration and accreditation and replaced the initial
legislation passed in 2008. Other states and territories passed similar
legislation to the National Law and jurisdiction-specific consequential and
The NRAS legislation replaced 65 Acts across the jurisdictions and the bodies
established replaced 80 state and territory boards. Several jurisdictions made
amendments to the National Law, including New South Wales which opted for
retaining its own complaints system.
The Commonwealth also passed consequential and transitional amendments
to Commonwealth legislation required to recognise and support the NRAS.
The NRAS commenced on 1 July 2010 for all States and Territories except
Western Australia which joined the NRAS on 18 October 2010.
Structure of the NRAS
AHPRA provided the following diagram to show how the scheme operates:
Australian Health Practitioner
Regulation Agency, Submission 26, p. 5.
Ministerial Council: AHWMC comprises the health ministers of each
state and territory and the Commonwealth. The functions of the Ministerial
Council are set out in the National Law and include:
appointing the National Board members and the Agency Management
giving direction to AHPRA and the Board about the policy they
must apply in exercising their functions; and
approving registration standards, lists of specialities and
specialist titles and endorsements in relation to scheduled medicines and areas
Health Workforce Advisory Council: provides independent advice to
the Ministerial Council about matters related to the national scheme;
National Boards: established under the National Law for each of
the regulated health professions with members appointed by the Ministerial
Council. Functions are set out in the National Law and include:
responsibility for registering health practitioners who meet the
requirements of the approved registration standards (English language skills,
professional indemnity insurance, recency of practice, continuing professional
development and criminal history);
investigate and manage concerns (notifications) about performance
or conduct of practitioners;
develop standards, codes and guidelines; and
set national fees;
The functions of
the National Boards can be delegated and many are delegated to AHPRA and Board
Agency Management Committee: effectively the board of AHPRA with
functions including policy development and ensuring that AHPRA performs its
functions in a proper, effective and efficient manner.
The AHWMC described its role as:
The AHWMC has an ongoing and defined role but had not
intended or expected continued administrative involvement except at the 'lightest
touch' level. Under the National Law, Ministers are responsible for approving
registration and accreditation standards put forward by the National Boards,
approval of specialist registration and approval of areas of practice for the
purposes of endorsement. Ministers can only give directions to National Boards
or the national agency under limited circumstances specified in the
Inquiries into the NRAS
The Senate Community Affairs Legislation Committee conducted two
inquiries into the NRAS. The first, National registration and accreditation
scheme for doctors and other health workers, made three recommendations:
providing a safeguard against the potential misuse of power by
the Ministerial Council in relation to accreditation standards (Recommendation
introducing a requirement into the NRAS that the reasons for the
Ministerial Council issuing a direction in relation to an accreditation
standard be made public (Recommendation 2); and
that the AHWMC ensure that the NRAS contains sufficient
flexibility for the composition of National Boards to properly reflect the characteristics
and needs of individual professions (Recommendation 3).
In May 2010, the Community Affairs Legislation Committee tabled its
report on the Health Practitioner Regulation (Consequential Amendments) Bill
2010. In addition to recommending that the bill be passed, the committee also
recommended that AHPRA place information on protected titles and roles,
including for nurses and specialists, on its website to ensure clarity around
definitions for the community.
Australian Health Practitioner Regulation Agency (AHPRA)
AHPRA was established on 1 July 2010 as part of the National
Registration and Accreditation Scheme to regulate 10 health professions. The
ten health professions regulated by AHPRA are:
dental practitioners (including dentists, dental specialists,
dental hygienists, dental prosthetists and dental therapists);
nurses and midwives;
The AHPRA annual report for 2009–10 indicated that from July 2012, a
further four health professions are planned to join the scheme:
Aboriginal and Torres Strait Islander health practitioners;
Chinese medicine practitioners;
medical radiation practitioners; and
AHPRA supports the nation boards to perform their functions. AHPRA staff
exercise functions delegated by each of the National Boards in relation to
registration of health practitioners and investigation of notifications. The
following provides an overview of the establishment of AHPRA.
Timetable for the appointment of staff:
Agency Management Committee
Dec 2009 – Jan 2010
AHPRA CEO and national
management team in place and receive handover from project team
AHPRA State and Territory
managers on board and recruiting senior staff
Most eligible staff accept
offer to transfer to AHPRA
Over 400 staff transfer to AHPRA
offices open in all states and territories
Source: Australian Health
Practitioner Regulation Agency Annual Report 2009–10, p. 9.
