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Audiology Regulation Consultation on Decision Regulatory Impact Statement

Important news!

Announced in May 2024, the Queensland Government is leading State and Territory Health Ministers to consult with the hearing health sector on the development of a Decision Regulatory Impact Statement (Decision RSI) considering regulatory and non-regulatory options for the future of audiology. This will consider impacts on both the audiology profession and audiometry.

Resources

Scroll below to read the consultation papers and explainer articles by Audiology Australia and other audiology stakeholders.

Options in scope for this review include:

  • National Registration and Accreditation Scheme (APHRA) registration
  • Regulation of only audiologists that perform paediatric diagnostic and cochlear implant care services
  • The status quo – certification under the National Alliance of Self-Regulating – Health Professionals (NASRHP)
  • jurisdiction based regulation

A consultation paper has been provided for to inform the process. You can download this here or under resources below. We suggest you also download and read our feature guide to everything you need to know about regulation and audiology.

It is important to keep in mind this is a review. Nothing has been decided and everything remains on the table. As a sector, it is an important opportunity for us to work together to help shape and inform the discussion. It is also a chance to collectively understand and reflect on what the future needs to look like and how each option gets us there.

Who is Being Consulted?

Hearing Health stakeholders and leaders, including peak accrediting bodies, Audiology Australia and the Australian College of Audiology have been invited to consult on this review with public feedback to be sought through the Queensland Government website.

Consultation closes 5pm AEST Friday 31 May 2024.

Consultation and Delivery Timeline:

Deloitte have been engaged by Queensland Health to conduct the consultation process which will include consultation, development and presentation of the Decision RSI as follows:

  • May 2024: National sector and public consultation
  • June 2024: Develop Decision RIS drawing on consultation
  • 26 July 2024: Present Decision RIS to Health Minister’s meeting

Audiology Australia’s Role

As the largest national accrediting body and policy advocate for the audiological profession, we’ve been invited to consult along with identified key sector stakeholders and leaders. Deloitte is currently scheduling these meetings to take place throughout May 2024.

As stated above those participating have been asked to respond to a consultation paper. We have identified many inaccuracies throughout this document which we will seek to address as part of our consultation feedback, as well as providing context and detail to give appointed reviewers a more complete understanding of the impacts of each option for the profession. Ultimately, we want to ensure this review is clear about not only the problem it seeks to solve, but the effectiveness of the proposed options to address it.

Audiology Australia Statement

While Audiology Australia welcomes this opportunity to strengthen the profession, we urge caution in viewing regulatory changes for audiology as a panacea for broader systemic failures in the settings identified in the recent Qld and SA inquiries.

Resources and Support to Join the Conversation

As we continue this discussion, it is important you are well informed, armed with all the facts and understand not only our current regulatory environment but what registration really means for you and the audiology profession.

To help you understand the nuances, risks, and opportunities of self-regulation vs. registration and the options in between, we have developed feature articles that provide a good overview of both models and their benefits and disadvantages, while dispelling common myths and misconceptions and exploring impacts on you and your daily work and the profession. We have also shared articles from stakeholders: Independent Audiologists Australia (IAA) and the National Alliance of Self-Regulating Health Professions (NASRHP).

Along the way we will provide additional resources and support. You can also find information in the FAQs below.

Frequently asked questions

How can I provide feedback?

You can find out more information and provide feedback online through the Queensland Health website: https://www.health.qld.gov.au/clinical-practice/engagement/audiology-regulatory-impact-statement

To share your views, please have the Audiology RIS Consultation paper available while completing the feedback survey. The survey should take around 10 minutes to complete.

Access the survey directly here: https://www.health.qld.gov.au/clinical-practice/engagement/audiology-regulatory-impact-statement/feedback

Consultation closes 5pm AEST Friday 31 May 2024.

Why have the state ministers called for this consultation?

This consultation comes as the audiology profession continues to be under the spotlight with recent inquiries in South Australia and Queensland and key reviews currently underway including the Allied Health Scope of Practice, falling out of the Strengthening Medicare Reforms, and the Allied Health Clinical Governance review, the latter of which is being led by Queensland Health. This increased scrutiny has sparked renewed discussion about regulation of the profession.

Importantly, we need to work together with governments and consumers to ensure these types of incidents do not continue to occur.

What is Audiology Australia’s position on regulation?

We have raised and continue to raise registration as part of our advocacy, but the decision ultimately lies with Government. As we continue this discussion, it is important you are well informed, armed with all the facts and understand not only our current regulatory environment but what registration really means for you and the profession.  There are both advantages and disadvantages to registration, and indeed, areas that remain unaddressed in any regulatory and self-regulatory models.

