Assisting members to meet the new CPD requirements
Professor Lyn Littlefield OAM FAPS
From 1 July this year, the Psychology Board of Australia (PBA) introduced new mandatory continuing professional development (CPD) requirements, which are a necessary condition of maintenance of registration as a psychologist under the new national registration scheme. All CPD requirements must be completed within an annual cycle.
The first cycle commenced on 1 July 2010 and will finish on 30 November 2011. Thereafter, annual cycles will run from 1 December to 30 November.
The consequences of non-compliance with the PBA's CPD requirements are severe and apply for the current first annual cycle of national registration (see relevant heading later in this article for more details). All aspects of the CPD requirements (learning plan, activities across various categories of CPD, and journal entry for each hour of CPD activity) must be fully met in order to be deemed compliant.
The APS is very aware of the complexities that have surrounded transition to the new national registration system across a range of areas, and has been working tirelessly to support its members through advocacy with the PBA, provision of advice, and the introduction of a number of practical measures. To assist members to meet the complexities of the new CPD requirements, the APS Board has decided to:
- Align the existing APS CPD requirements with the new PBA requirements to save members additional complexities in meeting the requirements of two different systems
- Redesign the APS CPD online logging system to aid compliance through a streamlined program that enables online documentation and self-monitoring of all required CPD components.
The PBA has made some minor adjustments in response to identified anomalies but has not been willing to negotiate any substantial changes to the CPD requirements. APS efforts are therefore now focused on assisting members to meet the new requirements through provision of clear information and through the design of the new online logging system.
Alignment of APS CPD requirements with PBA requirements
For the reasons outlined above, the APS CPD requirements for continuing membership have been made identical to the PBA requirements over annual cycles, with only one minor difference between the two sets of requirements which is only applicable to a very small number of APS members who belong to three or more Colleges.
The revised APS CPD arrangements will therefore enable members to be confident that if they meet these requirements (with the assistance of the online logging tool) they will also fulfil the PBA's mandatory CPD requirements.
The APS Board has determined that the new CPD requirements will apply to all APS members including academics and other members who may not be working as registered psychologists. Certain exemptions to meeting CPD requirements, for example, for members who have retired from practise, are outlined under the relevant heading later in the article.
Redesign of the APS CPD online logging system
The APS experience in introducing new CPD requirements in the past is that compliance was greatly aided by the online logging system, which was used by over 80 per cent of members in the last CPD cycle.
There has been some delay in finalising the reprogrammed CPD logging system while negotiation with the PBA has taken place and testing has been undertaken to ensure there will not be problems when the system goes live at the beginning of next year.
The APS believes the logging tool will be a significant member benefit to assist in meeting the new PBA requirements.
Summary of the CPD requirements for each annual cycle
First annual cycle commenced on 1 July 2010 and concludes on 30 November 2011.
A. All psychologists must meet three components each annual cycle in order to comply with the PBA and APS requirements
- Individual learning plan – sets and reviews learning goals to guide selected CPD activities
- 30 hours of CPD activities – base minimum with required types
- Minimum 10 hours of peer consultation – consultation or supervision in a group or individual format
- Minimum 10 hours of active CPD – recommended only, but will become mandatory in a subsequent annual cycle
- Journal entry for each hour of CPD – must demonstrate how CPD activity has contributed to learning goals
B. Specific requirements for psychologists with PBA area of practice endorsement(s) and/or APS College membership(s)
- One endorsement/College – 16 hours of the 30 CPD hours must be allocated to the relevant specialist area
- Two endorsements/Colleges – the 30 CPD hours must be spread equally across the two specialist areas (15 hours each)
- Three or more endorsements/Colleges
- Maintenance of each PBA endorsement – the 30 hours of CPD must be spread equally across the specialist areas
- Maintenance of each APS College membership – 15 hours of CPD across each specialty area must be undertaken
C. Specific requirements for psychologists providing ‘Focused Psychological Strategies (FPS)’ Medicare items under the Better Access initiative
- 10 hours of the 30 CPD hours must be FPS-related learning activities
Understanding the new CPD requirements
Individual learning plan for each annual cycle
- An individual learning plan must be developed for each annual CPD cycle based on a self assessment of skills and knowledge.
- The learning plan should identify learning goals (areas for development or improvement) relevant to the psychologist’s individual work context, the types of activities proposed to meet these goals, and the anticipated outcomes.
- The CPD activities selected should seek to enhance competence and contribute to the quality of the psychologist’s work in the particular area of professional practice.
