Health Professions Accreditation Collaborative Forum...

Health Professions Accreditation Councils’ Forum

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Date: 10 October 2014 To: Australian Health Ministers’ Advisory Council Email: [email protected] A submission in response to the Consultation Paper, August 2014, for the Review of the National Registration and Accreditation Scheme for health professions, prepared by Independent Reviewer Mr Kim Snowball commissioned by the Australian Health Ministers’ Advisory Council to undertake the review. The Health Professions Accreditation Councils’ Forum is pleased to have the opportunity to make a submission in response to the Consultation Paper for the Review of the National Registration and Accreditation Scheme for the health professions. About the Health Professions Accreditation Councils’ Forum

The Health Professions Accreditation Councils’ Forum (‘the Forum’) is a coalition of the accreditation Councils of the regulated professions. Each of the Councils is appointed under the Health Practitioner Regulation National Law Act 2009 (the National Law) as the accreditation authority for the relevant profession-specific National Board and is part of the National Registration and Accreditation Scheme (NRAS). The Forum comprises: Australian Dental Council Australian Medical Council Australian Nursing and Midwifery Accreditation Council Australian Pharmacy Council Australian Physiotherapy Council Australian Psychology Accreditation Council Australasian Osteopathic Accreditation Council Australian and New Zealand Podiatry Accreditation Council Council on Chiropractic Education Australasia Optometry Council of Australia and New Zealand Occupational Therapy Council (Australia and New Zealand) Ltd

The Forum has been meeting regularly since 2007 to consider matters of common interest, principally matters concerning the accreditation of education and training programs in the health professions. The Forum responds collectively to consultation processes and papers on matters common to the relevant professions. In general, a submission made by the Forum constitutes the shared response of the Forum members and is confined to general issues that are common to all the health professions. Each member Council may make a separate submission, and the views expressed do not override any views expressed by a member Council in its own separate submission. Member Accreditation Councils have agreed to the content of this submission and the principles outlined, however it is not possible to represent the views of each Council on each and every matter raised in the questions posed, and a Council may address specific matters in its own submission in more depth.

mailto:[email protected]

http://www.dentalcouncil.net.au/

http://www.amc.org.au/

http://www.anmc.org.au/

http://www.pharmacycouncil.org.au/

http://www.physiocouncil.com.au/

http://www.psychologycouncil.org.au/

http://www.anzoc.org.au/

http://www.anzpac.org.au/

http://www.ccea.com.au/

http://www.ocanz.org/


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Statutory Roles of the Members of the Forum

The members of the Forum are external accreditation entities and are independent companies limited by guarantee, registered under the Corporations Act 2001. Member organisations vary considerably in their membership, objectives, roles and functions. Their statutory roles under the Health Practitioner Regulation National Law 2009 (the National Law) arise directly from the decision of the relevant National Board to appoint them to undertake the accreditation function for the NRAS under S.43 of the National Law. A National Board can decide whether to appoint an external entity (and which body) or whether to establish an accreditation committee to undertake the accreditation function. In 2009 most Accreditation Authorities (or their predecessors) were assigned to undertake the accreditation function under the National Law by the Australian Health Workforce Ministerial Council (AHWMC) for a period of 3 years from 1 July 2010. In 2012, the National Boards and the Australian Health Practitioner Regulation Agency (AHPRA) undertook a review of each of these Accreditation Authorities and its performance against the domains of the Quality Framework for the Accreditation Function (Quality Framework) to inform the decisions on how to continue to implement the accreditation function under the National Law. This process has been described in the report of the review of accreditation arrangements which was submitted to Ministerial Council, through the Australian Health Ministers’ Advisory Council and its Health Workforce Principal Committee1. In summary, the review of the accreditation arrangements required substantial submissions by each of the ten Accreditation Authorities, consultation with stakeholders and involved a full assessment of how each Authority was conducting its accreditation functions, including reviewing the organisational governance and management, policies, and financial viability as well as accreditation standards and processes. Consultation elicited views and recommendations from stakeholders on the organisation that should undertake the accreditation functions for the profession. This process, in effect, constituted an evaluation of each of the entities undertaking accreditation and provided an opportunity to transfer the function to another organisation or a committee. Following this review process, all members of the Forum (i.e. each of the ten Accreditation Authorities) were re-assigned responsibility for the accreditation function for their respective profession.

Introduction The introduction of the National Registration and Accreditation Scheme (the Scheme) represents a significant achievement. Members of the Forum consider it to be effective and largely appropriate - for achieving the objectives of the Scheme. They recognise that it is still early in the implementation of the Scheme and improvements can be made to the Scheme’s efficiency and effectiveness.

The accreditation functions are critically important for achieving the objectives of the Scheme. By providing quality assurance of the standards of education and training, they provide the mechanism for practitioners to meet requirements for eligibility of registration in the Scheme.

1 Appendix 1: Accreditation within the National Registration and Accreditation Scheme (NRAS) – a paper

developed by the Accreditation Liaison Group, 2014 – Attachment B “Report to Ministerial Council on review of accreditation arrangements”


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The 11 external accreditation entities and the three accreditation committees exercise the accreditation functions independently, within the parameters of the National Law and the Quality Framework, the principal benchmarks for assessment of the work of those Accreditation Authorities. The accreditation functions cover:

Education and training. Under the Scheme, accreditation is an important quality assurance and quality improvement mechanism for health practitioner education and training. Through developing accreditation standards and assessing programs against those standards, these Authorities provide the key quality assurance mechanism to ensure that graduates completing accredited and approved programs of study have the knowledge, skills and professional attributes to practise the relevant profession in Australia. By national and international benchmarking Accreditation Authorities ensure best practice in accreditation standards. At any one time, these Authorities oversee more than 120,000 health professional students as they progress through more than 400 accredited programs of study that lead to general registration.2

Overseas trained practitioners. Accreditation Authorities also develop and undertake processes to assess overseas qualified practitioners who are seeking registration and work in Australia, and therefore are responsible for the responsiveness and rigour- of those assessments, and for establishing that individuals have the knowledge, skills and competence to practise in the Australian health care setting.

Other functions. Accreditation of programs for specialist registration, examination of

locally trained practitioners, and quality assurance of programs for continuing professional development are some of the other functions also undertaken by these Authorities under the Scheme.

In addition to the direct benefits attained through the accreditation functions exercised in Australia, there are indirect benefits from activities of the Accreditation Authorities conducted outside Australia. Under the Trans-Tasman Mutual Recognition (TTMR) arrangement any person registered in Australia to practise an occupation is entitled to practise an equivalent occupation in New Zealand, and vice versa, without the need for further testing or examination3. However, many of the Accreditation Authorities under the Scheme exercise similar functions on behalf of New Zealand regulatory authorities. This consistency in accreditation functions between the two countries assures consistency in the competency of health practitioners when the TTMR arrangement is applied. While the costs of accreditation outside Australia are not borne by the entities or individuals within Australia, the value in protecting the Australian public with this common assignment of function cannot be disregarded.

Response to the Consultation Paper

Members of the Forum acknowledge the significant work to prepare the Consultation Paper released on 29 August 2014, and consider it to provide a valuable framework by which the Scheme can be examined and opinions on its future canvassed.

Members of the Forum note the areas where a need for change has been identified, and the options presented for consideration.

The Forum agrees that accountability of such a large National Scheme is important. The Scheme is complex. The consultations as part of this review demonstrate that there is still variable understanding of the Scheme, and of the role of AHPRA, the National Boards and the

2 These figures sourced from the AHPRA Annual Report 2012 – 2013, p 130

3 Note Medicine is exempt from the TTMRA, but there is still a joint process for accreditation of programs. ,


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Accreditation Authorities, which affects the capacity of organisations and individuals to contribute appropriately. Improved accountability, coupled with enhanced communication is strongly supported.

The Forum agrees that the efficiency and effectiveness of the Scheme’s operations must be kept under review, with the expectation that the operational and cost efficiency of the Scheme will continue to improve. Members of the Forum look forward to further discussion concerning the potential benefits and risks of consolidating functions between professions.

Forum Members note the Consultation Paper identifies several areas as requiring closer scrutiny, including areas relating to the governance and operation of the accreditation functions covered by the Scheme. This response focusses on these issues, and Forum members indicate their commitment to contributing to the development of solutions in areas where processes and practices can be improved.

As the Consultation Paper explains, Accreditation Authorities and National Boards have complementary functions under the National Law. These roles and functions can work effectively, and do in professions where good processes have been established. For some professions, national accreditation processes are quite new, and the understanding of these roles, and relationships between the National Board and the Accreditation Authority have had to develop. The work by the Accreditation Authorities, the National Boards and AHPRA to develop good practice guidelines when issues arise is contributing to better delineation of roles, with clear expectations about good practice.

As the review moves to consider the area of accreditation, members of the Forum agreed that aspects of the current Scheme that should be maintained in any future model include:

Appropriate independence and accountability of co-regulatory functions

Strong relationships with professions and education providers

Flexibility to achieve workforce objectives of the Scheme

Strong international relationships for quality, innovation and efficiency

Technical expertise for quality accreditation functions.

Without these, the objectives of the Scheme, particularly in relation to protecting public safety, facilitating high-quality education and training and facilitating the assessment of overseas-trained health practitioners, will be compromised. As the Scheme continues to mature, the capacity of Accreditation Authorities to contribute to areas such as cross-profession collaboration, facilitating innovation in education and training and achieving efficiencies, without compromising quality, will be more apparent.

Given the co-dependence of all aspects of the Scheme, appropriate resourcing of the accreditation functions is essential to achieve the objectives of the Scheme. Further, the current requirement for accreditation councils to re-negotiate funding every year, despite their assignments running for periods of three years, is seen as inefficient, and also an impediment to longer-term strategic planning and thereby the overall effectiveness of the Scheme. Responses to specific questions in the Consultation Paper will expand on these themes further.


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Responses to questions posed in the Consultation Paper 1. Should the Australian Health Workforce Advisory Council be reconstituted to provide

independent reporting on the operation of the National Scheme? The Health Professions Accreditation Councils’ Forum (the Forum) supports the suggestion that an appropriate body be responsible for independent reporting on the operation of the National Scheme. Although advice is provided to the Australian Health Minister’s Advisory Committee via the Commonwealth’s Department of Health and the Health Workforce Principal Committee, there is also value in the Scheme’s governance structure including a body with members who have particular expertise in health, regulation, education and training to ensure the Scheme reflects contemporary practice. It seems sensible and efficient to re-instate the Australian Health Workforce Advisory Committee (AHWAC) given the diversity in membership of this group and the determinations already included in the National Law. Accreditation Authorities are already subject to performance monitoring. The Quality Framework for the Accreditation Function (Quality Framework) has been established as the principal reference document for National Boards and AHPRA to assess the work of Accreditation Authorities. Accreditation Authorities provide six-monthly reports to their National Boards on developments relevant to the domains of the Quality Framework. They also give statistics on matters such as accreditation decisions made, applications by overseas trained practitioners, and complaints considered. Furthermore, each Accreditation Authority must also undergo periodic assessment and provide data to support the organisation’s continuation as the external accreditation entity. The Forum supports the continuation of these, comprehensive reporting arrangements and would welcome discussion on increasing the transparency of the performance review reports across the Scheme via an agency such as AHWAC. 2. Should the Health Workforce Advisory Council be the vehicle through which any

unresolved cross-professional issues are addressed? The Health Professions Accreditation Councils’ Forum considers it essential that the professional regulation and accreditation system clearly outlines an accountability framework for managing cross-professional issues that cannot be resolved by National Boards. While the regulatory bodies should continue to be responsible for ensuring their practitioners meet acceptable standards for competence and conduct, it seems reasonable for an independent authority with legislative permissions, such as the Australian Health Workforce Advisory Council, to act in mediation-like role to help resolve an issue or to support decision-making. 3. Should a single Health Professions Australia Board be established to manage the

regulatory functions that oversee the nine low regulatory workload professions? Estimated cost saving $11m per annum.

4. Alternatively, should the nine National Boards overseeing the low regulatory workload professions be required to share regulatory functions of notifications and registration through a single service? Estimated cost saving $7.4m pa.

It is the Forum’s view that of the two options put forward in the Consultation Paper for achieving efficiencies in the management of regulatory functions, the continued existence of distinct National


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Boards for each health profession is the best option to achieve the objectives of the National Scheme. The essential work of professional advice that all of the National Boards undertake to ensure that the objective of safe practice is met should not be underestimated. It is, however, difficult to price because it is almost always based on professional advice which is provided at no or marginal cost. This ‘preventive’ work of the National Boards includes approving both the Standards for accreditation and the accredited programs to be recognised for registration purposes, as well as agreeing on the mechanisms to assess overseas trained health practitioners seeking to practice in Australia. National Boards also issue a range of specialist guidelines which can enhance public access to safe care. Such guidelines range from the relatively straightforward, such as appropriate recency of practice rules for practitioners who leave a profession for a period of time, to the more innovative, such as allowing therapeutically trained optometrists to independently diagnose and manage glaucoma in line with current international practice in New Zealand, the United States and in Canada. While reporting the numbers and types of notifications and complaints are important indicators of risks in the National Scheme, and analysis of this data can help improve public safety, they are lagging indicators. Identifying and responding to leading indicators of risk as they emerge in professional practice are most likely to occur as a result of the professional expertise of National Board members. The Consultation Paper notes that the current notifications per ‘000 practitioners are already higher in several of the ‘lower regulatory workload’ professions [podiatry, chiropractic, and optometry], than in one of the ‘higher regulatory workload professions’ [nursing]. National Boards need to be able to respond with agility to, and on occasions play a leading role in promoting, changes in professional practice if the objectives of the National Scheme for workforce mobility and a flexible workforce are to be met. The following examples illustrate how National Boards have recently enabled changes in professional practice:

The Occupational Therapy Accreditation Standards (December 2013) now explicitly provide that up to 20% of clinical placement experience can be gained through well-developed simulation activity. The Occupational Therapy Board of Australia has initiated a national, multi-site research project to evaluate the use of simulation as a partial substitute for traditional clinical placement.

