The announcement in December 2008 that the Australian Psychology Accreditation Council (APAC) had been assigned the accreditation functions of the new national registration and accreditation scheme until 2013 is very good news for the discipline and profession of psychology in Australia. The vote of confidence in APAC reflects its successful track record as the independent national accrediting authority for the psychology profession since 2003. The introduction of the new scheme will require APAC to meet a range of new requirements, including an expanded Board, but of particular concern are changes which will have significant implications for APAC's independence.
Since its establishment, APAC has represented the interests of both the regulators (Registration Boards) and the profession in undertaking its accreditation function. Following the introduction of the scheme, however, the new National Psychology Board becomes responsible for the development of psychology accreditation standards, and will direct APAC as to how to develop and monitor accreditation standards for the first three years of the scheme, with one important caveat. Accreditation standards set by the National Board and implemented by APAC must be presented to the Ministerial Council for approval, which has the power to reject them but crucially cannot direct the National Board as to how rejected standards must be changed. In a scheme where the Ministerial Council has the ability to veto proposed changes to standards in education, the accrediting body's power to stimulate change and reform in education programs is limited, with the potential risk that Australia's programs of psychologist training and education may fall even further behind international benchmarks, such as the higher standards of training in the UK, USA and New Zealand. The scheme does not provide for any mechanism which would address the situation of a stalemate which could arise when a National Board recommends endorsement of an accreditation standard and the Ministerial Council refuses to approve it, and while the feedback from the current Government is that it has no intention of interfering in accreditation standards, the fact remains that future governments may well choose to do so. Therefore, a system in which such a stalemate is possible - without a mechanism for breaking it - risks condemning the discipline to the status quo while standards in the profession elsewhere in the world move even further ahead of Australia. At the very least, the scheme should create a path for resolution, and one possibility could be to allow such a stalemate to be resolved by the Ombudsman under the Commonwealth Ombudsman's Act 1976.
APAC, along with the accrediting bodies of the other nine professions in the scheme, has argued strenuously that the scheme in its present form undermines the independence of accreditation, and that although government has a legitimate interest in the system of accreditation of health professionals' education and training, it is crucially important that the development and implementation of accreditation standards is not driven by matters of cost, workforce needs or other political motives, which will be key considerations of the Ministerial Council. The arrangement currently proposed leaves open the possibility that issues such as workforce registration considerations could drive accreditation decisions, making standards and quality a secondary consideration.
It is precisely because of these concerns that policy making bodies around the world uphold the independence of accreditation bodies and their work from government. The European Consortium for Accreditation in Higher Education (ECA), founded by twelve higher education accreditation organisations from eight European countries, states as a principle that "Accreditation organisations must be independent from government" (Accreditation in the European Higher Education Area, 2004, p.7). Independence of the accrediting body is also required in the influential World Health Organisation/World Federation of Medical Education Guidelines for Accreditation of Basic Medical Education (2005), which states that "The legal framework must secure the autonomy of the accreditation system and ensure the independence of its quality assessment from government" (p.4). Within the psychology discpline, the American Psychological Association's Guidelines and Principles for Accreditation of Programs in Professional Psychology (2008) define accreditation as "a voluntary, non-governmental process of self-study and external review" (p. 5).
In order to protect the public from a lowering of standards in the education and training of psychologists, the national scheme legislation must allow the accrediting body and the National Psychology Board to set and maintain standards independently of government.
Consortium for Accreditation in Higher Education. (2004). Accreditation in the European Higher Education Area. Document accessed on 20/10/08 from www.aic.lv/ace/ace_disk/Bologna/contrib/Statem_oth/ECA_on_Bergen.pdf.
World Health Organisation. (2005). WHO/WFME Guidelines for Accreditation of Basic Medical Education, Geneva/Copenhagen.
American Psychological Association. (2008). Guidelines and Principles for Accreditation of Programs in Professional Psychology. APA Office of Program Consultation and Accreditation, Washington, DC.