- The success of the learning plan should be reviewed towards the end of the cycle. The learning plan can be amended during the year to respond to emerging learning needs.
Base minimum 30 CPD hours of required types
- A minimum of 10 of the 30 hours must be peer consultation, which means supervision or consultation in a group or individual format which involves a critically reflective focus on the practitioner’s own practice. In a group setting, only those hours spent discussing and reflecting on the individual psychologist’s own cases/work matters can be counted towards the peer consultation requirement. The additional time in the group can be counted towards active CPD hours.
- A minimum of 10 hours of the 30 hours are recommended to be active CPD, which means CPD that engages the psychologist in active learning through written and oral activities designed to enhance and test learning.
- Other hours of CPD activities undertaken to make up the 30 hours can be peer consultation, active CPD or other relevant CPD activities.
- The same CPD requirements apply regardless of part-time work status.
Allocation of CPD in specific categories
PBA area of practice endorsement(s)/APS College membership(s)
New CPD requirements for Medicare providers
- The new PBA CPD requirements also coincide with the introduction by the Australian Government of mandatory CPD as a requirement of maintaining Medicare provider status for psychologists delivering ‘Focused Psychological Strategies (FPS)’ Medicare items. The requirement is for 10 hours of FPS-related CPD activities per annual cycle, which can obviously be counted towards meeting the 30 hour PBA or APS CPD requirements.
- Psychologists providing clinical psychology Medicare items are already required to meet CPD requirements to maintain Medicare provider status. These requirements are those to maintain eligibility for the APS College of Clinical Psychologists and PBA area of practice endorsement in clinical psychology. These requirements involve 16 hours of clinical psychologyrelated CPD activities per annual cycle, which are counted towards meeting the 30-hour PBA or APS CPD requirements.
- The Australian Government has delegated the CPD monitoring process for Medicare providers delivering FPS to the APS (as per current arrangements for clinical psychology Medicare providers), and has advised that the consequence of a psychologist’s non-compliance with the CPD requirements will be loss of Medicare provider status.
- See article on page 27 of this edition for further information.
Journal entry for each hour of CPD undertaken
- Psychologists are required to keep a record of the content and relevance to their individual learning goals of each CPD activity undertaken. This should be in the form of a journal entry.
- The journal entry must demonstrate engagement with the CPD activity through outlining the content of the activity, how it has contributed to the psychologist’s individual learning goals and any action that has been taken in response to the learning.
- The PBA has indicated that approximately half a page of reflection and learning should be written for each hour of CPD.
Acceptable CPD activities
- A wide range of CPD activities is acceptable providing these fulfil the goals of enhancing psychologists’ professional competencies (both skills and knowledge) in their own area of psychological practice. Psychological practice has been defined by the PBA as any role, whether remunerated or not, in which the individual uses his or her skills and knowledge as a psychologist. This is not restricted to the provision of direct client care and includes using professional knowledge in management, administration, education, research, advisory, regulatory or policy roles, and any other roles that impact on the safe, effective delivery of services in the psychology profession.
- Selected CPD activities should enable psychologists to keep up to date with advances in their area of practice, such as research evidence and theoretical developments, organisational work (team building and leadership), communication, ethics, teaching, research and administration.
- The selection of activities needs to be based on the individual psychologist’s identified areas for development and improvement, as assessed in the annual learning plan.
- Psychologists can choose whether to undertake CPD activities that have been formally endorsed by the APS or to engage in other selected activities relevant to their learning needs. The relevance of activities will need to be able to be justified if audited.
Online CPD logging
- The redesigned APS CPD logging system is currently being finalised and is expected to be available for members use at the beginning of the new year. At that time, APS members will be sent full information on how to use the online logging system to meet the CPD requirements.
- The redesigned system will enable all of the required components of CPD documentation and record keeping to be recorded online in one location. This includes the required learning plan, the various categories of CPD activities and the required journal entry for each hour of CPD activity. The APS CPD logging system will automatically enable users to know when all CPD requirements have been fulfilled by tallying the number of hours of CPD that have been undertaken in each required category and registering the learning plan and journal entries.
- Members should keep alternative records of all CPD activities undertaken and the required journal entries while the online logging system is being finalised. Members are encouraged to keep electronic notes for journal entries so that these can be easily copied and pasted into the new online logging system.