The Pharmacy Board of Australia has approved an expanded scope of practice for pharmacists to enable them to administer vaccinations. The Australian Pharmacy Council has prepared standards for the accreditation of courses which train pharmacists to administer vaccines.

These activities all require a detailed knowledge of the complexity of each profession, and the ability to benchmark the standards for safe practice internationally as well as nationally. They are therefore most effectively carried out by National Boards having considerable profession-specific expertise, not to mention the respect and recognition of each profession in Australia and overseas, and which include multiple-State representation to deal with local and regional variations. Given this view, of the two options outlined in the NRAS Review Consultation Paper, the Forum views the option set out in Question 4 as the best way to ensure that all of the regulated professions in the National Scheme retain an equivalent access to governance and policy setting capacity to encourage regulation which is innovative and focussed on continuous improvement.


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In the event that Ministers decide that a merged Health Professions Australia Board is their preferred option, the Forum’s view is that considerations such as the above, which go beyond numbers of registrants and notifications to the key question of how best to assure safe professional practice of an internationally competitive standard, must be developed and applied in further consultation with the professions before the composition of any merged Board is finalised. The Forum notes that further work on the modelling of changes and the costs is still to be done and it looks forward to contributing to this work.

5. Should the savings achieved through shared regulation under options 1 or 2 be

returned to registrants through lower fees? The desire for the National Scheme to operate efficiently and the cost to individual registrants to be kept as low as possible is appreciated. Nevertheless the Forum notes that the Scheme currently does not possess a universal active mechanism for funding of cross-professional activity, and consideration of such may be of value. 6. Should future proposals for professions to be included in the National Scheme

continue to require achievement of a threshold based on risk to the public and an associated cost benefit analysis?

7. Should the National Law be amended to recognise those professions that provide adequate public protection through other regulatory means?

8. Should a reconstituted Australian Health Workforce Advisory Council be the vehicle to provide expert advice on threshold measures for entry to the National Scheme to the Health Workforce Ministerial Council?

The Forum supports the achievement of a threshold based on risk to the public as the primary criterion for new health professions to be added to the Scheme. The COAG criteria applied at the time the National Scheme was established still appear relevant to assessing that risk, as does further regulatory impact assessment in accordance with the COAG best practice regulation requirements.

It appears unnecessary to amend the National Law to recognise those professions that provide adequate public protection through other regulatory means, given Ministers have available other mechanisms to document this recognition such as through communiques and policy statements on the AHMAC website.

There does, however, seem to be confusion about which professions are covered by the Scheme and the implications of inclusion in the Scheme. For example, the Quality Framework requires Accreditation Authorities operating in the Scheme to develop accreditation standards that:

meet relevant Australian and international benchmarks

are based on the available research and evidence base

are developed with stakeholder involvement and wide ranging consultation

are regularly reviewed

take account of AHPRA’s ‘Procedures for Development of Accreditation Standards and the National Law’.

These expectations are not in place for health professions which are not covered by the Scheme.

A reconstituted AHWAC would appear to be an appropriate body to provide expert advice to the Ministerial Council on revised threshold measures for entry to the Scheme, should the COAG criteria require amendment in the future.


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9. What changes are required to improve the existing complaints and notifications system under the National Scheme?

10. Should the co-regulatory approach in Queensland, where complaints are managed by an independent commissioner, be adopted across all States and Territories?

11. Should there be a single entry point for complaints and notifications in each State and Territory?

12. Should performance measures and prescribed timeframes for dealing with complaints and notifications be adopted nationally?

13. Is there sufficient transparency for the public and for notifiers about the process and outcomes of disciplinary processes? If not, how can this be improved?

14. Should there be more flexible powers for National Boards to adopt alternative dispute resolution, for instance to settle matters by consent between the Board, the practitioner and the notifier?

15. At what point should an adverse finding and the associated intervention recorded against a practitioner be removed?

16. Are the legislative provisions on advertising working effectively or do they require change?

17. How should the National Scheme respond to differences in States and Territories in protected practices?

18. In the context of the expected introduction of a National Code of Conduct for unregistered health practitioners, are other mechanisms or provisions in the National Law required to effectively protect the public from demonstrated harm?

19. Should the mandatory notification provisions be revised to reflect the exemptions included in the Western Australian and Queensland legislation covering health practitioners under active treatment?

The Forum notes the considerable material on AHPRA’s website and those of the various health complaints entities about complaints and notifications processes, and information in AHPRA annual reports about the numbers of notifications managed. Despite this, submissions to previous enquiries into the operations of the National Scheme indicate that the health professions regulatory environment is complex and can be unclear to those raising concerns as well as those against whom complaints are raised. As bodies that contribute to regulation of health professions, Accreditation Authorities are keen to see these complex and important processes managed well. Forum members support a single entry point for complaints and notifications in each State and Territory.

Forum members note that 60 per cent of notifications assessed by the National Boards result in a finding of no further action. 4 This suggests that there are considerable opportunities to improve the management of notifications so that these cases can be addressed quickly and resources directed to managing other aspects of the processes and to other areas of the Scheme. For this reason, Forum members also support more flexible adoption of alternative dispute resolution processes – either by National Boards or by referral to those processes as used by complaints commissioners.

The Forum members note that nine of the professions in the Scheme account for a very small number of notifications5 and support proposals to improve and streamline the management of notifications and complaints for this group. It is important to appreciate that as the result of health workforce reform initiatives, and changes to the role and scope of practice of some professions (for example extending prescribing to non-medical professions), the regulatory work load for some professions may increase in the future.

4 Page 17 Consultation Paper

5 Consultation Paper


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20. To what extent are National Boards and Accrediting Authorities meeting the statutory objectives and guiding principles of the National Law, particularly with respect to facilitating access to services, the development of a flexible, responsive and sustainable health workforce, and innovation in education and service delivery?

The core role of the Accreditation Authorities is to ensure that only health practitioners who are suitably trained and qualified to practise in a competent and ethical manner are registered. The Accreditation Authorities contribute to this in two ways: by setting Standards for education and training that are contemporary, robust, nationally and internationally benchmarked, and are responsive to the needs of the community, and by ensuring that these Standards are applied to Australian programs. When applied, the Standards ensure that educational programs have appropriate didactic and experiential education, have professional input, and employ assessment processes that are valid, reliable and fair. Additionally, ten Accreditation Authorities assess the qualifications of internationally trained health practitioners to ensure that they meet these standards, including verifying the credentials of these practitioners and providing appropriate assessments and examinations. Nine Accreditation Authorities also assess overseas standards setting bodies to identify the programs that meet Australian standards for registration. Accreditation is largely concerned with National Law objectives (c) to facilitate the provision of high quality education and training of health practitioners and (d) the rigorous and responsive assessment of overseas-trained health practitioners. Under the National Law, Accreditation Authorities develop accreditation standards and National Boards approve them. Since the National Scheme inception most Accreditation Authorities have reviewed their Standards. The modern principle for standard-setting is to prepare “evidence based and outcome focused” standards; that is, standards that are not unnecessarily prescriptive and where an education provider provides evidence of achievement of the outcome. These types of standards enable and facilitate diversity of approaches and innovation by education providers. By the Accreditation Authorities being cognisant of the contemporary issues of key stakeholders, educational developments, developments in the practice of the professions and the needs of the public, Government, and employers, they can set standards that drive and enable responsive practice and innovation.

There is still some more work to be done in this area of Standard setting for some professions, as some Accreditation Authorities do not yet have sufficiently outcome-focused standards. However, these professions endorse the need to make such changes and have plans in place including working with the assistance of other Accreditation Authorities in this process. To assist this work, the Forum has undertaken a mapping of Standards across the 11 professions, including examining commonalities, with a particular focus on areas of interest in health workforce reform.

The Forum is also one of the vehicles for discussion and interaction with key stakeholders such as government, other accreditation bodies such as TEQSA and ASQA and other groups interested in development of curriculum frameworks or accreditation standards for specific topics, such as an Indigenous Health Curriculum Framework. The Forum is also a vehicle for Accreditation Authorities to share best-practice policies and procedures, including appeals mechanisms and feedback tools that can be used to encourage continuous quality improvement in accreditation activities.

By encouraging flexible delivery of practice, the Accreditation Authorities support workforce mobility and greater access to service. One example of this is the UNE Bachelor of Pharmacy program which is delivered in a blended learning modality with online learning and face-to-face residential schools, allowing students to learn from remote and regional locations. These students are able to undertake their experiential placements in their local communities, which enables remote communities to retain skilled practitioners and maintain services.


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Innovation in education and service delivery is exemplified by the changes made to accreditation standards to support the use of simulated learning platforms, enabling students to develop core skills before they use them in a clinical setting or professional practice. This is also assisting in the development of a sustainable health workforce, as such innovation prepares graduates for competent safe practice across the breadth of their scope of practice.

The assessment of international health practitioners by Accreditation Authorities contributes to access to services by having assessment standards that ensure practitioners are safe and competent to practice their profession anywhere in Australia. In many professions, internationally trained health practitioners constitute a large proportion of the rural workforce, and Accreditation Authorities recognise that assessment of these practitioners must not be a barrier to the entry of appropriately qualified practitioners into Australia. There are examples of flexibility in this area such as the workplace-based assessments of overseas trained medical practitioners, and competent authority processes. All those Accreditation Authorities that undertake the assessment of international health practitioners strive to keep their assessment processes rigorous, fair and transparent and to set applicant fees appropriate to the cost of the process.

21. Should a reconstituted AHWAC carry responsibility for informing regulators about

health workforce reform priorities and key health service access gaps? For effective engagement and successful progress on key issues there is a need to establish a process of good debate and informed interaction with Accreditation Authorities and other relevant stakeholders. Accreditation Authorities recognise the importance of this engagement, and are willing to have these discussions with the relevant parties. The Forum can see the benefits of such a role within the Scheme, and agree that a reconstituted AHWAC may be an appropriate body. As previously stated, the Forum agrees that accountability within the National Scheme is necessary and that this could reasonably come from AHWAC provided it is appropriately constituted. 22. To what extent are Accrediting Authorities accommodating multidisciplinary education

and training environments with coordinated accreditation processes or considering future health practitioner skills and competencies to address changes in technology, models of care and changing health needs?

Accreditation Authorities are fully aware of the changes in health care models and encourage education providers to be innovative in the delivery of programs that assist multidisciplinary education outcomes, bearing in mind that innovations should not be to the detriment of any profession-specific Standards. However, the fact that each of the health professions regulated under the National Scheme are seen as sufficiently different and autonomous to require regulation for their own scopes of practice must be acknowledged.

Accreditation Authorities are only one part of the mix with respect to driving innovation within a profession; National Boards, professional bodies, educators and practitioners also have roles. Accreditation Authorities consult widely with these stakeholders on their Standards, and are responsive to their feedback, with National Boards having the final approval in what is presented to them following this consultation. The key to full accommodation of multidisciplinary education and training is to focus on outcomes of training, and this is endorsed by the Accreditation Authorities in the development and implementation of Standards. Evidence based and outcome focused Standards assist to encourage innovation in interprofessional education. Those Authorities with outcomes focussed Standards require the


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education provider to ensure that their graduates are equipped for patient-centred care as part of multidisciplinary teams. However, some education provider’s perceptions of what constitutes interprofessional education, and what can be seen as a solution to implementing interprofessional education, does not always align with what the profession expects. Accreditation Authorities are not convinced of the validity of some of the approaches taken, with an example being the introduction of common health first year programs, in which students are placed together in large learning environments before they are professionalised within their own future roles. The members of the Forum have commenced the process of workshopping common assessment processes, common policies and procedures, and joint projects where representatives from a variety of the professions are involved. This is part of the continuing quality improvement that each Council is undertaking under the Quality Framework, and also in response to concerns from education providers on timing and logistics of accreditation visits. The Forum is currently working on complaints policy. Four professions are collaborating to develop Standards at the high level that are applicable across professions.

The Forum’s recently established Accreditation Managers Sub-committee will provide further opportunities for the sharing of best practice processes and procedures. The Forum has also started work on establishing a common Standard for non-medical prescribing. This work is based on the NPS MedicineWise prescribing competencies and the Health Practitioner Prescribing Pathway developed by Health Workforce Australia. This is a substantial piece of work, and will include a process for collaborative common assessment methods that could be used for a number of the professions considering expanding their scopes of practice to include limited prescribing. 23. What relationship, if any, is required between regulators and educational institutions to

ensure the minimum qualification for entry to professions remains available? The question raises issues concerning the relationships and differences between the regulation of higher education and the health professions. Under the Tertiary Education Quality and Standards Agency Act 2011, each higher education provider that is registered in the ‘Australian University’ provider category and meets the requirements under Section 45(1) of the Act is authorised to self-accredit each course of study that leads to a higher education qualification that it offers or confers. TEQSA may authorise other categories of higher education providers to self-accredit certain courses of study.

The Australian Qualifications Framework (AQF) is the national policy for regulated qualifications in Australian education and training. It incorporates the qualifications from each education and training sector into a single national qualifications framework.

Universities, through their own course approval mechanisms, have the power to approve the level of qualification for a program of study, but their programs should adhere to AQF guidelines. TEQSA has indicated that universities must comply with the AQF by January 2015 to retain registration as higher education providers.

The National Law defines accreditation standard, for a health profession, as a standard used to assess whether a program of study, and the education provider that provides the program of study, provide persons who complete the program with the knowledge, skills and professional attributes necessary to practise the profession in Australia. This places the Accreditation Authority’s focus on the assessment of the program of study’s and the provider’s ability to meet approved accreditation standards rather than the level of qualification awarded.


