The inclusion criteria into the government complaints mechanism, Australian Health Practitioners Registration Agency (AHPRA) is known as statutory registration. Many natural therapists are under the illusion that inclusion into AHPRA will give credibility to their profession. This is untrue.
To be regulated by governing bodies, it is widely recognised that Natural Therapist Associations need to present themselves in a united way with a workable strategy to be included and recognised by independent and governing bodies.
To unite again for the support of Natural Therapies, it is now recognised that Co-regulation is the preferred model for “Practitioners”.
Firstly it needs to be understood that Stat. Registration is NOT RECOGNISING Naturopathy, Herbalism or Natural Therapies as a valid Treatment or Health Care Model.
It recognizes only that those professionals are capable of harming the public.
The system is designed for public protection from medical services and therapies which could cause significant harm.
Many practitioners are under the entirely false impression that registration stands for recognition. This could not be further from the truth.
... Contrary to PRO-Registration's claims ....
Statutory Registration will NOT increase public safety; un-accredited, un-educated, unregistered practitioners, or sales personnel in retail shops and staffing websites will still be able to recommend, give advice and sell supplements or herbal remedies. The additional obligations will only apply to those in the registered profession! Complaints mechanisms will not change; they will still be retrospective in nature, investigations conducted into harm that has already occurred.
"Protection of Title"will make NO difference to people who practice without qualification.
Accreditation as under the Co-Regulation system states already that only accredited practitioners are allowed to practice. The day to day practice is not the subject of exclusion through Protection of Title, only the name by which practitioners advertise themselves. Thus, when an unqualified professional comes to regulatory attention through harm they have caused, the only thing that protection of title will add is another criminal offence to the charge sheet…
Registration is NOT of any “Direct Measurable Benefit” to registered practitioners. Purported benefits are indirect at best, and usually specious promises, such as inclusion into the public health system (Medicare), that will at the least require significant legislative and regulatory change over decades as well as a total reversal in established health budget spending forecasts. “Improved recognition” also falls into this category, and it can be far better effected amongst the healthcare consumer by alternate means without the unavoidable and necessary detriments of inclusion in the stat. reg. scheme. Other Registered professionals have experienced the detriments from day one; and they are still waiting for the promised benefits, such as access to restricted Chinese herbs…
ISOLATION OF MODALITIES: Registration will isolate Natural Therapies from each other, working against Holistic Principles. It has to be recognised that titles considered for Registrations are ONLY Naturopaths & Herbalists, which raises concerns for a separation of Natural Therapy Modalities, ultimately leading to a loss of traditional and preventative treatment concepts. The modalities a practitioner chooses to use on a daily basis could be subject to control by AHPRA at a future date; for example, it is entirely conceivable a practitioner could be prosecuted for using a modality “without evidence of efficacy”.
To become registered, a profession has to comply to Registration requirements (the AHMAC criteria). One clause is to cause ‘SIGNIFICANT HARM’ to the public, and Naturopathy or Herbalism (or indeed ANY natural therapy) practiced by accredited practitioners is NOT causing SIGNIFICANT RISK OF HARM, therefore it is NOT fulfilling AHPRA's requirements for inclusion.
The issue is not of pure risk, the issue is that of threshold; current evidence does not support the argument that members of the public choosing to engage a practitioner are exposed to significant risk that cannot be managed by existing regulatory schemes. In fact, data of complaints about practitioners to regulatory authorities shows that the choice to see a natural therapist is overwhelmingly safe.
Registration is not to be conflated with Regulation. They are not the same! Registration is not the only method for effective Regulation. Registration is also not necessary for Regulation. In fact, Regulation is already in place! State-based Unregistered Health Professions legislation being rolled out across Australia is ALREADY a regulatory system overseeing ALL health practitioners (regardless of what they choose to call themselves). The state-based bodies already have almost identical powers and procedures to those of AHPRA. Practitioners are already regulated under a system that has the aim of protecting the public from harm!
Herbalists in particular are using remedies that are deemed “safe” under therapeutic goods legislation and foods regulations, and those same herbs are available for OTC/off-the-shelf self-selection by lay people. Those arguing that Western Medical Herbalists are dangerous are arguing that their professional training makes them more, not less dangerous, which is ridiculous - the opposite to any other profession on the earth and the opposite to the aim of professional training – education aims to confer the knowledge upon a person to remove the risk in using that which is potentially dangerous in untrained hands!
Stat. Registration may WRONGLY COMPARE NATURAL THERAPIES TO THE MEDICAL SYSTEM - This compounds misrepresentation of Natural Therapy. Natural therapies is a poor fit for a pure “disease management” model of healthcare. Being able to analyse and treat preventative and developing health issues and imbalances, is THE core difference between medical therapies and natural therapies.
Natural Therapies Practitioners are under constant attack. Some of those attacks are of a vexatious complaints nature, others are deliberate misrepresentations by "skeptics" to discredit Natural Therapies.
NOTE: Stat. Registration is likely to increase vexatious complaints, especially from individuals and 'bodies' that are working hard to discredit Natural Therapies in every way they can.
The AHPRA Board overseeing all practitioners of a registered profession under Statutory Registration will NOT be able to implement anything which could be perceived as to be against the prevailing medical thinking. Where there is a disagreement between a natural therapies philosophy and a medical one, it is clear which will win. Many of the strongest prohibitions on registered professionals are concerned purely with advertising (for example, “Protection of Title” is all about advertising) which will constrain the ability of natural therapists to advocate a higher standard of HEALTH and wellness to the public!
And finally a word of caution: 'Once registered there is NO way back'.As acupuncturists and chiropractors who are realizing statutory registration has conferred only detriment to their professions and their individual practice are finding out!
To find out more about Co-Regulation go to: What is Co-Regulation
To be registered the following criteria has to be made. NMAA argues, we don't meet the criteria ...
The six AHMAC criteria are:
Is it appropriate for Health Ministers to exercise responsibility for regulating the occupation in question, or does the occupation more appropriately fall within the domain of another ministry?
NMAA argues: NO, it needs to be with a new independent body
Do the activities of the occupation pose a significant risk of harm to the health and safety of the public?
NMAA argues: NO, accredited Naturopath or Herbalist do NOT pose a significant risk of harm!
NOTE: Fraudulent practitioners DO harm, but they will not get registered.
Do existing regulatory or other mechanisms fail to address health and safety issues?
NMAA argues: Existing regulatory mechanisms work well for accredited practitioners, and will be improved by "Co-regulation".
Is regulation possible to implement for the occupation in question?
NMAA argues: NO
Is regulation practical to implement for the occupation in question?
NMAA argues: NO
Do the benefits to the public of regulation clearly outweigh the potential negative impact of such regulation? Do our professions meet these criteria?
NMAA argues: NO
Do our professions meet these criteria?
NOTE: Australian Health Ministers' Advisory Council (AHMAC) is the advisory and support body to the COAG Health Council.