Exemptions from meeting the new CPD requirements
APS members registered with the PBA
- Psychologists may apply to the PBA for a partial exemption fropm meeting the CPD requirements due to ill health, maternity/paternity leave or other special circumstances. Requests must be submitted in writing to the PBA prior to the expiry of the annual registration period and must include the nature of the special circumstance and the period of time for which exemption is being sought.
- A psychologist who is granted an exemption from the PBA will be eligible for the same exemption from meeting the APS requirements. The PBA exemption will be required as evidence.
- Psychologists who have non-practising registration with the PBA are not required to meet the CPD requirements. Information regarding this status should be supplied to the APS.
Other non-registered APS members
- APS members who have retired from psychological practice or are not working in a role related to psychology are exempt from meeting the CPD requirements. This non-practising status needs to be indicated on the annual APS membership renewal form.
- APS members may apply to the APS for an exemption from meeting CPD requirements due to special circumstances.
Audit of CPD activities
- Random audits of registered psychologists will be conducted by the PBA following each annual cycle to ensure requirements have been met. APS online records will be accepted by the PBA as evidence of fulfilment of CPD requirements.
- In addition to the evidence available in the APS online logging system, psychologists will need to produce supporting documentation as proof of participation in CPD activities.
- The APS will also undertake an annual random audit of members to ensure compliance with CPD requirements.
Consequences of non-compliance with CPD requirements
- The PBA Continuing Professional Development Standard states that psychologists renewing their registration or endorsement must declare that the CPD requirements have been met in the previous 12-month registration period. The PBA has indicated that all components of the CPD requirements (learning plan, specified minimum number of hours of CPD in particular categories, and journal entry for each hour of CPD undertaken) must be met in order to be deemed compliant with the mandatory CPD requirements.
- The PBA Standard states that consequence of failure to comply may be one or more of the following:
- Refusal to renew registration or endorsement
- Imposition of a condition on registration
- Requirement to undergo a performance assessment
- Requirement to undergo an examination
- Instigation of disciplinary proceedings.
- The consequence of non-compliance in relation to APS membership will be a warning only for the first annual cycle in acknowledgement of the complexities of transitioning to the new CPD arrangements. The exception to this applies to APS College members who will be downgraded to Affiliate Member status if the specialist CPD component of requirements is not met, as per the APS Colleges' previous practices.
Health and community psychology gain PBA endorsement status
The APS is delighted that the two specialties of health psychology and community psychology have been added to the list of approved areas of practice endorsement under national registration, following a decision by the Australian Health Ministers Council to overturn the previous ruling which excluded them.
The decision follows months of intensive advocacy by the APS and its Colleges of Health and Community Psychologists to have these two specialist areas of psychological practice recognised under the PBA system of endorsement of specialist psychological practitioners on the national register. The decision by the Ministerial Council was based on advantages to the public in being able to identify psychologist practitioners with specialist skills in health and community psychology.
The lack of endorsement status under the previous ruling had major implications for the survival of these two important specialties of psychology and the critical expertise they bring to health services and community health. On this basis, the two APS Colleges of Health and Community Psychologists undertook intensive high level advocacy with Health Ministers, Shadow Health Ministers, Ministerial advisors and senior health bureaucrats.
The advocacy included writing letters, holding numerous meetings and garnering support from relevant employers. The Colleges also organised a grass roots campaign by members and a petition that was signed by over 3,000 people.
The APS sought to highlight awareness of the important contribution of these two psychology specialties through preparing a special report in InPsych – which was distributed widely to politicians – and through a number of media releases. In addition, the APS campaign was enhanced through support from international colleagues in the UK and the US where both health and community psychology are recognised as prominent specialities under regulatory frameworks.
It is very pleasing that the Health Ministers have recognised the importance of these two psychology specialisations to community health and wellbeing.
The transition arrangements for psychologists seeking endorsement in the newly recognised practice areas of health psychology and community psychology under national registration are yet to be announced by the PBA.
The PBA has advised that the Area of practice registration standard will be revised to reflect the two newly recognised areas of practice. The revised registration standard must then be formally approved by the Ministerial Council before psychologists can apply for endorsement in these areas of practice.
The PBA has advised that the necessary forms and guidelines will need to be updated once Ministerial approval has been granted, and expects this to take place early in 2011. The APS has lobbied the PBA to provide the same transition arrangements for eligibility to apply for area of practice endorsement under the previous rules as were provided for the other seven approved areas of practice.
The PBA has advised that it expects these transition arrangements to reflect the provisions for the previous seven areas of practice and will update the guidelines following Ministerial approval.