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Where there have been substantive changes in the level of qualification offered, Accreditation Authorities have drawn attention of their National Boards to this change, and considered the implications of the change for accreditation. For example, in response to the introduction of Australia’s first primary medical qualification set at Masters Degree level in 2011, the Australian Medical Council consulted with education providers, professional bodies, student associations, health consumer bodies, jurisdictions, health workforce bodies and higher education regulators on the change and developed a policy paper addressing the issues arising and the changes it would make to its accreditation processes as a result of the developments.

24. How effective are the current processes with respect to the assessment and

accreditation of overseas trained practitioners? As the Consultation Paper notes, one of the objectives of the National Law is to facilitate the rigorous and responsive assessment of overseas-trained health practitioners. Coupled with this are other objectives of the National Law, including ensuring protection of the public by ensuring that only health practitioners who are suitably trained and qualified to practise in a competent and ethical manner are registered, and the facilitation of access to services in accordance with the public interest. The background paper previously provided to the Review Team, which is at Appendix 1,6 lists the ten Accreditation Authorities which assess overseas trained practitioners. Significant variation in training and outcomes associated with health practitioner education occurs across (and also within) international jurisdictions. Accordingly, assessment processes need to reflect this, and the Accreditation Authorities use a range of approaches, including desktop assessment of training and qualifications, portfolio assessment, written and clinical examinations, and workplace-based assessment, depending on the nature of the profession involved and the associated risks. Nine of the Accreditation Authorities assess overseas assessing authorities and have established competent authority pathways to provide streamlined assessment pathways for applicants from some jurisdictions where the standard of training is considered to be comparable with Australia for the profession in question. Variation within professions across jurisdictions and individual programs require that such pathways are carefully considered. For example, while some professions may have recognised competent authority arrangements in relation to training undertaken in the United Kingdom (UK), the absence of training in radiography in at least one of the chiropractic programs recognised in the UK does not enable the application of competent authority recognition for all programs recognised in the UK, since being a registered chiropractor enables recognition in this component of practice in Australia. All Accreditation Authorities involved in the assessment of overseas trained practitioners are acutely aware of their responsibilities under the National Law, their accountabilities and the expectations of a range of stakeholders in this area of the National Scheme. As noted in the Consultation Paper, Australia has a significant reliance on overseas trained practitioners, particularly in rural areas, and Accreditation Authorities who conduct the assessment functions devote considerable effort to ensuring the assessment processes are appropriately benchmarked to the standard of locally-trained practitioners to enable the provision of a healthcare workforce that meets the requirements of the Australian public.

6 Appendix 1: Accreditation within the National Registration and Accreditation Scheme (NRAS) – a paper

developed by the Accreditation Liaison Group, 2014


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Similarly, much attention is focussed on ensuring timely access to assessment opportunities, at a cost to applicants that is reasonable given the requirements and accountabilities associated with the function. The above notwithstanding, all Accreditation Authorities are cognisant of the 2011 Australian Government House of Representatives enquiry in to the processes associated with the assessment of overseas trained doctors and the resultant Lost in the Labyrinth 7 report. This report made in excess of forty recommendations that were relevant to a range of bodies, including the Australian Medical Council (AMC) and the Medical Board of Australia. Both these bodies, in conjunction with others, such as the specialist medical colleges, were proactive in responding to recommendations, and resultant changes have seen significant streamlining and increased clarity and transparency of processes associated with applications, to the benefit of applicants and the health care system. Of particular significance in this regard is the capacity for the bodies involved in the assessment of overseas trained doctors to access documents required for multiple components of the assessment pathway through an electronic portal, thus reducing the time and expense incurred by applicants at the different stages of the process. Other Accreditation Authorities are interested in this approach, which, if able to be funded, could result in increased efficiencies for applicants. The construction by the AMC of a purpose-built National Test Centre in Melbourne to increase access to the clinical examination component of its examination requirements is another notable initiative, with the facility able to be accessed for use by other Accreditation Authorities and education providers.

In summary, the assessment of overseas trained health practitioners is a complex, high stakes activity conducted by ten of the independent Accreditation Authorities for their National Boards. The system is felt to work well, given the need for public safety, balanced against other considerations, including the ability of a geographically dispersed population to access healthcare in appropriate settings. The Accreditation Authorities that undertake this function are aware of the important stakeholder considerations involved in the activity and are committed to achieving further cooperative initiatives reflective of areas identified through the Lost in the Labyrinth report. 25. Should the appointment of Chairperson of a National Board be on the basis of merit? The Forum agrees that the Chairperson of a National Board should be appointed on the basis of merit. Chairs of National Boards are appointed by the Minister, rather than following the private sector practice of the chair being appointed by the board itself. However, the definition of merit requires some consideration. The ABC and SBS Acts8 for example, provide that the assessment of applicants is based on merit if:

7 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 Tabled 19 March 2012 http://www.aph.gov.au/parliamentary_business/committees/house_of_representatives_committees?url=haa/overseasdoctors/report.htm 8 Special Broadcasting Service Act 1991, Part 3A.

http://www.comlaw.gov.au/Details/C2014C00594/Html/Text#_Toc395858265


14

a) an assessment is made of the comparative suitability of the applicants for the duties of that Director, using a competitive selection process; and

b) the assessment is based on the relationship between the applicants’ experience, skills and competencies and the experience, skills and competencies genuinely required for the duties of that Director; and

c) the assessment focuses on the capability of the applicants to achieve outcomes related to the duties of that Director; and

d) the assessment is the primary consideration in nominating the candidates for that appointment.

Contemporary corporate governance principles9 recommend having independent chairs so as to contribute to a culture of openness and constructive challenge that allows for a diversity of views to be considered by the board. However, any Chairperson of a National Board will need to possess adequate technical background and have the respect of the profession. 26. Is there an effective division of roles and functions between National Boards and

accrediting authorities to meet the objectives of the National Law? If not, what changes are required?

The National Law clearly articulates a co-regulatory approach between National Boards and Accreditation Authorities. The co-regulatory approach provides for an important separation between the respective responsibilities of the Accreditation Authority and the National Board with the key features being:

the Accreditation Authority is required to develop accreditation standards following wide reaching consultation with stakeholders, to use these standards to assess programs of study and the education providers offering them, and to accredit programs of study and the education providers that meet the accreditation standards;

the National Board is required to approve the accreditation standards [s35(c)(i)], and to approve accredited programs as providing a qualification for the purposes of registration or endorsement in the relevant health profession [s35(d)].

The Accreditation Authorities recognise the importance of the independence of the accreditation functions. Independence of the accreditation function, especially decision-making processes, from the influence of any single stakeholder is internationally recognised as a fundamentally important principle of accreditation. The International Network for Quality Assurance Agencies in Higher Education (INQAAHE) Guidelines of Good Practice in Quality Assurance10 state that an external quality assurance agency ‘must be independent, i.e. it has autonomous responsibility for its operations, and its judgments cannot be influenced by third parties’. Loss of the independence of the accreditation functions under the Scheme would degrade the capacity to make decisions free of the influence of any other party and the integrity of the quality assurance aspects of the Scheme and would not be in the community’s interests.

Many National Boards and Accreditation Authorities have developed a strong working relationship that provides for independence, accountability and efficiency. However for some Accreditation Authorities and National Boards this relationship is still maturing, and in an effort to ensure that the functions are carried out correctly at times there may appear to be a compromising of independence, accountability and efficiency. This experience is consistent with views expressed by

9 ASX Corporate Governance Principles and Recommendations 3

rd Edition

10

Guidelines of Good Practice in Quality Assurance. At http://www.inqaahe.org/admin/files/assets/subsites/1/documenten/1231430767_inqaahe---guidelines-of-good-practice[1].pdf

http://www.inqaahe.org/admin/files/assets/subsites/1/documenten/1231430767_inqaahe---guidelines-of-good-practice%5b1%5d.pdf

http://www.inqaahe.org/admin/files/assets/subsites/1/documenten/1231430767_inqaahe---guidelines-of-good-practice%5b1%5d.pdf


15

the not for profit sector11 more broadly when engaged by government to provide services, where heavy handed contractual and reporting requirements and contracts have been used to micromanage providers and cause impediments to efficient and effective service delivery.

Although maintaining the independence of their work on quality and standards, the Accreditation Authorities (member councils of the Forum) recognise and support the need to demonstrate accountability in exercising the accreditation functions under the National Law. Forum members, AHPRA and the National Boards, particularly through the Accreditation Liaison Group, have worked collaboratively since the introduction of the Scheme to achieve consistent interpretation and application of the co-regulatory approach articulated by the National Law, including attention to the objectives and principles of the Scheme. The Forum believes this approach provides for best balance in decision-making. Examples include the development of:

Policies and processes concerning the implementation of accreditation functions as set out in the agreed document Accreditation under the Health Practitioner Regulation National Law Act. This document covers a range of issues associated with accreditation functions, including relationships and communication between Accreditation Authorities, National Boards and AHPRA concerning accreditation, the application of the Quality Framework for the Accreditation Function, and the Procedures for the Development of Accreditation Standards.

Guidelines for reporting accreditation decisions and recommendations on accreditation standards to National Boards.

Such collaborative work has been a balanced, efficient and effective way to achieve consistent interpretation and application of the Law, and has often proved to be particularly helpful to the smaller Councils.

Forum members recognise that further work is still required to clarify expectations and improve understanding of responsibilities under the co-regulatory approach, in order to ensure the most effective and efficient practices by both the National Boards and the Accreditation Authorities. Some Accreditation Authorities have experienced what they consider to be inappropriate and unnecessary practices, such as requiring a National Board representative on every assessment team visit conducted by the appointed external Accreditation Authority; requesting, as standard practice, to review the material gathered by an Accreditation Authority and used to make the accreditation decision, rather than having confidence in the application of agreed policies and processes and the accountability demonstrated through monitoring the performance of the Accreditation Authority as set out in the agreed Quality Framework; and some National Boards deferring decisions on approval of accreditation despite Accreditation Authorities submitting clear reports.

Some Accreditation Authority reports in the early days of the Scheme did not have the clarity needed for National Boards to have confidence to make a decision. This has been proactively addressed in some instances by the implementation of risk frameworks from the Accreditation Authority, with open dialogue with National Boards.

Members of the Forum are aware that there are examples of excellent relationships between an Accreditation Authority and a National Board and with the maturing of the Scheme and the commitment and collaboration of the entities involved, the interpretation and application of the National Law will continue to be refined and clarified including further improvement of practices

11

Contribution of the Not-for-Profit Sector. Productivity Commission Research Report; 2010. At http://www.pc.gov.au/projects/study/not-for-profit/report p 297

http://www.pc.gov.au/projects/study/not-for-profit/report


16

and responsibilities, improving the effectiveness and efficiency with which accreditation functions are undertaken.

Where there are disputes or concerns about roles, this might be referred to AHWAC.

The members of the Forum are committed to working collaboratively, and have over a number of years committed significant resources to this. There is however currently no mechanism within the Scheme for funding of multi-profession projects. The Forum believes that formally incorporating multi-profession work in the roles of both the Accreditation Authorities and the National Boards, backed by an appropriate funding allocation, would assist in streamlining and finding efficiencies, and deliver more in relation to multi-profession approaches.

27. Is there sufficient oversight for decisions made by accrediting authorities? If not, what

changes are required?

Members of the Forum believe that there is good oversight of the decisions made by the Accreditation Authorities through a range of mechanisms but recognise that improvements can be made. The mechanisms include the provisions of the National Law supplemented by agreed approaches across National Boards, Accreditation Authorities and AHPRA, which support the accreditation functions to operate effectively, and provide oversight of the decision making of the Accreditation Authorities. They include:

The Quality Framework for the Accreditation Function, as a measure of good practice for accreditation bodies

Six monthly reports to the National Board against the Quality Framework

Reviews of the accreditation arrangements for the 2010 professions.

Development of good practice principles between National Boards, Accreditation Authorities and AHPRA, and.

AHPRA Procedures for the development of accreditation standards.

The Quality Framework is central to reviewing the work of the Accreditation Authorities setting parameters for their work by identifying benchmarks of good practice across eight domains:

1. Governance

2. Independence

3. Operational management

4. Accreditation standards

5. Processes for accreditation of programs and providers

6. Assessing authorities in other countries

7. Assessing overseas qualified practitioners

8. Stakeholder collaboration.

These domains of the Quality Framework are the principal reference for National Boards and AHPRA to assess the work of Accreditation Authorities and should remain so. Accreditation Authorities provide six-monthly reports to their National Boards on developments relevant to the domains of the Quality Framework.


17

The Quality Framework was also used in 2012, when the performance of the Accreditation Authorities of the first ten professions to be regulated under the National Law were assessed during the review of accreditation arrangements. The process of the review was considered jointly by the National Boards, AHPRA and the Accreditation Authorities. The process established required the Accreditation Authority to prepare a submission assessing its performance against the domains of the Quality Framework and a wide consultation by the National Board. In this review process each Accreditation Authority prepared a detailed submission explaining their roles and functions, and providing evidence of their performance against the domains of the Quality Framework. These submissions were available publicly and each National Board consulted widely in making a decision as to the future accreditation arrangements for their respective profession.

While Forum members believe strongly in the need for independent decision-making, it is important to explain the concept of independence which applies to accreditation functions in the National Scheme. The Intergovernemental Agreement explains the concept of independent accreditation as:

“Governance arrangements that provide for community input and promote input from education providers and the professions but provide independence in decision-making”

Independence from government was explicitly included by late 2008, when the consultation paper about accreditation arrangements was issued by the National Registration and Accreditation Implementation Project. The consultation paper referred to the World Health Organisation/World Federation of Medical Education Guidelines for Accreditation of Basic Medical Education (2005) statement that “The legal framework must secure the autonomy of the accreditation system and ensure the independence of its quality assessment from government, the medical schools and the profession”.

This concept of independence is reflected in the Quality Framework.

Under the governance domain, it requires “The accreditation authority’s governance arrangements provide for input from stakeholders including input from the community, education providers and the profession/s”. Accreditation Authorities have adopted governance structures which provide for stakeholder input into accreditation decision making at a range of levels. Typically this would include an expert accreditation panel, and accreditation committee to which it reports, and often also includes a board of directors which makes the final decision on accreditation.

