Australian Medical Association

The AMA Joint submission highlights the real risk that the new scheme will erode the medical board’s ability to protect patient safety, and addresses four major concerns with the proposed registration arrangements:

1. There is no recognition or guarantee of the continued role of medical colleges in determining specialist qualifications for, and conferring them on, medical practitioners;
2. The scope of practice for the other health professions will be able to be expanded without any obligation for one health profession board to consult with other boards, particularly the medical profession board;
3. The scheme seeks to introduce new onerous continuing competence/CPD requirements, which will effectively create a new scheme for the medical profession, and does not recognise the role of the colleges in continuing competence and professional development for the medical profession;
4. The medical board will be able to register a person who does not meet the requirements for registration in certain circumstances.

The AMA responded to an invitation from the Australian Register of Naturopaths and Herbalists to comment on the development of practice, registration and accreditation standards for naturopathy and western herbal medicine in Australia. The AMA advised that it could not provide comments until the proposals had legal standing and a board for naturopaths and herbal medicine practitioners is established under the Health Practitioner Regulation National Law Act 2009.

The AMA has made a submission to the Optometry Board of Australia in response to a proposal that all optometrists applying for general registration should be required to meet additional therapeutics qualifications. The AMA's view is that registration standards for all prescribers should be equal to those required for the medical profession.

The AMA has made a submission to the Podiatry Board of Australia's consultation process on proposed revisions to their prescribing standards for podiatrists.  This submission, which is consistent with previous AMA submissions on this issue to the Podiatry Board, highlights the deficiencies in the Guidelines with respect to course content and accreditation, shared care arrangements and expansion of the national drugs list.

The AMA has lobbied very strongly to secure a number of important changes to the scheme.  The AMA's concerns about elements of the scheme that have been addressed by government and incorporated into the scheme are set out below:

The AMA has also made a Joint Submission on the exposure draft to the Project Implementation Team.

This submission notes that the Ministerial Council has forfeited the power to approve accreditation standards, but has retained a power to give the national board policy directions on accreditation standards. The submission calls for additional provisions to be added to the legislation that:

• Defines the circumstances when the Ministerial Council can issue policy directions on accreditation standards; and
• Provides mechanisms for transparency and accountability of these directions.

The submission also outlines a range of other important functional operational and administrative issues with the scheme that need to be clarified and reflected, where necessary, in revisions to the Bill.

The AMA Submission to the Senate Community Affairs Committee inquiry into the national registration and accreditation scheme encapuslates the major concerns set out in our previous submissions to government on the proposed scheme.  The submission also sets out the AMA's proposal for a simple, cost effective alternative arrangement for a national system for medical practitioner registration that:

1. maintains the nationally consistent accreditation of medical education and training through an independent medical accreditation body with specific medical expertise;
2. implements mutual recognition of registration arrangements for medical practitioners across all states and create a ‘virtual’ national register; and
3. establishes a formal process for ongoing harmonisation of registration standards.

Message to members and non members on the proposed National Registration and Accreditation scheme

The AMA Joint Submission on the proposed arrangements for specialists highlights concerns that the proposed scheme will be a vehicle for governments to respond to workforce challenges by:

• permitting people to be registered as medical practitioners even though they do not meet the requirements for general medical registration; and
• allowing other health providers to inappropriately undertake competencies beyond their training and scope of practice.

Further, there is no guarantee the proposed scheme will incorporate the the role of medical colleges in:

• determining specialist qualifications for, and conferring them on, medical practitioners;
• continuing professional development for the medical profession; and
• assessment of overseas medical graduates who are applying for Australian specialist qualifications.