In the Council of Australian Government (COAG) communiqué of April 2007, it was agreed to establish a single consolidated scheme with a national body overseeing both the registration of health practitioners and accreditation of health professionals' education and training. There has been concern since that time about including accreditation under the scheme as it potentially threatens the independence of the bodies that set the standards for education and training in the professions, leaving the way open to government influence. This article reviews the current arrangements for accreditation of psychology education and training programs, presents the key features of the proposed new system, and discusses the concerns regarding the proposed accreditation arrangements for psychology education and training under the new scheme.
Until 2003, the APS had been the accrediting body for university psychology education and training programs in Australia for approximately 30 years. In 2003, a Memorandum of Understanding was formed between the organisation representing the various State and Territory Registration Boards (the Council of Psychologists Registration Boards [CPRB]) and the APS, which paved the way for forming a partnership which produced a new body, the Australian Psychology Accreditation Council (APAC). Since that time, APAC has been responsible for accrediting programs of education and training in psychology in Australia for the purpose of registration as a psychologist and for membership of the APS. APAC was established to achieve two major goals - firstly, to ensure that a single standard applies across Australia for the education and training of psychologists seeking registration under various State/Territory regulations, and secondly, so that universities only have to apply for accreditation with one body to ensure that their graduates can achieve both membership of the APS and State registration. APAC comprises four directors from each of the CPRB and the APS, one director representing consumer and carer interests, and two observers from the Heads of Departments and Schools of Psychology Association (HODSPA).
There is currently a high demand for education and training in psychology and 38 universities across Australia offer APAC-accredited undergraduate and postgraduate courses. Accreditation of each institution's programs is a huge undertaking that takes place on a five-year cycle. Courses are accredited by assessors from the APS Program Development and Accreditation Committee (PDAC) on behalf of APAC, using a set of standards developed by APAC.
In November 2008, the Health Ministers' Advisory Council issued a consultation paper on the proposed arrangements for accreditation under the national registration and accreditation scheme for the health professions. The paper sought comment on the regulatory framework and tools proposed to deal with accreditation, as outlined below.
The stated purpose of accreditation of education and training courses under the scheme is to ensure that graduates have the required skills, knowledge and competence to practise safely and meet registration requirements. The accreditation function of the scheme will consist of the following four activities:
The Ministerial Council will be responsible for assigning accreditation functions to suitable existing external accreditation agencies, initially for a period of three years from 1 July 2010. The accreditation body for each profession must meet criteria for the establishment, governance and operation of external accreditation bodies within the first 12 months of the new scheme. Following development of the accreditation standards for a profession, the accreditation body will submit the standards to the relevant National Board for consideration. If the National Board is satisfied that the standards will enable a training course to be developed that will satisfactorily prepare a student for registration as a practitioner, the standards will be submitted to the Ministerial Council for approval.
The passing of the first stage of legislation for the national scheme (Bill A) enabled the Ministerial Council to make decisions on assigning accreditation functions to suitable existing accreditation bodies. The APS advocated strongly for APAC to be given the accreditation function for the psychology profession under the new scheme, and it was announced in December 2008 that APAC had been selected to fulfil this function for the triennium commencing in July 2010.
In preparation for undertaking this role under the new scheme, APAC has made some changes to ensure that it can withstand close scrutiny under the new arrangements and maintain the accreditation function for the psychology discipline and profession. It has reviewed its governance arrangements and provided for community representation on its Board. APAC is also undertaking a major revision of its accreditation standards to ensure that they include expected attributes for graduates of psychology courses rather than only focusing on educational inputs, and that they take into account advances in the way education is delivered.
The APS provided a formal submission to the consultation paper on the proposed accreditation arrangements, outlining the concerns identified by the psychology profession which are summarised below.
The proposed structure for the accreditation process under the new scheme provides the potential for government interference in standards for the training of psychologists. Under the proposed arrangements, the National Agency will have the power to issue policy directions for accreditation standards and the Ministerial Council will have final approval of the standards that are developed. While government is a key stakeholder in the accreditation of psychology education and training programs, accreditation processes, and in particular the setting of accreditation standards, must be independent of political concerns such as workforce issues and cost savings. The lack of clarity in the role and powers of the Ministerial Council and the National Agency leaves open the possibility that, over time, they will begin to exert pressure on standards as a means to achieving certain workforce imperatives. The public must be protected from such an erosion of standards by explicitly excluding the National Agency from any role in accreditation matters and specifically limit the powers of the Ministerial Council. The National profession-specific Board, in conjunction with the accrediting body, should be able to independently set standards and accredit education and training programs against them without the potential for government control or political interference.
The proposed structure - which specifically combines registration and accreditation functions under one scheme - provides the potential for accreditation functions to be extended to incorporate aspects of registration. Currently, the accrediting body is only responsible for accrediting university undergraduate and postgraduate psychology programs. However, with a more direct link to registration functions through the combined scheme, the accreditation function could potentially be extended to workplace arrangements to achieve registration for provisionally registered psychologists, accreditation of supervisors, or even the accreditation of psychologists' private practices. Again, the lack of independence of the accrediting body may allow it to become a vehicle for political interference in the way the psychology profession conducts its affairs.
It is anticipated that the new national registration and accreditation scheme will be self-funded, that is, the scheme will be funded from fees received from registration functions and accreditation functions. The costs of the current accreditation process are met through fees from universities seeking accreditation, as well as through substantial financial contributions from the APS and the CPRB. Under the proposed new arrangements, the self-funded nature of the registration and accreditation scheme is likely to impose a significant burden on registrants and universities seeking accreditation. If there is an expanded role for the accrediting body, this will result in even greater costs associated with the scheme. It is possible that other ways of recouping costs will be sought, such as a fee on entry to the profession. The APS is vehemently opposed to any substantial increase in fees for practising psychologists and fees paid by universities requiring accreditation of their courses, and believes the Australian Government should commit to recurrent funding of the national scheme to meet a substantial proportion of its operating costs.
The other health professions who are subject to the new national registration and accreditation scheme have expressed similar serious concerns to those outlined above regarding the proposed accreditation arrangements. It is hoped that the submissions from all relevant professional bodies will be carefully considered in finalising the draft legislation governing the scheme. There will be further opportunity for consultation on accreditation aspects of the new scheme when the draft legislation is released in March/April 2009.
Major concerns about proposed accreditation arrangements under the national scheme