Under the independence domain it is required that “The accreditation authority carries out its accreditation operations independently. Decision making processes are independent and there is no evidence that any area of the community, including government, higher education institutions, business, industry and professional associations - has undue influence. There are clear procedures for identifying and managing conflicts of interest”.

In relation to review of accreditation decisions, consistent with this concept of independence, accreditation decisions are reviewable through a process of internal review by the Accreditation Authority. Under the National Law, an Accreditation Authority that decides to refuse to accredit a program of study must make available a process of internal review of the decision. The 2008 consultation paper about accreditation arrangements implies that by reference to external appeals education providers would continue to have access to the appeal arrangements existing before the National Scheme, namely recourse to review through the courts.

Accreditation Authorities recognise that education providers may wish to seek reconsideration of accreditation decisions other than those which result in refusal of accreditation, and/or review of the findings and judgments in an accreditation report. The Quality Framework requires


18

Accreditation Authorities to have complaints, review and appeals processes which are rigorous, fair and responsive, and to report to their National Board on the complaints made.

Currently the complaints, review and appeals practices vary, and members of the Forum have begun work on the development of good practice guidelines for complaints mechanisms. In this work the Forum members are considering the development of a standardised feedback tool to gather feedback on accreditation processes from education providers, as well processes that would enable external input to the review of accreditation processes and decisions.

In relation to decisions about accreditation standards, National Boards approve accreditation standards developed by Accreditation Authorities. Under section 25 (c) of the National Law, one of the functions of AHPRA is to establish procedures for the development of accreditation standards, ……. approved by National Boards, for the purpose of ensuring the national registration and accreditation scheme operates in accordance with good regulatory practice. Accreditation Authorities must apply the AHPRA Procedures for the development of accreditation standards.

Ministers have the power to issue a direction to a National Board about a proposed accreditation standard or proposed amendment of an accreditation standard if (a) in the Ministerial Council’s opinion, the proposed accreditation standard or amendment will have a substantive and negative impact on the recruitment or supply of health practitioners and (b) the Council has first given consideration to the potential impact of the Council’s direction on the quality and safety of health care, and this is appropriate.

Education providers have expressed concerns to Forum members about the costs and the regulatory burden of accreditation. The costs of accreditation vary depending on the complexity of the profession, the programs and providers. The regulatory burden may vary depending on the stage of development of the program, with greater oversight of developing programs, and the number of conditions on program/providers accreditation. Through the Forum, members are working together to improve the efficiency of processes and where possible reduce operating costs.

All Accreditation Authorities currently receive some funding from AHPRA through their National Board and hence are subsidised by the registrations in that profession. All charge a proportion of the accreditation costs to education providers, although their business models vary. They are aware of, and under the Quality Framework required to report on, the principle that fees charged should remain reasonable having regard to the efficient and effective functioning of the Scheme. Accreditation fees charged to education providers contribute towards (but do not cover) the cost of accreditation being: initial and re-accreditation of a program; monitoring to ensure continued compliance with standards; review of proposals for program changes; and providing advice to the provider. Under this model, there is limited funding available for Accreditation Authorities to undertake other accreditation related work such as develop policy, review of issues that apply to more than one program and provider, and contribute to national policy debates. The Forum members are concerned about their capacity to contribute appropriately to achieving important objectives of the Scheme, beyond business as usual accreditation processes, where the capacity to charge fees and the funding through the Scheme is constrained. 28. The Review seeks comment on the proposed amendments to the National Law.

The Forum wishes to make no response to this question.


19

Should the Independent Reviewer require further information the Chair of the Health Professions Accreditation Councils’ Forum would be happy to expand on the comments made in this submission on behalf of the Forum. Ms Peggy Sanders Forum Secretariat 0438 624 542 [email protected]

mailto:[email protected]

Accreditation with¡n the NationalRegistration and Accreditation Scheme(NRAS) - a paper developed by theAccreditation Liaison Group

The Accreditation Liaison Group (ALG) is an advisory group comprised ofrepresentatives of the National Boards, Accreditation Authorities and the Australian

Health Practitioner Reg u lation Agency (AH PRA).

The ALG initially developed this paper in July 2014 and submitted it as a backgroundpaper to the NRAS review team to inform its public consultation processes. The ALG

approved this version of the background paper for submission by the Health

Professions Accreditation Councils' Forum, the National Boards and AHPRA as an

appendix to their responses to the NRAS public consultation in October 2014.

Gontents

lntroduction

Governance

Model of accreditation

lndependence

Accreditation Authorities

Review of accreditation arrangements

Accreditation and the objectives and guiding principles of the National Law

Other bodies involved in accreditation

Accountability

Functions and infrastructure

Overview of accreditation functions under the National Law

Funding accreditation

Mechanisms to support accreditation functions

Agreement for the accreditation functions

Terms of reference for accreditation committee

AHPRA Procedures for the development of accreditation standards

Ghange and achievements

Change since the National Scheme

Achievements against the objectives and guiding principles of the National Law

The Quality Framework for the Accreditation Function

Routine reporting on accreditation functions against the Quality Framework

Processes streamlined

Publicly available information

Joint meetings

Future opportunities

Collaboration and multi-profession approaches

Conclusion

Attachments

Attachment A:

Attachment B:

Attachment C:

Ministerial CouncilS May 2009 communiqué

Report to Ministerial Council on review of accreditation arrangements

Overview of accreditation functions by profession

Accreditation within the NRAS - a paper developed by the Accreditation Liaison Group 2014 2

lntroduction

The National Registration and Accreditation Scheme has established a common statutory framework foraccreditation bodies that had previously operated within a diversity of profession-specific models. Sincethe Scheme commenced, the accreditation functions have been exercised within the statutory context ofthe National Law and the approach to independent accreditation functions within the National Schemeagreed by Ministers. Within the parameters of this model, much has been achieved by the AccreditationAuthorities, National Boards and AHPRA.

The objectives and guiding principles of the National Law are broad and extend from matters specific toeducation and training, workforce sustainability and access to services. The objectives and guidingprinciples all apply to any body exercising functions under the National Law, including AccreditationAuthorities, National Boards and AHPRA, and provide a shared context for the accreditation functionsand work on accreditation issues. The Accreditation Authorities, National Boards and AHPRA collectivelyhave worked to develop a common understanding of the National Scheme and its accreditation function,and to effectively implement the accreditation functions of the Scheme.

AHPRA, the National Boards and Accreditation Authorities have increasingly worked collaboratively toidentify opportunities for improvement, aspects of accreditation that need some consistency of approach,such as the Quatity Framework for the Accreditation Function and reporting and areas within accreditationthat lend themselves to cross-professional approaches. Steady progress continues and there is work thatis either in the early stages of implementation or that is planned, with the aim of further demonstratinggood practice in health profession accreditation.

Governance

Model of accreditation

Judgements about the effectiveness of accreditation need to be made in the context of the model

Ministers deliberately established.

The model of accreditation in the National Scheme changed as the National Scheme evolved from the2OOB tntergovernmental Agreement for a National Registration and Accreditation Scheme for the healthprofessions (the IGA). This is evident from consultation documents on key aspects of the Scheme,Ministerial announcements and the National Law, which embodies the final Scheme agreed by HealthMinisters. ln particular, the model of independent accreditation functions established by the National Law

has important differences from both the recommendations on accreditation in the 2005 ProductivityCommission Reporl on the health workforce and the lGA.

ln addition to independence, which is discussed separately below, there are other important aspects ofthe model of accreditation that evolved as the Scheme developed. For example, as the IGA

acknowledges, the Productivity Commission recommended that there should be a single nationalregistration board for health professionals, as well as a single national accreditation board for healthprofessional education and training. However, the IGA specifies that there will be boards for each of theprofessions covered by the scheme and that the boards will be responsible for both the registration and

accreditation functions. The IGA goes on to state that "...as a transitional measure, the Ministerial Council... will assign accreditation functions to existing accreditation bodies, with the requirement that within thefirst 12 months of the new scheme they meet standards and criteria set by the national agency for theestablishment, governance and operation of external accreditation bodies."

Similarly, there was a change from the IGA to the National Law in relation to the ongoing decisions aboutthe bodies to perform accreditation functions. lnitially the IGA proposed that following a review ofaccreditation arrangements, ongoing decisions about whether external bodies should continue to perform

accreditation functions would be taken by the Ministerial Council following consultation with the NationalBoards. However, as announced by Ministers in a communiqué on 27 August 2009 (see

h1lplglv¡ry4¡tqo.qov.aulnatreq.asp ) and reflected in the National Law, ongoing decisions about thebodies to perform accreditation functions are solely a matter for the National Boards.

3Accreditation within the NRAS - a paper developed by the Accreditation Liaison Group 2014

lndependence

The concept of independent accreditation functions is critical to the model of accreditation in the National

Scheme and evolved as the Scheme developed. The IGA explains the concept of independentaccreditation as:

"Governance arrangements that provide for community input and promote input from educationproviders and the professions but provide independence in decision-making"

By the time a consultation paper about accreditation arrangements. was issued by the National

Registration and Accreditation lmplementation Project in late 2008' (the accreditation consultation paper),

the concept of independence explicitly included independence from government (see statement ofprinciples on p. 6 of the accreditation consultation paper). The accreditation consultation paper referred tothe Wortd Heatth Organisation/Wortd Federation of Medicat Education Guidelines for Accreditation ofBasic Medical Education (2005) statement that "The legal framework must secure the autonomy of the

accreditation system and ensure the independence of its quality assessment from government, the

medical schools and the profession".

Ultimately, Health Ministers further modified the model of independent accreditation to remove their role

in approving accreditation standards, as reflected in their I May 2009 communiqué (see Attachment A).

Under the National Law, Ministers do not approve accreditation standards and only have the power to

issue a direction to a National Board about a proposed accreditation standard or proposed amendment ofan accreditation standard if (a) in the Council's opinion, the proposed accreditation standard oramendment will have a substantive and negative impact on the recruitment or supply of healthpractitioners and (b) the Council has first given consideration to the potential impact of the Council'sdirection on the quality and safety of health care.

Consistent with this concept of independence, the accreditation consultation paper proposed thataccreditation decisions would be reviewable through a process of internal review by the accreditationbody followed by an external appeal. Elsewhere the consultation paper implies that the reference toexternal appeals implies continuation of the appeal arrangements before the National Scheme, in whicheducation providers ultimately had recourse to review through the courts. The Quality Framework has

built on this approach, by requiring accreditation authorities to have complaints, review and appealsprocesses which are rigorous, fair and responsive, and to report to their National Board on the complaintsmade.

Ministers have clearly expressed the intention that accreditation functions be independent of all

stakeholders including government through the lGA, accreditation consultation paper and the National

Law. National Boards, Accreditation Authorities and AHPRA have worked to implement the model ofindependent accreditation functions consistent with Ministers' intentions.


There are currently 11 external Accreditation Authorities and three accreditation committees exercisingaccreditation functions in the Scheme (see www.ahpra.gov.au/Education/Accreditation-Authorities.aspx).All Accreditation Authorities, whether external authorities or committees, are independent in making

accreditation decisions.

Ministers assigned accreditation functions to external Accreditation Authorities for the first ten professions

to be regulated under the Scheme, for the first three years of the Scheme. ln December 2008, the

Ministerial Council appointed Accreditation Authorities for chiropractic, dental care, medicine, optometry,

osteopathy, pharmacy, physiotherapy and psychology. ln March 2009 an Accreditation Authority wasappointed for podiatry and then for nursing and midwifery in 2010.

t seewww,ahwo.gov.auldocumentqlNationAllq2QReg¡sl@tion%20qnd%2OAccrgditation/Cq¡sultatiq¡7o20paper%20on%20 Accred itation %20v 1 .0. pdf


ln contrast, Ministers provided for the National Boards for the 20'12 professions to decide whether theiraccreditation function is to be exercised by an external accreditation entity or a committee established by

the National Board. The 2012 professions are relatively small and were not regulated in all jurisdictions

before the Scheme commenced (two professions were only regulated in one state or territory prior to theNational Law) . For tuo 2012 professions there was not an obvious or well-established body to take on

accreditation functions.

The National Law also provided for the review of the accreditation arrangements for the first tenprofessions after three years.

Review of accreditation arrangements

ln 2012, there was a review of the accreditation arrangements for each of the first ten professions to beregulated under the National Law. The process for these reviews was considered jointly by the NationalBoards, AHPRA and the Accreditation Authorities (initially through the Accreditation Liaison Group) and

the agreed process provided for a submission from the Accreditation Authority and wide-rangingconsultation by the National Board. ln this review process, each Accreditation Authority prepared adetailed submission explaining their roles and functions, and providing evidence of their performanceagainst the domains of lhe Quality Framework for the Accreditation Function. These submissions wereavailable publicly and National Boards consulted widely in making a decision about the review of theaccreditation a rra n gements for thei r profession.

There was significant additional work undertaken by the Accreditation Authorities to prepare for thisassessment at short notice, and the very substantial submissions developed had resource implications forthe authorities. The submissions continue to be available publicly and are a useful reference on the work

of the authorities.

As a result of these reviews, each National Board determined that its Accreditation Authority was meeting

the domains of the Quality Framework for the accreditation function and would continue to exerciseaccreditation functions, most commonly for a five year period. ln some cases, individual National Boardshave required the relevant Accreditation Authorities to make changes to better meet the QualityFramework and model of independent accreditation decision-making.