The articles below delve into the various considerations in more detail:

What is the timeline for implementation of changes?

Timelines for implementation of any decision or change as a resulting from this review are ultimately up to Government, however, given the work involved they will be some years away. This means it will remain business as usual in terms of the next twelve months and foreseeable future.

How is Audiology currently regulated?

Currently Audiology in Australia is self-regulated, however this doesn’t mean there is an absence of regulation.

To practice audiology and receive government funding through Medicare, HSP and NDIS an audiologist is required to be an accredited member of a professional practitioner body (PPB), either Audiology Australia or the Australian College of Audiology.

Audiology Australia is an approved member of the National Alliance of Self Regulating Health Professions (NASRHP), the national peak body representing self-regulating health professions in Australia. The NASRHP standards are closely modelled on NRAS standards. In addition, audiologists must adhere to the standards set in the National Code of Conduct for Health Care Workers

To handle complaints, the Ethics Review Committee investigates and manages breaches of the code of conduct. Any reports that hold significant concern are referred onto the relevant state-based health complaints body.

You can read more in our feature article here: Demystifying Regulation: An Overview for Audiologists — By Eleanor Hoskins, Policy Manager, Audiology Australia

What does registration mean?

Currently Audiology in Australia is self-regulated.

To be registered with Ahpra a profession must be assessed for eligibility into the National regulation and accreditation Scheme (NRAS). The NRAS is governed by a nationally consistent law passed by each state and territory parliament – the Health Practitioner Regulation National Law (the National Law).

Practically this means that the professions that are part of the NRAS, have consistent, nationally recognised professional standards, accreditation of education workfocrece mobility and a robust notification system for complaints against practitioners.

The primary role of the NRAS is to protect the public from harm. Member associations that sit outside of Ahpra provide additional activities to support their members.

You can read more in our feature articles here:

What would change under registration?

Without confirmation of the entire scope of the changes the extent of the changes that the sector faces under registration is somewhat ambiguous however broadly it would allow for Protection of title, Legislated compliance with national standards, professional credibility, robust complaints handling procedures, Potential higher fees, Potential higher insurance premiums, loss of Autonomy.

What would remain the SAME under registration?

The commitment of the audiology sector to provide high quality and professional services along with the extensive certification, accreditation, and compliance activities that AudA require of its members, most of the practical components would remain the same under Ahpra registration including CPD, accreditation of education and compliance with national standards including the Code of Conduct.

Workforce mobility between states isn’t a significant issue within the sector so that will largely remain the same.

Many of the challenges faced by the sector would also likely remain. Many other allied health practitioners, both Ahpra registered and self regulated report challenges with funding, Medicare direct referrals, workforce in rural and remote areas and professional recognition. Some of these require additional changes in legislation and advocacy to government.

Would there be more protection against unethical business practices and advertising under Ahpra?

The main purpose of the NRAS is to protect the public not the interests of health professions . These two aspects are often intrinsically linked, and as such The Guidelines for advertising a regulated health service have been developed under section 39 of the National Law to ensure the advisement of services provided by a registered health practitioners are appropriate.

Other legislation exists to provide protection against unethical or illegal business practices that is not related to advertisement of health services and the ACCC can investigate and can take action to enforce compliance. Similarly the TGA investigates inappropriate advertising and use of medical devices (such as hearing aids).

When it comes to unethical business practices in the current regulatory environment, the Audiology sector is supported by the existing legislation and regulations under the ACCC and TGA. Audiology Australia Accredited audiologists must also meet the professional and ethical standards as set out in the Code of Conduct for audiologists and audiometrists.

Audiologists who are registered with a PPB can be investigated by the Ethics Review Committee in relation to breaches of the code of conduct and can also be investigated by the relevant state based health complaints body.

You can read more about current rules for advertising and promotion through testimonials here. 

Would audiologists get automatic exemption or be excused from Jury Duty as an Ahpra registered profession?

Legislation on jury duty exemptions vary from state to state, in NSW for example, exemptions exist for 4 of the 16 registered health professions (doctors, dentists, pharmacists and paramedics). Most other states do not have specific exemptions for health practitioners. In all states exemptions usually relate to individuals who work in positions where conflict of interest is an issue such as within the Justice system or within specific government positions. Other exemptions include criminal convictions, poor English language skills and age.

Depending on which state you live in, you may also be excused from participating in jury duty if you make an application, there are many reasons that vary between states but some examples include being a sole trader or owning a small business, having caring responsibilities, university commitments, medical issues or that attending the jury duty will result in substantial financial hardship.

You can read a full list of current reasons for exemptions for each state here:

HAVE A QUESTION?

For further information about the consultation, please contact info@audiology.asn.au or 03 9940 3900.