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   Submission regarding the National Registration and Accreditation Scheme for Health Professions nraip@dhs.vic.gov.au National Registration and Accreditation Scheme for Health Professions Re: Call for Submissions - Exposure draft of Bill B. Dear Chairperson & Committee Members, The following submission is from the Australian Podiatry Association (Qld) Inc in regard to the Call for Submissions - Exposure draft of Bill B. Accreditation While the A Pod A (Qld) Inc supports the national scheme from the perspective of national registration for the profession, we have a specific concern that the Ministerial Council has a reserve power over standards that they may believe have a substantial and negative impact over workforce numbers. This power, if used, may change standards, which may prove incompatible with objectives of protecting and improving public health and safety.  Action requested – Remove the ministerial reserved powers to overrule the National Registration Board. The handling of complaints The A Pod A (Qld) Inc believe that the Public Interest Assessor will provide unnecessary delays in the review and handling of complaints, increase costs to the profession and community, and duplicate similar services handled by peer review through the national registration board and supported by relevant health complaints commissions. If the Public Interest Assessor was to remain we would support the adoption of the HQCC in Queensland undertaking this role.  Action requested – Remove the Public Interest Assessor from the handling of complaints.  Fines / penalties The A Pod A (Qld) Inc feels that the levels of fines indicated for breach of title are inadequate and consideration should be given to make these more severe and in line those that many states already have in place. In particular, we feel that Body Corporate fines for breach of title should be greater than double that of individuals as listed in the draft Bill.  Action requested – Increase fines for breach of Protected Title and increase Body Corporate breaches of such instances to Five (5) times individual fines/penalties. Specialist Register  Podiatric surgeons currently already have specialist registration in South Australia and Western Australia. Whilst specialist registration does not exist in all jurisdictions, all Boards have a policy of recognising the specialist nature of podiatric surgery, and endorse the training and postgraduate roles of this arm of the profession. Not including a specialty register for podiatric surgeons in the  Health Practitioner Regulation  National Law (2009) Bill B will erode standards in the profession, and is against the spirit and intent of the Intergovernmental Agreement (IGA) signed by all Health Ministers, whereby no jurisdictions will be disadvantaged by the scheme. The absence of a Specialty Register for ‘Podiatric Surgery’ and ‘Podiatric Physician’ is of great concern for the A Pod A (Qld) Inc. We supported the srcinal intent for specialist endorsement as outlined in the January 2009 CONSULTATION PAPER: Proposed arrangements for specialists within the National  Registration and Accreditation Scheme for the Health Professions . This Consultation paper clearly stated under Registration arrangements for registered podiatrists – proposal 10.1.3 that: there be an offence for a  person who is not a registered podiatrist with endorsement as a podiatric surgeon to hold themselves out as a podiatric specialist. However, the Exposure draft for Bill B does not include podiatric surgeons as a specialist category. This is of great concern to the A Pod A (Qld) Inc and many within the profession as the January 2009 CONSULTATION PAPER also stated: For the purposes of transition, from 1 July 2010, initial registration of specialists in any profession will be by an endorsement on the public register subject to (a) above. In the absence of such a standard being in existence at the time of transition to the scheme, the registrant will only be granted general registration without specialist endorsement. The specialty of podiatric surgery already exists, and the proposed legislation will directly erode the current legal rights of the profession, and penalise those states with specialist arrangements for podiatric surgeons already in place. Of most importance is the potential impact on the public – current specialisation and accreditation process’s provide a means for identification and monitoring of standards of surgical practice in the podiatry profession. To remove this is clearly placing the public at heightened risk. It is in the public interest to recognise that specialist podiatric surgeons and physicians continue to be recognised under a specialist register, maintained by the Podiatrists Board of Australia. This exists because of a need to ensure podiatrists with surgical and further qualifications are recognised in the interests of public protection and safety. Podiatric surgeons, as a specialist branch of podiatry, have been performing reconstructive surgery on bone and joint structures of the foot and ankle in Australia for over 30 years. Medical groups opposed to podiatric surgery argue against the provision of these surgical services by podiatrists, however this has been formally recognised in many pieces of legislation and statutory instruments. Training leading to Fellowship with the Australasian College of Podiatric Surgeons (ACPS) is the nationally recognised benchmark for specialist surgical practice across Australia. Fellowship with the College is already  recognised and accredited by the Commonwealth under the  Health Legislation Amendment (Podiatric surgery and other matters) Bill 2004. The Podiatrists Registration Board of WA also formally recognises the Doctor of Clinical Podiatry as a qualification for specialisation as either a Podiatric Surgeon or as a Podiatric Physician. The Podiatrists Act 2005 (WA) also recognises the UWA Master of Podiatric Medicine and the Doctor of Podiatric Medicine programs as additional pathways to specialise as a Podiatric Physician (management of the high risk foot). The Australasian Podiatry Council is the current accrediting body for the ACPS, until the newly formed Australia and New Zealand Podiatry Accreditation Committee (ANZPAC) can take over this role upon the formation of the Podiatrists Board of Australia. In 2008, the Australia and New Zealand Podiatry Accreditation Committee (ANZPAC) was established and incorporated, to take over the process of accrediting podiatry courses and overseas qualifications from the Australasian Podiatry Council. The Australian Health Workforce Ministerial Council recognised and endorsed ANZPAC to take over this role in 2009.The similarly-tasked medical practitioner organisation, the Australian Medical Council (AMC), was established in 1984 and has only recently (since 2002) taken over the role of accrediting specialist activities of the medical profession. Like the AMC, ANZPAC is expected to take the leading role in accrediting the activities of specialist podiatric surgeons. The ACPS is looking forward to developing a strong association with ANZPAC, in the same professional manner as the Royal Australasian College of Surgeons does with the AMC.    Action requested- The draft legislation should be amended to list podiatry as the third profession with specialisation (Podiatric Surgery and Podiatric Physician). Titles We note some submissions to this inquiry express a view that only medical practitioners should be legally able to utilise the term ‘ surgeon ’ and “ doctor  ”. The A Pod A (Qld) Inc currently supports the range of professional titles to be protected under proposed legislation. We see no reason to modify the current provisions, and would strongly oppose any restrictions surrounding these titles. Other professional groups, such as podiatrists, chiropractors, dentists, veterinary practitioners would be directly impacted and disadvantaged by any modification to the current provisions. This would again undermine the spirit and intent of the IGA.  Action requested - The adoption of the proposed legislation in regard to title protection as drafted The A Pod A (Qld) Inc hopes you will consider the above submission – we can provide further information as required. Yours sincerely   Trent Johnston President A Pod A (Qld) Inc
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