The review processes highlighted how much has been achieved in implementing the accreditationcomponent of the National Registration and Accreditation Scheme and demonstrated that the business ofaccreditation had transitioned well into the new framework. Prior to 2010, health profession accreditationoperated outside a national regulatory framework, and although there was a regulatory framework forseveral professions there was considerable diversity in their operation. The reviews document how

Accreditation Authorities have reviewed their governance structures to strengthen their operations asindependent entities consistent with the accreditation model established by the Scheme.

lssues raised in the review by stakeholders such as Health Workforce Australia were identified as areasfor further consideration by Accreditation Authorities and National Boards (and articulated in the renewed

Agreements), such as:

. opportunities to increase cross-profession collaboration and innovation and address the guidingprinciple of the National Law that the Scheme is to operate in a transparent, accountable,efficient, effective and fair way, for example, opportunities involving joint projects with otheraccreditation entities or the Health Professions Accreditation Councils' Forum (the Forum)

. opportunities for each Accreditation Authority to facilitate and support inter-professional learningin its work

. opportunities for each Accreditation Authority to encourage use of alternative learningenvironments, including simulation, where appropriate.

lndividual Accreditation Authorities are reporting separately to their National Boards on their response tothese issues.


More information is available in the attached report of the review of accreditation arrangements (see

Attachment B) which was submitted to Ministerial Council, through the Australian Health Ministers'Advisory Council and its Health Workforce Principal Committee.

Accreditation and the objectives and guiding principles of the National Law

Accreditation Authorities have worked within the framework, structure and provisions of the National Lawto deliver accreditation functions that meet the objectives and guiding principles of the National Lawassisted by collaborative work with National Boards and AHPRA.

The objectives and guiding principles in section 3 of the National Law apply equally to all those exercisingfunctions underthe National Law i.e. National Boards, Accreditation Authorities and AHPRA. ln exercisingtheir functions each must have regard to the objectives and guiding principles.

Objectives directly related to accreditation functions

Section 42 defines accreditation functions quite broadly. The objectives relating to facilitating theprovision of high quality education and training of health practitioners (s3(2)(c)) and facilitating therigorous and responsive assessment of overseas qualified practitioners (s3(2)(d)) relate directly toaccreditation functions. Accreditation standards and accreditation of programs of study against thosestandards are fundamental determinants of the quality of the education and training of healthpractitioners. Accreditation Authorities develop processes to assess overseas qualified practitioners andundertake those processes, and therefore control the responsiveness and rigorousness of thoseassessments.

Other objectives

Parts of section 3 dealing with protection of the public, workforce mobility, public access to services, thedevelopment of the workforce and innovation in the education of, and service delivery by, healthpractitioners are also relevant to accreditation functions, as described below.

Protection of the public

The quality of the assessment of overseas qualified practitioners, accreditation standards andaccreditation of programs of study determines whether practitioners who complete programs of study orare assessed as qualified for registration have the knowledge, skills and professional attributes to practisetheir professions and is critical to protecting the public.

F a c i I itate wo rkfo rce m o b i I ity

The establishment of the National Scheme has facilitated workforce mobility, including by establishingnational accreditation standards and processes where in some cases they did not previously exist.

Facilitate access fo servlces in the public interest

lf the registration standards, codes and guidelines developed by national boards are unnecessarilyonerous or restrictive, this could impact on access to services. Similarly, if the assessment process foroverseas practitioners is unnecessarily onerous or unduly restrictive, it could impact on the number ofoverseas qualified practitioners from professions in shortage who are able to enter Australia to provideservices. lf accreditation standards are unnecessarily onerous, institutions may decide not to offercourses, impacting on the supply of practitioners and ultimately on access to services.

Continuous development of a flexible, responsive and sustainable workforce

Registration standards, codes and guidelines as well as accreditation standards, the quality ofaccreditation of programs of study and assessment of overseas qualified practitioners may all influencethe attainment of this objective.


Other bodies involved in accreditation

The Health Professlons Accreditation Councils' Forum

The Health Professions Accreditation Councils' Forum (the Forum) is the coalition of the accreditationcouncils of the external Accreditation Authorities for the professions regulated under the National Law.

The Forum has been meeting regularly since 2007, prior to the commencement of the Scheme, toconsider matters of common interest, principally matters concerning the accreditation of education and

training programs in the health professions and advocating for good accreditation practices. The Forum

has worked to ensure that the requirements of best practice in accreditation and the independence of the

accreditation bodies is reflected in the National Law and in the implementation of the Law, and engageswith AHPRA and the National Boards in relation to the operation of the Scheme, particularly in the area ofaccreditation, education and training.

Forum of National Board Chairs

The Forum of National Board Chairs (the Chairs Forum) supports the national boards and AHPRA toachieve good regulatory performance and decision-making by bringing cross-professional leadership and

focus to the administration and strategic development of the National Scheme. The Chairs Forum

comprises all National Board Chairs, the Chair of AHPRA's Agency Management Committee and

AHPRA's National Executive. lt has a number of committees, including the Accreditation Liaison Group.

Chairs of Accreditation Committees

The Chairs of Accreditation Committees also meet regularly to share their experience and learnings from

exercising accreditation functions through Committees and to facilitate collaboration.

Accreditation Liaison G roup

The National Boards, Accreditation Authorities and AHPRA have established an Accreditation Liaison

Group (ALG) to facilitate effective delivery of accreditation within the National Scheme. The ALG is a

committee of the Forum of National Board Chairs and provides an important mechanism to considershared issues in accreditation across National Boards, Accreditation Authorities (nominated through theForum) and AHPRA. lt is an advisory group which has developed a number of reference documents topromote consistency and good practice in accreditation while taking into account the variation acrossentities. These documents have been approved by National Boards and Accreditation Authorities.Examples include lhe Quality Framework for the Accreditation Function.

Accountability

Under the model of accreditation functions established by the National Law, National Boards are

ultimately accountable for oversighting accreditation functions through their decisions about the body

which will perform accreditation functions. ln turn, National Boards are accountable to the AustralianHealth Workforce Ministerial Council. Accreditation Authorities are accountable for the performance ofaccreditation functions and their decisions may be subject to appeal through the courts. AHPRA has arole in relation to the agreements with external bodies for accreditation functions, content in the Health

Professions Agreements in relation to accreditation committees and the establishment of procedures,

such as the Procedures for the development of accreditation standards.

Functions and infrastructure

Overview of accreditation functions under the National Law

Accreditation is the second of the two branches of the National Registration and Accreditation Scheme.

The National Law defines accreditation functions as:

. develop accreditation standards and recommend them to the relevant National Board for approval

. accredit and monitor education providers and programs of study to ensure that graduates areprovided with the knowledge, skills and professional attributes to safely practise the profession inAustralia.


. provide advice to National Boards about issues relating to their accreditation functions

. assess overseas qualifìed practitioners

. assess overseas accrediting authorities.

Attachment C sets out the accreditation functions exercised by each Accreditation Authority.

Accreditation is an important quality assurance and quality improvement mechanism for healthpractitioner education and training. lt is also the key quality assurance mechanism to ensure thatgraduates completing approved programs of study have the knowledge, skills and professional attributesto practise the relevant profession in Australia. Accreditation standards and accreditation of programs ofstudy against those standards are fundamental determinants of the quality of the education and training

of health practitioners; and by international benchmarking Accreditation Authorities ensure best practice

in accreditation standards. Accreditation Authorities develop and undedake processes to assessoverseas qualified practitioners, and therefore are responsible for the responsiveness and rigorousnessofthose assessments.

Accreditation Authorities and National Boards have separate, but complementary, functions under the

National Law. For example, as discussed below, the National Law provides that:

. the Accreditation Authority develops the accreditation standards which are then approved by the

National Board. the Accreditation Authority accredits a program of study and the relevant National Board

approves the accredited program of study for the purposes of registration.

Development of accreditation standards

Accreditation standards are used to assess whether a program of study, and the education provider thatprovides the program of study, provides graduates of the program with the knowledge, skills andprofessional attributes to practise the profession. Each Accreditation Authority publishes on its website

the approved accreditation standards for the profession and information about any reviews of the

standards and opportunities for stakeholder input to those reviews.

Accreditation Authorities are required to develop accreditation standards for the education and training for

the profession through a wide-ranging consultation process and taking into account the requirements of

lhe Procedures for the Development of Accreditation Standards (the Procedures) (see

www.ahpra.qov.aulPublications/Procedures.aspx). The Procedures also apply to amendments to an

accreditation standard. The Procedures are currently being updated to include engaging with the Office

of Best Practice Regulation about regulatory impacts, and this step is occurring in anticipation of the

revised Procedures. Proposed accreditation standards are submitted by the Accreditation Authority to the

National Board for approval.

The National Board must decide whether or not it approves the proposed accreditation standardssubmitted by the Accreditation Authority.

Assessmenf and accreditation of education programs and providers

The Accreditation Authority:

1. assesses education and training programs of study, and the education providers that provide theprograms of study, against the approved accreditation standards to determine whether theprograms meet the approved accreditation standards, and

2. advises the National Board of its accreditation decision - i.e. whether program of study, and the

education provider that provides the program of study, meet an approved accreditation standardfor the profession; or the program of study and provider substantially meet an approvedaccreditation standard for the profession and the imposition of conditions on the approval will

ensure the program meets the standard within a reasonable time'

IAccreditation within the NRAS - a paper developed by the Accreditation Liaison Group 2014

Approval of the accredited programs of study for registration purposes

When a program of study has been accredited, the relevant National Board considers whether it will

approve, or refuse to approve, the accredited program of study for the purposes of registration. Only

graduates of approved programs are qualified for registration under s. 53(a) of the National Law. Asearchable list of approved programs of studv is available on this website.

Monitoring of accredited programs and education providers

The National Law requires Accreditation Authorities to monitor accredited programs and educationproviders to ensure that the authority continues to be satisfied that the program and provider meet an

approved accreditation standard for the profession. Although Accreditation Authorities already had

monitoring processes in place before the National Scheme commenced, the introduction of statutoryrequirements for monitoring strengthen consistency and improve its effectiveness as a quality assurancemechanism to ensure that graduates of approved programs of study have the knowledge, skills and

professional attributes to practise the relevant professton.

Effective approaches to monitoring involve substantial work for Accreditation Authorities and educationproviders. Regulation of monitoring is changing the dynamic of accreditation and has brought much more

of a focus on ongoing review against the standards. Accreditation Authorities are now providing more

thorough reporting on their monitoring work.

Assessmenf of overseas qualified practitioners

Ten Accreditation Authorities (see Attachment C) assess overseas qualified practitioners, with varying

approaches and requirements which typically include a desktop qualifications assessment and clinical

examination, but also often involve a written examination, and may involve a portfolio assessment or

requirement for orientation to Australian practice.

Assessmenf of overseas assesstng authorities

Nine Accreditation Authorities (see Attachment C) assess overseas assessing authorities, and have

established competent authority pathways, which provide streamlined assessment processes for certain

cohorts of overseas qualified practitioners. The competent authority pathways are necessarily specific to

the particular characteristics of the relevant professions and assessing authorities.

Funding accreditation

Each of the Accreditation Authorities that existed prior to the Scheme had a different model of funding

their accreditation activities although there were some common features. These models included

contributions from the relevant state and territory registration boards on whose behalf the authoritiescarried out accreditation activities - albeit generally without a statutory basis. lt is clear from the IGA and

consultation documents from the development of the Scheme that the Scheme would be self-funding from

registration and accreditation fees. The IGA states (at para 12.6): Where appropriate, registration fees will

cointinue to contribute to the accreditation function and transitional arrangements will apply as necessary.

The guiding principles of the National Law require the Scheme to operate in a transparent, accountable,

efficiónt, effective and fair way, and fees paid under the Scheme (including Accreditation Authorities' fees

to education providers) must be reasonable having regard to the efficient and effective operation of the

Scheme. fhe Quality Framework for the Accreditation Function requires that, in setting its fee structures,

each Accreditation Authority balances the requirements of the principles of the National Law and efficient

business processes.

Proportionally, accreditation is a modest cost to the National Scheme. For most National Boards a small

percentage of their income is distributed to Accreditation Authorities to carry out their required functions

under the National Law.

Under current arrangements, each Accreditation Authority derives all or part of its revenue from:

. fees paid by education providers for program assessment and accreditation, and

. a contribution from the relevant National Board.


Some Accreditation Authorities also receive fees for service activities in relation to assessing overseasqualifìed practitioners.

Each Accreditation Authority sets the fees paid by education providers in accordance with their respectivebusiness model and in consultation with the provider. The fees contribute towards (but do not cover) thecost of accreditation being: initial and re-accreditation of a program; monitoring to ensure continuedcompliance with Standards; and, other activities arising from the accreditation function such as advice tothe provider.

The Accreditation Authorities submit their requests for a contribution by the relevant National Board aspart of the Boards' annual budgeting processes. AHPRA, as agreed with the relevant National Board,

may approve an adjusted funding amount each year having regard to the activity to be undertaken by theAccreditation Authority, and in consultation with the Accreditation Authority and agreement whereverpossible. Where the accreditation function is exercised by an external entity, this amount is included aspart of the profession's Agreement for the Accreditation Function between AHPRA and the AccreditationAuthority. Where the accreditation function is exercised by a committee established by the Board, the

amount is reflected in the Board's budget as a net cost of accreditation.

The costs of accreditation vary between professions and reflect the variable complexity of professions,

education providers and programs of study across the 14 professions within the Scheme. For example,the length of programs varies, the number of divisions of the National Boards' registers vary, the providersthemselves range from small private registered training organisations to large public and private

universities, and the education and training pathways differ in terms of their complexity and any relevantinternational benchmarks.

Mechanisms to support accreditation functions

A number of mechanisms have been established to support the statutory framework and facilitateaccreditation functions meeting the objectives and guiding principles of the National Law. These include:

. agreements for the accreditation functions between AHPRA, in consultation with the relevantNational Board, and each external Accreditation Authority

. AHPRA Procedures for the development of accreditation standards

. the work of the Accreditation Liaison Group on key shared accreditation issues

. annual meetings between representatives of all National Boards, Accreditation Authorities and

AHPRA to discuss common accreditation issues. terms of reference for each Accreditation Committee.