AHPRA has a staff of around 510 full-time and part-time staff. More than
80 per cent of staff from the previous boards joined AHPRA. Most state and
territory managers were recruited from previous chief executive officers of
state and territory boards.
AHPRA has offices in all states and territories and a national office
co-located with the state office in Melbourne.
The Ministerial Council established the financial principles for the
transfer of assets and liabilities for state and territory boards. All funds
deriving from the state and territory boards of each profession were to be
pooled at a national level and held for the benefit of the national board of
The Australian Health Ministers Advisory Council (AHMAC) agreed that
boards were required to transfer funds to cover:
prepaid fees held at 20 June 2010;
funds to cover transferring liabilities; and
reserve funds equivalent to one year's operating, or if not
available, all reserve funds.
In addition, $19.8 million (and subsequently additional funds) were
provided by the Commonwealth and state and territory governments for project
costs before implementation commenced.
AHPRA is now funded solely by the registration and renewal fees paid by
health practitioners. AHPRA noted that in some cases transition and
implementation costs have been higher than expected. Further, renewal dates for
health practitioners differ across the states and territories. It was noted
that it will take up to 17 months before the new national fees can be applied
uniformly to all registrants.
AHPRA also commented that if more resources are required, additional
revenue can only be raised by increasing registration fees, in agreement with
the National Boards. It was stated that 'it is not expected that fees should
increase by more than the inflation rate on an annual basis'. The Ministerial
Council will be advised if the fee rise is to be greater than the inflation
Information and communication
The 2009–10 AHPRA Annual Report provides an overview of the information
and communication technology (ICT) system implemented. Following review of the
existing ICT capability of boards, it became clear that greenfields ICT would
be required by AHPRA with only limited re-use likely of existing systems and
Data migration of more than one million names and addresses from
42 databases located within state and territory registration boards. A key
element of the data migration was a mailing to registrants which commenced in
April 2010 to:
confirm registrant details;
confirm principle place of practice;
advise registrants of their new registration types; and
advise registrants of the conditions that would appear on the
Registration by AHPRA
There are over 528,000 health practitioners on the national registers
across 10 professions with just over half of those being nurses and
midwives (288,861) and 87,984 medical practitioners.
Application for registration
The National Law sets a maximum 90 day timeframe to assess an initial
application for registration. If a National Board does not decide an
application for registration within 90 days of its receipt, or a longer period
agreed between the Boards and the applicant, the failure by the Board to make a
decision is taken to be a decision to refuse to register the applicant.
AHPRA provided the following flowchart of the registration process:
Source: Australian Health Practitioner Regulation Agency, Submission
26, p. 26.
AHPRA noted that the registration process now includes additional
requirements that 'stem from the core principle of public safety'. These new
requirements are as follows:
English language skills registration standard;
criminal history registration standard;
recency of practice registration standard;
continuing professional development registration standard;
automatic expiry of registration; and
new common renewal date.
AHPRA has instituted special procedures for the graduate registration
process which allows graduates to pre-apply for registration.
Renewal of registration
All health practitioners must renew their registration annually. If
practitioners do not renew their registration by the end of the late period
(one month after their registration expiry date), their registration will lapse
and they will need to make a new application for registration.
AHPRA stated that the National Law does not set a time period for a
decision on an application for renewal, as section 108 enables a practitioner
to remain registered after he or she has made an application for renewal until
the Board decides to renew or refuse to renew the registration. AHPRA stated
that in most cases, where practitioners renew online and make no adverse
declarations, their registration is updated within hours.
AHPRA provided the following flow chart of the renewals process:
Source: Australian Health Practitioner Regulation Agency, Submission
26, p. 43.
APHRA's response to service
In response to service delivery problems, AHPRA indicated that it had
instituted measures to improve service delivery. These include:
contacting AHPRA: boosted resources for customer services teams,
management of calls directly by experienced staff and established new backup
and peak demand capacity;
lapsing of registrants: established a fast track application
process for registrants who miss the renewal deadline, to streamline their
re-registration, with no late or application fees in the first year. The fast track
is open for one month after the end of the late period; and
improved online services: implemented enhancement of the online
applications and tracking process.
In addition, AHWMC announced that the Commonwealth will consider ex gratia
or act of grace payment for a period of time so that patients are not
disadvantaged by lapsed registration of their health care practitioner who is
See chapter 4 for further details.
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