Agreements for the accreditation functions

The agreements for the accreditation functions between AHPRA, on behalf of the relevant NationalBoard, and each external Accreditation Authority is the formal document which describes the details ofthe accreditation functions, reporting, funding and work program for the Accreditation Authority. Theagreement and/or work program is a mechanism to highlight priority issues for Accreditation Authorities to

consider in their work.

Terms of reference for accreditation committees

The terms of reference for each accreditation committee set out the functions, reporting, process toidentify annual funding and work program for the Accreditation Authority. While the National Board

establishes an accreditation committee and sets its terms of reference, the committee's statutorydecision-making functions are conferred directly by the National Law and are not delegated by theNational Board.

The terms of reference for each accreditation committee are published on the relevant National Board'swebsite.

AHPRA Procedures for the development of accreditation standards


AHPRA's Procedures for the development of accreditation standards (the procedures) are an importantmechanism for articulating a common process for the development and approval of accreditationstandards, and the interrelationships between the National Registration and Accreditation Schemeentities on this function. The procedures were developed with input from the Australian HealthProfessions Councils' Forum and others. They inform National Boards, Accreditation Authorities andAHPRA about the matters:

. that an Accreditation Authority should take into account in developing accreditation standards orchanging accreditation standards

. which an Accreditation Authority should explicitly address when submitting accreditationstandards to a National Board for approval

. that a National Board should consider when deciding whether to approve accreditation standardsdeveloped by the Accreditation Authority, and

. which National Boards should raise with Ministerial Council as they may trigger a MinisterialCouncil policy direction and the timing for this to occur.

Ghange and achievements

Before 1 July 2010, health profession accreditation functions were largely conducted outside a statutoryframework. Accreditation Authorities reflected considerable diversity, which has continued under theScheme, however all the Accreditation Authorities are now operating within the framework of the NationalLaw. Many Accreditation Authorities have been undertaking accreditation of programs and assessment ofoverseas qualified practitioners for many years. While many of the established accreditation policies andprocedures continue, Accreditation Authorities have evolved and adapted to the requirements of theScheme. Achievements include: stronger governance and operating structures including the contributionof a wide range of stakeholders; reporting directly against the accreditation standards; and the ongoingmonitoring of education providers.

Differences between the Accreditation Authorities include the following:

. some Accreditation Authorities have been operating as independent national bodies for manyyears while some operated on a state and territory basis and became national bodies only afterthe Scheme commenced, others have been in place for only around 18 months

. some Accreditation Authorities accredit large numbers of programs (over 400) while othersaccredit very small numbers (eg less than ten)

. some Accreditation Authorities operate in Australia only while others are joint Australia/NewZealand bodies and some operate in other countries, for example, where an Australian educationprovider delivers part or all of an approved program of study in another country,

. eleven Accreditation Authorities are independent external organisations while three arecommittees established by National Boards

. some authorities exercise functions for professions with complex structures, including multipledivisions of the register, specialties, endorsements, examinations systems and compulsoryvocational pathways, while others exercise functions for professions with less complex regulation

. ten Accreditation Authorities assess overseas qualified practitioners, with varying approaches andrequirements

. nine Accreditation Authorities assess overseas assessing authorities

Change since the National Scheme

Accreditation Authorities (and the relevant National Boards) have made very significant organisationaland operational adjustments to effectively deliver accreditation functions within the new statutoryframework. The relationships between Accreditation Authorities, and the National Boards and AHPRAhave developed and matured since 1 July 2010. Each of the National Boards and their AccreditationAuthorities have agreed to the process for reporting of accreditation decisions and have further enhancedthis communication by developing their own arrangements for engagement within the framework of theNational Law and the shared understanding built between National Boards, Accreditation Authorities andAHPRA. These relationships have also been supported by the Forum, which now includes discussions


with all the Accreditation Authorities as well as discussions amongst the external authorities only, the

Accreditation Liaison Group and meetings of the Chairs of the three accreditation committees.

Achievements against the objectives and guiding principles of the National Law

The uninterrupted delivery of accreditation functions through the transition to the National Scheme is a

significant achievement. The Accreditation Authorities in particular, with National Boards and AHPRA,worked to support a seamless transition from the diverse range of accreditation approaches pre-1 July2010, to the delivery of accreditation functions by independent Accreditation Authorities within a singlestatutory framework.

The importance of including accreditation as a fundamental part of the Scheme cannot be

underestimated. The change flowing from applying the objectives and guiding principles of the NationalLaw to accreditation is profound, and has important and far-reaching implications for the delivery ofaccreditation functions. Similar to other areas of the Scheme, perceptions of the extent of this changevary and may not always reflect the significant shift that has occurred.

Comments on specific objectives

The effective delivery of accreditation functions directly achieves objective (c) facilitating the high quality

education and training of health practitioners and (d) the rigorous and responsive assessment ofoverseas-trained health practitioners. lndividual Accreditation Authorities will provide examples of theirachievements in these areas. However, since the Scheme commenced, accreditation has made animportant contribution to objective (f) enabling the continuous development of a flexible, responsible and

sustainable Australian health workforce and innovation in the education of, and service delivery by,

practitioners.

For example, the accreditation standards for all professions contribute to the objectives and guidingprinciples particularly objective (f), by:

. not precluding the use of interdisciplinary supervision models for student clinical placements. The

focus of standards is more that the supervisor has the required competencies, skills, knowledge,authority, time and resources to provide the supervision appropriate to the learning outcomes the

student is to achieve. ln some professions supervision by health professionals from alternativedisciplines is an established practice.

. allowing the use of simulated learning (SLE). The role of simulation as a learning method is

recognised; its use should be supported by evidence for achieving the learning outcomes the

student is to achieve. For several Accreditation Authorities it is particularly recognised that SLE

could be used to enhance, support and in certain circumstances replace some direct clinicalinvolvement.

The outcomes focus of accreditation standards generally facilitates innovation by education providers

lncluding accreditation in the National Scheme made a significant contribution to the objective offacilitating workforce mobility. The availability of national accreditation standards, and nationallyaccredited and approved programs of study are fundamental elements to support workforce mobilityacross Australia which were not always in place before the National Scheme commenced.

Other key achievements

Other key achievements include

developing a Quality Framework as the primary measure of quality accreditation functions underthe National Lawdocumenting an agreed understanding of the shared responsibilities in the accreditation functionunderthe National Law, promoting efficiency and effectivenessdeveloping a Framework for Accreditation Authorities and National Boards on CommunicatingAccreditation and Program Approval Declsions and Requests for Changes to AccreditationStandards and other reference documents which reflect the objectives and guiding principles of


the National Law and promote a consistent framework for the performance of accreditationfunctions

. developing an agreed process for the consultation and review of the assignment of theaccreditation functions

. work to develop a Guideline on the management of complaints relating to accreditation functionsunder the National Law

. availability of additional data - including significant work to provide information for inclusion in thesearchable register of approved programs of study on each National Board and AHPRA'swebsite, promoting transparency.

Other matters that have been the subject of joint work include:

. the agreements between AHPRA, for the National Boards, and the external AccreditationAuthorities

. the issues related to accreditation of new programs of study

. AHPRA's Policy for approved programs of study

. the Forum regularly discusses good practice in accreditation and has shared approaches such asprocedural guides contributing to commonality across authorities. Some Forum members have

also provided assistance to the accreditation committees and their support unit. the Forum has delivered multi-profession workshops for accreditation assessors, and the Forum

Chair contributed to assessor training for accreditation committees. some Accreditation Authorities have undertaken joint work on the development of accreditation

standards. jointly considering the principles for the development of accreditation standards and processes for

prescribing. the three accreditation committees have largely common processes.

Key achievements are discussed in more detail below.

The Quality Framework for the Accreditation Function

The Accreditation Authorities, National Boards and AHPRA have agreed to a Quality Framework for the

Accreditation Function to support quality assurance and continuous quality improvement of accreditationunder the National Law.

The framework identifies eight domains of good practice:

1. Governance

2. lndependence

3. Operationalmanagement

4. Accreditation standards

5. Processes for accreditation of programs and providers

6. Assessing authorities in other countries

7. Assessing overseas qualified practitioners

8. Stakeholdercollaboration.

The Quality Framework is the principal reference document for National Boards and AHPRA to assessthe work of Accreditation Authorities. Accreditation Authorities provide six-monthly reports to theirNational Boards on developments relevant to the domains of the Quality Framework. The QualityFramework was also used in 2012, when the performance of the Accreditation Authorities of the first tenprofessions to be regulated under the National Law was assessed during the review of accreditationarrangements.


The Quality Framework is an important document in promoting consideration of the objectives andguiding principles of the National Law. lt emphasises that the National Law requires those exercisingfunctions under the National Law to do so having regard to the objectives and guiding principles. ln

addition, the Quality Framework itself promotes effectiveness and efficiency in accreditation functions.

The Quality Framework will be reviewed at least every three years. The Accreditation Liaison Group has

begun work on its first review, and is planning consultation with key stakeholders such as government.

Routine reporting on accreditation functions against the Quality Framework

The agreement between AHPRA, in consultation with the relevant National Board, and externalAccreditation Authority for the accreditation functions specifies the reporting requirements for theauthority. The reporting requirements for accreditation committees mirror these requirements with minormodifications to take into account that an accreditation committee is not a separate legal entity (eg itsfinancial accounting is part of the National Board/AHPRA's accounts).

Accreditation Authorities report against the domains of the Quality Framework for the AccreditationFunction. The Accreditation Liaison Group has developed a Sample guide for a repoft by an AccreditationAuthority wlth input from National Boards and Accreditation Authorities. The Sample guide indicates thatan Accreditation Authority will provide two reports per year:

1. a retrospective report, which includes:

. a copy of the annual report prepared on behalf of the authority's governing body for the previousperiod including the publicly available financial statements

. a detailed financial report on revenue and expenditure relevant to the accreditation function andany other projects or work funded by the relevant National Board through AHPRA

. a report, as outlined in the sample guide, against domains in the Quality Framework

. a half yearly update on activity against the work program; and

2. a prospective report, with a draft work plan and budget for the next financial year.

Since the Scheme commenced, the quality, consistency and comprehensiveness of repoñing has

continued to develop. Accreditation Authorities also report to National Boards each time they make anaccreditation decision and when they review, or develop new, accreditation standards.

Reporting against the Quality Framework is an important accountability mechanism and contributes to theguiding principles of efficiency and effectiveness.

Processes streamlined

Communication framework for accreditation decrsions

The Accreditation Liaison Group has developed a Framework for Accreditation Authorities and NationalBoards on Communicating Accreditation and Program Approval Decrslons and Requests for Changes toAccreditation Standards (the Framework).

The National Law requires communication between the Accreditation Authorities and the National Board

when certain decisions are made or required. The Framework provides guidance on what AccreditationAuthorities should report to National Boards to enable the Boards to discharge their separate roles andhow National Boards and Accreditation Authorities can work collaboratively to facilitate good decision-making.

The Framework provides a set of guiding principles for Accreditation Authorities and National Boards on(i) matters to address in reporting an accreditation decision; and (ii) reporting on new or revisedaccreditation standards. lt facilitates consistent approaches that promote good decision making and the

objectives and guiding principles of the National Law. lt is expected to be published on the AHPRA andHealth Professions Accreditation Councils' Forum websites shottly.


The Framework contributes to the effectiveness and efficiency of accreditation functions and therespective decision-making roles of National Boards and Accreditation Authorities.

Complaints

The Accreditation Liaison Group is developing a template complaints protocol, as a resource for allAccreditation Authorities and National Boards. The template protocol aims to clarify the respective roles,responsibilities and processes of Accreditation Authorities, National Boards and AHPRA in themanagement of complaints about matters relevant to accreditation functions. lt aims also to describegood practice in managing complaints relating to accredited programs and providers of those programs.The guidance document is expected to be completed shortly and will be published as a referencedocument. lt will contribute to the guiding principle of fairness, and as with all resource documents willpromote efficiency and effectiveness and avoid duplication.

Publicly available information

A feature of the National Law is the requirement for published information about accreditation functions.The establishment of the Quality Framework has also facilitated the development of consistent reportingrequirements. ln addition, there are now published reference documents which document and expandupon some of the obligations of all Accreditation Authorities within the statutory framework of the Schemesuch as the Quality Framework and wide-ranging public consultation on the accreditation standards. Thiscontributes to the guiding principle of transparency.

The AHPRA website publishes a list of Accreditation Authorities and which functions they exercise underthe National Law (htto://www.ahora.oov.aulEducati on/Accred itation-Authorities.as ox

The National Law provides that each Accreditation Authority must publish how it exercises theaccreditation function. Each Accreditation Authority publishes information online about its functions (see

Attachment C for links).

National Boards must publish the accreditation standards they approve. National Boards do this bypublishing the standards on their websites or publishing via a link to where the approved standards arepublished by the relevant Accreditation Authority.

National Boards, Accreditation Authorities and AHPRA have also developed a reference documentAccreditation under the National Lar¡¡, which is published on the AHPRA website(http://www.ahpra.gov.aulPublications/Accreditation-publications.aspx). The Quality Framework andinformation about the reviews of accreditation arrangements are also published on the AHPRA website.As furlher reference documents describing agreed good practice approaches are developed, they areprogressively published to build more transparency over time.

Joint meetings

Joint meetings are held annually between representatives of all National Boards, Accreditation Authoritiesand AHPRA on an annual basis. These meetings provide a formal mechanism to discuss commonaccreditation issues. They aim to facilitate shared understandings of accreditation under the National Law

to address the objectives and guiding principles of the National Scheme. For example, previous jointmeetings have focussed on routine reporting requirements, reporting on accredited programs of studyand the potential for cross-profession approaches in accreditation. This work has contributed to theefficiency and effectiveness of accreditation arrangements.

Future opportun¡ties

Collaboration and multi-profession approaches

Opportunities for collaboration in accreditation continue to be actively explored by the Health ProfessionsAccreditation Councils Forum, individual Accreditation Authorities and Committees and the AccreditationLiaison Group.


For example, the ALG workplan lor 2014 includes:

. Support for interprofessional education, and consideration of the scope for a cross -professionworkshop on interprofessional education

. 2014 Joint Meeting, to considerfacilitation and achievements in relation to simulation,interprofessional education and collaboration that can be presented to the NRAS review

. Review of Quality Framework and Sample Reporting Guide

There is scope to continue to build collaboration between Accreditation Authorities within the frameworkof the National Law. Accreditation functions are currently delivered through separate profession-specificstructures. External Accreditation Authorities are separate organisations, although in two cases theirSecretariat and administrative services are delivered by the same service company. AccreditationCommittees are also profession-specific and are supported by AHPRA. However, these arrangementsare not the only possibilities within the existing framework of the National Law, which allows for greatercollaboration and shared administrative arrangements if appropriate. For example, the National Law is not

an impediment to two or more Accreditation Authorities agreeing to combine their administrativefunctions. However, the criteria when this would be appropriate would need to be articulated and

sustainability, efficiency and effectiveness would be important considerations.

The implications of these opportunities, identifying exemplars of good practice, whether there is potentialto build greater collaboration or consistency or whether diverse approaches are more appropriate are

issues for further consideration by the Accreditation Authorities, and other bodies in the National Scheme.

ConclusionAccreditation Authorities in particular, with National Boards and AHPRA, have worked hard to develop a

shared understanding of the model for accreditation established by the National Law and to effectivelydeliver the accreditation functions under the Law. Accreditation Authorities, National boards and AHPRAhave proactively established liaison mechanisms to facilitate joint understanding, share good practice and

build common resources where appropriate. This work continues to progress steadily and contributes tothe critical work of individual Accreditation Authorities to ensure that graduates of accredited andapproved programs of study have the knowledge, skills and professional attributes to practise theirprofession and overseas qualified practitioners are subject to rigorous and responsive assessment.

Accreditation within the NRAS - a paper developed by the Accreditation Liaison Group 2014 to

Australian Health Workforce Ministerial Council

GommuniquéI May 2009

DESIGN OF NEW NATIONAL REGISTRATION AND ACCREDITATION SCHEME

The Ministerial Council has today reached a national consensus on how the newNational Registration and Accreditation Scheme for the Health Professions will work.This will deliver improvements to the safety and quality of Australia's health servicesthrough a modernised national regulatory system for health practitioners.

The Ministerial Council acknowledged and welcomed the very high level of participationby consumers, practitioners and regulatory bodies in the consultation process to date.Over 1,000 people have attended forums around the country and over 650 writtensubmissions have been received in response to the consultation papers issued in 2008and 2009.

As a result of the consultation process and the feedback received, the MinisterialCouncil has determined that a number of changes should be made to the originalproposals put fonruard, in pafticular in the areas of accreditation, the role of state bodiesand complaints handling.

'The following sections outline the main matters on whii:h

Ministers have made decisions today.

lndependent accred itation functions

The Ministerial Council agreed today that the accreditation function will be independentof governments. Accreditation standards will be developed by the independentaccrediting body or the accreditation committee of the board where an external bodyhas not been assigned the function.

The accrediting body or committee will recommend to the board, in a transparentmanner, the courses and training programs it has accredited and that it considers tohave met the requirements for registration. The final decision on whether theaccreditation standards, courses and training programs are approved for the purposesof registration is the responsibility of the national board. The accrediting body will havethe ability to make its recommendations publicly available in the circumstance thatagreement between the accrediting body and the national board cannot be achieved.

The Ministerial Council will have powers to act, for instance, where it believes thatchanges to an accreditation standard, including changes to clinical placement hours orworkplace and work practice, would have a significantly negative effect.

National accreditation standards which exist prior to the commencement of the newscheme are to continue until they are replaced by new standards.

Page 1 of 5

Existing external accrediting bodies such as the Australian Medical Council and theAustralian Pharmacy Council are expected to continue. The specific governancearrangements for these bodies will be a matter for them, although they will be expectedto meet modern governance standards.

Ghanges to registers

Ministers today agreed there will be both general and specialist registers available forthe professions, including medicine and dentistry, where ministers agree that there is to

be specialist registration. Practitioners can be on one or both of these registers,depending on whether their specialist qualification has been recognised under thenational scheme. Ministers agreed specialist registers will not cover practitionersregistered to practice in an area of need.

Ministers have also decided that there will now be separate registers for nurses and formidwives.

Support for continuing professional development

The Ministerial Council has agreed that there will be a requirement that, for annualrenewal of registration, a registrant must demonstrate that they have participated in a

continuing professional development program as approved by their national board.

Each profession's requirements will be set by the relevant board. A board may use itsaccrediting body to set standards for such programs and approve providers of suchprograms (including, in the case of medicine, specialist medical colleges) where that isthe best arrangement for that profession.

Extension of scheme to other professions

The Ministerial Council also decided that, from 1 July 2012, Aboriginal andTorres Strait lslander health practitioners, Chinese medicine practitioners and medicalradiation practitioners will be regulated under the scheme. These are in addition to theten professions already agreed for inclusion in the national scheme from 1 July 2010(chiropractors; dental (including dentists, dental hygienists, dental prosthetists anddental therapists); medical practitioners; nurses and midwives; optometrists;osteopaths; pharmacists; physiotherapists; podiatrists and psychologists).

Other improvements to quality and safety of health services

The Ministerial Council also agreed a number of other changes to registrationarrangements in order to improve the quality and safety of health services being

delivered to the public. These are set out below.

Mandatoru repoñinq of registrantsThe Ministerial Council agreed on 5 March 2009 that there will be a requirement thatpractitioners and employers (such as hospitals) report a registrant who is placing thepublic at risk of harm.

Page 2 of 5

Ministers agreed that reportable conduct will include conduct that places the public at

substantial risk of harm either through a physical or mental impairment affecting practice

or a departure from accepted professional standards. Practitioners who are practisingwhile under the influence of drugs or alcohol, or have engaged in sexual misconductduring practice must also be reported.

This requirement will deliver a greater level of protection to the Australian public.

Criminal historv and identitv checksNational agreement was reached on 5 March 2009 on criminal history and identitychecks to apply to registered health professionals.

Mandatory criminal history and identity checks will apply to all health professionalsregistering for the first time in Australia. All other registrants will be required to make an

annual declaration on criminal history matters when they renew their registration and

these declarations will be audited on a random basis by an independent source.

Ministers also agreed that national boards will have the power to conduct ad hoccriminal history and identity checks on registrants.

Simplified complaints arranqements for the public

Assistance will be provided to members of the public who need help to make acomplaint. Ministers agreed that this new arrangement will not affect the servicesprovided by health complaints commissions across the country. However it will helpmake the complaints process simpler for members of the public.

Student reqistrationThe Ministerial Council agreed that national boards will be required to register studentsin the health professions. Boards will decide at what point during their programs ofstudy students will be registered, depending on the level of risk to the public.

Ministers agreed the national scheme will enable national boards to act on studentimpairment matters or where there is a conviction of a serious nature which may impacton public safety. This requirement will come into effect at the beginning of 2011.

Students will be registered by a deeming process based on lists of students supplied toboards by education providers

Handlinq of complaintsGiven the diversity of arrangements in Australia at this time, Ministers have agreed to aflexible model for the administrative arrangements for handling complaints.

The National Law and/or State or Territory law, depending on each jurisdiction's choice,

will provide the legislative framework for investigations and prosecutions and thedefinitions of offences and contraventions and outcomes will be recorded as part of asingle national framework.

Where the national legislative framework is adopted, it will also be up to each State and

Territory to decide whether the prosecution and investigation functions remain with thenational boards or be undertaken by an existing State or Territory health complaintsarrangement.

Page 3 of 5

The Ministerial Council also agreed a number of other elements related to the effectivefunctioning of the new scheme.

Appointments to national boards

Ministers confirmed the arrangements set out in the Health Practitioner Regulation(Administrative Arrangements) National Law Act 2008 (the Act), that boards will beappointed by the Ministerial Councilwith vacancies to be advertised. At least half, butnot more than two thirds, of the members must be practitioners and at least two must bepersons appointed as community members.

Adding to the Act, Ministers have also agreed that the National Law will require allnational boards to contain at least one practitioner member from each of the largerjurisdictions (Queensland, New South Wales, Victoria, South Australia andWestern Australia) and at least one other practitioner member drawn from the threesmaller States and Territories (Tasmania, the Australian Capital Territory or theNorthern Territory). Members of existing boards and State and Territory boards underthe national scheme (see below) will be eligible for appointment to national boards.Members of the Agency Management Committee may not hold an appointment to anational board.

Ministers have also agreed that each national board will have at least one member froma rural or regional area.

State and Territory boards (previously "State and Territory committees")

Ministers agreed that the main committee of a national board in each State or Territorywhere a committee is appointed will be known as a State or Territory board, for examplethe South Australian Board of the Pharmacy Board of Australia. Each national boardwill need to determine where State or Territory boards will be appointed, taking intoaccount the need to provide efficient processes in each profession.

The role of these State and Territory boards will be to oversee registration andcomplaints processes in that State or Territory where these functions are delegated tothem by the national board. State and Territory boards will perform these functionsunder the national legislation for the scheme. Appointments to State boards will bemade by State Ministers following an open and transparent process.

Ministers also agreed that from 1 July 2010 (and subject to the decision of a nationalboard that there will be a State or Territory board of that national board located in ajurisdiction), members of the existing board in that jurisdiction will comprise that State orTerritory board for the balance of the terms of their appointment.

New national regulation of cosmetic lenses

To protect the public from injuries arising from the misuse of cosmetic contact lenses,the Ministerial Council has agreed that the prescribing of cosmetic lenses will berestricted to optometrists and medical practitioners. These are the same restrictionsthat will apply to the supply of other contact lenses under the new scheme.

Page 4 of 5

Area of need arrangements

The Ministerial Council agreed that national boards will be required to considerapplications for registration from practitioners seeking to work in a location or positionthat has been declared by the relevant State or Territory Minister as an area of need.Boards will determine whether the practitioner is eligible for registration and, ifregistration is granted, what conditions will apply

Privacy protections for practitioners and consumers

Ministers agreed to build on the Commonwealth's leadership and adopt under thenational scheme the Commonwealth National Privacy Principles and privacy regime (or

its successor). This will provide practitioners and consumers with the protection neededin relation to information collected by the national boards and the national agency.

Location of national office

Ministers agreed that the national office of the new Australian Health PractitionerRegulation Agency will be located in Melbourne.

Next steps

Ministers agreed that these decisions should be included in the exposure draft of theHeatth Practitioner Regulation National Law Bill2009, which will provide the legalframework for the national scheme. The exposure draft of the legislation will bereleased by the Ministerial Council later in 2009 for a further round of publicconsultations.

When comments have been received on the exposure draft, the Ministerial Councilwilldetermine the final form the legislation should take.

Melbourne8 May 2009

Page 5 of 5

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Reviews of accreditation arrangements

1. lntroduction

This report describes and evaluates the reviews of accreditation arrangements for the first ten professions

to be regulated under the Health Practitioner Regulation National Law Act as in force in each state andterritory (the National Law).

Gontext

Section 253 of the National Law requires National Boards to review the arrangements for the exercise ofthe accreditation functions no later than 30 June 2013. These arrangements were generally establishedbefore the commencement of the National Law and involve the appointment of an external AccreditationAuthority for each of the first ten professions to join the National Registration and Accreditation Scheme(the Scheme). When Health Ministers appointed the first of the Accreditation Authorities, they indicatedthat the assignment of accreditation functions would be 'subject to the requirement to meet standards andcriteria set by the national agency for the establishment, governance and operation of externalaccreditation bodies'.

Boards and Authorities collectively have worked to develop a common understanding of the Scheme andhow it operates. The relationships between boards, authorities and AHPRA have evolved and maturedduring the period of assignment. Each of the profession-specific Boards and Authorities have developedtheir own arrangements for communication, including meetings, reporting etc. Within the commonframework and shared understanding agreed by all Boards and Authorities, they have also eachdeveloped specific reporting and operating processes that reflect the complexity, volume and nature of theparticu lar accreditation business.

Accreditation functions after the reviews

Although Ministers initially appointed the Accreditation Authorities, the National Law provides that Boardsmust make subsequent decisions about how accreditation functions are to be exercised:

. the National Board..... must decide whether an accreditation function for the health profession forwhich the Board is established is to be exercised by (a) an external accreditation entity; or (b) acommittee established by the Board (s43), and

. the National Board must ensure the process for the review includes wide-ranging consultationabout the arrangements for the exercise of the accreditation functions (S253 (5)).

Accordingly, the reviews considered both how the accreditation arrangements had been operating andwhat arrangements should continue from I July 2013.

2. How the review process was developed

The review process was developed by the Accreditation Liaison Group (ALG) in consultation with NationalBoards and Accreditation Authorities. The ALG is a joint body of the National Boards, the HealthProfessions Accreditation Councils' Forum (the Forum) and AHPRA, with members from each group. The

ALG provides an opportunity for collaborative work on matters related to the accreditation functions under

the National Law.

Australian Health Practitioner Regulation AgencyG P O Box 9958 | Melbourne VIC 300'1 | www ahpra gov au

When the ALG started to develop a proposed review process, it carefully considered the wording of s.

253. The ALG's interpretation was that s. 253 conveys a focus on the existing arrangements and whetherthey should continue, rather than starling from a "blank page".

Accordingly, given the arrangements already in place, the ALG considered that the review process shouldbegin with an assessment of the way in which the Accreditation Authority appointed for each profession

had performed the accreditation functions. The ALG was aware that the process would also need to takeaccount of the differences in size of the health professions, the volume of accreditation activity and therange of accreditation functions undertaken by the accreditation entities.

The proposed review process developed by the ALG was agreed by National Boards and AccreditationAuthorities.

3. Overview of the review process

The scope of the review was defined by the objectives of the National Law, in particular those objectivesmost relevant to the accreditation functions, as well as the elements of the Quality Framework, which is

essentially an agreed list of aspirational principles for the accreditation work of the AccreditationAuthorities, previously developed and agreed by the National Boards and the Accreditation Authorities.

Principles

The key principles of the review process included:

. an agreed and transparent process for the revlew

. an appropriate focus on the current accreditation arrangements

. an agreed cross-profession framework with the capacity to take differences between theprofessions into account

. weighing of relative risks, benefits and costso evaluation of the suitability of the process for future reviews required under the National Law.

The principles which informed the development of the Quality Framework for the Accreditation Function(the Quality Framework) also applied.

The review process drew on the information already accumulated about how the accreditationarrangements are working for each profession and provided the Accreditation Authority and the National

Board an opportunity for open dialogue as part of the revtew.

Key questions for the review

The review considered the following key questions:

1. What accreditation functions has the Accreditation Authority undertaken under the National Law?2. How well has the Accreditation Authority undertaken each of these functions under the eight domains

of the Quality Framework since it was appointed?3. Taking in to account the context for the profession and the complexity of registration and accreditation

arrangements for the profession, how has the Accreditation Authority addressed its responsibilitiesunder the National Law (or - aligned its delivery of accreditation functions with the National Law)?

4. Has the Accreditation Authority demonstrated that it is effectively undertaking the accreditationfunctions and that it is likely to continue to do so? Are the current arrangements satisfactory?

5. Considering the costs, risks and benefits, on balance, is continuing with the current arrangements forexercising the accreditation functions or changing the arrangements appropriate?

6. ls there a clear justification for any proposed changes to the current arrangements for exercising theaccreditation functions?

Review of accreditation arrangements/July 201 3Page 2 oI 14

Outline of the review process

Key steps in the review process were:

1. accreditation authority made a submission to the Board, if it wished to continue exercising theaccreditation functions

2. Board assessed the submission and made a decision about its proposed direction3. wide-ranging consultation4. Board made final decision

A full description of the steps in the review process is in Attachment One.

Submission from accreditation authority

The reviews started with the Board writing to its accreditation authority, inviting it to make a submission if it

wished to continue exercising accreditation functions. The submission was intended to build on existinginformation where appropriate and to take into account the way the Authority had discharged theaccreditation functions since its first period of assignment commenced. Each accreditation authorityprepared a detailed submission explaining their roles and functions. The submission also specificallyaddressed the Quality Framework and the progress made by the Authority in moving toward alignmentwith the Framework.

After the Accreditation Authority made its submission to the National Board, representatives of the Board

and Accreditation Authority met to discuss the submission and any other issues relevant to the review.

Assessment of submission and decision about proposed direction

The National Board then considered the submission and discussions with the Accreditation Authorityagainst the key questions for the review to make a preliminary decision about whether the currentarrangements for the exercise of the accreditation functions were satisfactory and therefore should becontinued. The National Board's proposed direction (eg to continue the current arrangements) formed thebasis of consultation, but allowed stakeholders to express their views about the direction including anyalternative options for exercising the accreditation functions.

Wide ranging consultation

The Boards included "wide-ranging consultation about the arrangements for the exercise of theaccreditation functions" (s. 253 (5)) as part of this review process. (See the next section for moreinformation about the consultation process)

National Board makes final decision

The National Board provided the Accreditation Authority with an opportunity to discuss any issues from thestakeholder feedback. The National Board reviewed the feedback from the consultation process and anyfurther information provided by the Accreditation Authority against the key review questions to make its

final decision about the review outcome. The National Board communicated the review outcome and

reasons for its decision to its Accreditation Authority. lt then publicly announced the decision.

Review timing

While the review did not need to be completed until 30 June 2013, the aim was to complete the reviewearlier to allow certainty for National Boards and for Accreditation Authorities wishing to continueexercising these functions. lt would also allow a transition to any new arrangements, should they be

necessary. For this reason, the review process started in August 2012,with the aim of completing thereviews by the end of 2012, while recognising that some reviews may be more complex and take longer tocomplete.

Review of accreditation arrangements/July 201 3Page 3 of 14

4. Consultation process and submissions

Each board conducted preliminary and public consultation, using a profession-specific consultation paper

which drew on a template consultation paper and the submission made by the Accreditation Authority.

The consultation paper:

1. explained the history of the assignment and the requirement for the review of the accreditationarrangements

2. explained the options open to the National Board, its preliminary conclusion about whether the currentarrangements are satisfactory and the proposed direction based on a preliminary review of the current

arrangements, including an analysis of the risks, benefits and costs3. attached the public part of the submission from the Accreditation Authority4. linked the Reference Document - Accreditation Under the Health Practitioner National Law Acf and

included a diagram of the respective roles of the National Board, Accreditation Authority and AHPRA

5. invited comments on the accreditation functions and the domains of the Quality Framework andprovided an opportunity for any other comments.

Boards consulted according to the published National Boards Consultation Process( ) Each Board Publishedits public consultation paper on its website inviting feedback. lt also alerted its key stakeholders to the

consultation process. The Boards also invited the Accreditation Authorities to suggest any additionalstakeholders to be directly approached by the Boards to participate in the review. ln some cases the

Accreditation Authority also encouraged its stakeholders to participate in the consultation process.

Submissions

Boards received 92 submissions during the public consultation process across all ten professions. A

breakdown of the submissions is at Attachment 2.

Each Board has published the submissions from the public consultation process on its website, exceptwhere stakeholders requested non-publication. The submissions are accessible from links on the AHPRAor each Board website egSeptember-2012.aspx . All submissions were made available to the accreditation authority.

Health Workforce Australia and the Health Workforce Principal Committee also made confidentialsubmissions to the reviews.

5. Review outcomes

All Boards have decided that their accreditation authority will continue to exercise accreditation functions,

with some variations in the continuation period:

. seven boards decided on a five year period

. one board decided on a three year period with a possible two year extension

. one board decided on a three year period

. one board decided on a one year period but is prepared to consider a longer period subject to somegovernance issues being addressed

6. lmplementing the review outcomes

The review outcomes were implemented through:

1. the National Board advising the accreditation authority of its decision2. the National Board announcing its decision3. extending the existing agreements for the exercise of accreditation functions to cover the new period

from I July 2013, recognising the context of health reform issues and opportunities for collaboration4. each National Board establishing a workplan with its Accreditation Authority which includes issues

from the review process and a timeframe for future work.

80% of the reviews were completed within the target timeframe (by the end of 2012). The extension ofnine of the ten existing agreements was completed by late June 2013.


As was previously the case, the accreditation arrangements are subject to the reporting requirements in

1. the agreement between AHPRA on behalf of the National Board and the Accreditation Authority2. the sample guide report, which provides guidance about the content for regular reports under the

agreement, and3. the annual workplan and funding arrangements

7. Assessing the review against the objectives

The following table analyses the review against the key principles:

Principle Evaluation of review

The ALG developed a proposed review process which wasclearly documented. National boards and accreditationauthorities agreed on the proposed review process.

The preliminary and public consultation papers included adescription of the review process. The submissions topublic consultation were published and each Boardpublicly communicated the outcome of the review process.

An agreed and transparent processfor the review

The review focused on the current accreditationarrangements, but enabled any recommendations forchanges to the existing arrangements to be raised,including proposals from any organisation who wished tobe considered as an alternative to the accreditationauthorities appointed by Ministers (none were received).

An appropriate focus on the currentaccreditation arrangements

The review process and template consultation paperprovided an agreed cross-profession framework with thecapacity to take differences between professions intoaccount. There was also enough flexibility in the process toenable adjustment for profession-specific issues. Thisresulted in two boards completing their review to a longertimeframe than the other eight boards.

An agreed cross-professionframework as outlined in this paperwith the capacity to take differencesbetween the professions intoaccount

Weighing of relative risks, benefitsand costs

Boards made their decisions according to the keyquestions for the review, which required a weighing ofrelative risks, benefits and costs

This report specifically considers the suitability of thereview process for future reviews required under theNational Law.

Evaluation of the suitability of theprocess for future reviews requiredunder the National Law.

8. Suitability of the process for future reviews required under the National Law

Many aspects of the review process would be suitable for future multi-profession reviews required underthe National Law, including:

. collaborative planning and implementation

. an agreed process between the National Boards and Accreditation Authorities

. coordinating processes and timeframes across professions to assist stakeholders of multipleprofessions.


9. Opportunities for improvemenU lessons learnt

Key learnings from the review include:

1. Detailed planning and coordination of the review process was important. The review aimed tocoordinate the review process for stakeholders of multiple National Boards such as governments.

This included providing a multi-profession submission template for these stakeholders to use.

2. The ALG's design, oversight and leadership role was an important element in achieving agreementabout the review process and 80% of the reviews being completed within the target timeframe.

3. lt was important for National Boards, Accreditation Authorities and AHPRA to have a sharedunderstanding about the process and timeframes. An agreed, clearly documented review process

helped participants and stakeholders all understand the process, and enabled effective coordination.

4. The submissions from the Accreditation Authorities were very large documents, up to 20 mb. Thispresented challenges in the preliminary consultation phase, as the documents could not be emailed.Drop-box style web access was used but some stakeholders had difficulties using the site and wereprovided with the submissions on a usb stick. There is an opportunity to make this process more

user-friendly and simpler in future.

10. Conclusion

The reviews of accreditation arrangements were completed by 30 June 2013 as required by the NationalLaw, although implementation of the reviews is continuing into 2013. The review processes highlighted

how much has been achieved in implementing the accreditation component of the National Registration

and Accreditation Scheme. The review also provided useful opportunities for National Boards andAccreditation Authorities to consider key issues that will be important factors for the future of accreditation

within the National Registration and Accreditation Scheme.


Attachment One Outline of Review Process

1. Boards/AHPRA wrote to Accreditation Authority asking whether Accreditation Authority wishes tocontinue undertaking the accreditation functions and if so, to send a submission to Board

2. The Accreditation Authority provided a submission to the Board advising that it wished to continueexercising the accreditation functions

3. Representatives of the Board and Accreditation Authority met to discuss any key issues arising from

the submission4. National Board formed preliminary view about whether the current arrangement is satisfactory and

approves consultation paper for preliminary consultation

5. National Board advised Accreditation Authority of its preliminary view

6. Preliminary consultation with key stakeholders7. National Board considered outcome of preliminary consultation and advised accreditation authority of

any change in approach from preliminary consultation

L National Board approved consultation paper for public consultation

9. Public consultation on the preliminary view on whether or not the arrangements appeared to be

satisfactory10. National Board provided the Accreditation Authority with an opportunity to discuss any issues from the

stakeholder feedback1 1. National Board made final decision, communicated the decision and its reasons to the Accreditation

Authority and then announced the decision'12. lmplementation


Attachment two Submissions received in public consultation

Attachment two has been removed from this public consultation version of the paper

because it lists submissions that organisations and individuals identified asconfidential. Submissions received in public consultation that were not identified asconfidential are published on the National Boards' websites that can be accessed via

www.ahpra.gov.au

Attachment C

Summary of accreditation functions and roles

The Accreditation Authority for each health profession is listed in the table below with informationabout the accreditation functions they perform. lnformation about the accreditation process is also

available on the website of each external authority and Accreditation Committee.


This table lists the Accreditation Authorities that exercise accreditation functions under the NationalLaw and work with the National Boards.

Functions undertaken under theNational Law

National Board Accreditation Authority

Development and review ofaccreditation standards

Assessing programs of study andeducation providers against thestandards, including monitoringaccredited programs and providers

Providing advice to National Board onaccreditation functions

Aboriqinal and To s Strait lslanderHealth Pra AccreclitationCommittee

AboriginalandTorres Straitlslander HealthPractice Board ofAustralia

Development and review ofaccred itation standards



Chinese Med AccreditationCommittee

Chinese MedicineBoard of Australia



Assessing overseas assessingauthorities

Assessing overseas qualifiedpractitioners


Council on Chiropractic EducationAustralasia lnc.

http://www.ccea.com.aul

Chiropractic Boardof Australia







Providing advice to National Board onaccred itation functions

Australian Dental Council

http://www.adc.org.au/

Dental Board ofAustralia






Australian Medical Council Limited

http://www.amc.org.aul

Medical Board ofAustralia




Medical Radiation PracticeAccreditation Committee

Medical RadiationPractice Board ofAustralia

Development and review ofaccred itation standards



Assessing overseas qualifiedpractitioners (National Board is alsoundertaking this function)


Nursing andMidwifery Board ofAustralia

Australian Nursing & MidwiferyAccreditation Council

http://www.an mc.org.aul

2







OccupationalTherapy Board ofAustralia

Occupational Therapy Council(Australia & New Zealand) Ltd

http://otcouncil.com.au/






Optometry Council of Australia andNew Zealand

http://www.o canz.orgl

Optometry Board ofAustralia






Osteopathy Board ofAustralia

Australian and New ZealandOsteopathic Council

http ://www. a nzoc.or g.aul

3


Accreditation AuthorityNational Board






Pharmacy Board ofAustralia

Australian Pharmacy Council Ltd

http://pharmacycou ncil.org.au





Providing advice to National Board onaccreditation fu nctions

Australian Physiotherapy Council

http://www.physiocou ncil.com.au/

Physiotherapy Boardof Australia






Australian and New ZealandPodiatry Accreditation Council

http ://www. a n zpac. org. au/

Podiatry Board ofAustralia

4


Accreditation AuthorityNational Board





Psychology Board ofAustralia

Australian Psychology AccreditationCouncil Limited

http://www.psychologycouncil.org.aul

More information about accreditation under the National Law

A reference document Accreditatíon underthe National Law has been developed by AccreditationAuthorities, National Boards and the Australian Health Practitioner Regulation Agency (AHPRA)toprovide information about accreditation under The Health Practitioner Regulation National Law Act asin force in each state and territory (the National Law).

5

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