Chapter 3
Implementation of the National Registration and Accreditation Scheme by the
Australian Health Practitioner Regulation Agency
Introduction
3.1
The introduction of the National Registration and Accreditation Scheme
(NRAS) was a very complex task: it brought together 10 health professions from
eight jurisdictions into one national registration and accreditation scheme. The
Australian Medical College noted that it is a common misconception that 'the NRAS
project is a straightforward transfer of existing registration functions and
activities from the State and Territory regulatory bodies to the National Board
and AHPRA'. In addition to registration functions, the 10 health professions
are required to develop, and maintain both registration standards and standards
for the accreditation of programs of study and the institutions providing these
programs. The College commented that:
...development of these standards is complex and there are
high-stakes for the educational institutions that provide the programs, the
professions, health jurisdictions and the community. It requires careful
consideration and stakeholder input. The consultation requirements, while essential
to achieving national consistency, add to an already complex system and have
contributed to time delays in other AHPRA processes. Again, there were no
precedents for these in the legacy systems that were inherited by AHPRA from
the State and Territory regulatory processes.[1]
3.2
The size and complexity of the task, as many witnesses noted, was well
recognised by stakeholders from the inception of the scheme. Dr Kay Sorimachi,
Pharmaceutical Society of Australia, stated:
We did foresee problems, given the complexity of the
transition. This was not simply amalgamating a number of organisations into
one. It consisted of 10 diverse health professions being brought together. The
number of registrants and therefore the accompanying data that needed to be put
together was considerable.[2]
3.3
The Australian Medical Association in particular pointed to Australian
Health Practitioner Regulation Agency's (AHPRA) lack of understanding of the
core business requirements for registering health professionals and the impact
on the health system. As a consequence, there was no strategic planning to
ensure that all aspects of the registration and renewal processes were
addressed, resulting in significant delays and disruption for the profession,
employees and patients.[3]
3.4
Submitters were of the view that there appeared to be a lack of
recognition of the nature and extent of difficulties that were likely to arise and
as a consequence, AHPRA was provided with inadequate resources.[4]
Ms Liesel Wett, Chief Executive Officer, Pharmaceutical Society of Australia
commented that 'it would seem to us that, given the scope, the resources were
not adequate to cope with the merging of the 10 professions into a new
database and a new entity with new people'.[5]
This view was supported by other organisations including the Australian College
of Rural and Remote Medicine.[6]
3.5
Some submitters commented that it had been a mistake to transition all
10 professions as the same time. The Australian Psychological Society, for
example, commented that 'in hindsight it is obvious that many of the problems
encountered could have been managed if the task involved a step-wise
introduction of professions into the scheme instead of ten at once'.[7]
3.6
It was generally agreed by submitters that insufficient planning had
been undertaken by AHPRA and therefore a lack of adequate resources were
committed to the implementation process. As a result, unrealistic timeframes
for transition were set. The lack of resourcing was in seen in:
-
AHPRA offices and state and territory boards;
-
inadequate call centre and website processes;
-
inadequate training of staff; and
-
lack of liaison with key stakeholders including large commercial
entities.
3.7
There were also concerns that the implementation process had not taken
advantage of the expertise available in state and territory boards. Dr
Sorimachi commented:
We were also aware that, because pharmacy as a profession had
been operating under state and territory legislation in terms of registration
for many years, the state entities, our pharmacy boards, had considerable
experience in this. We were concerned that in the transition some of this
expertise would be lost. So even as early as October 2006 we had suggested that
perhaps in the initial stages the state and territory pharmacy boards remain as
organisations whilst the transition was made. In April 2009, I think, we
reiterated that position. We were concerned that in looking forward to the 2010
implementation that aspect had not been taken into consideration and that in
simply dismantling all the state and territory pharmacy boards we would lose
all the benefits that resided in those entities.[8]
3.8
Concern about the loss of expertise was also raised by Dr Steve
Hambleton, Vice President, Australian Medical Association (AMA), who also put
the view that the process had not been well-handled by AHPRA:
There was lots of expertise available. We know the complexity
of medical registration, and state boards know the complexity. I guess AHPRA,
which took on that role, should have done a better job. It is unacceptable in
these days that they should not have done a better job, and if they were not
resourced to do so then they should have been.[9]
3.9
The Australian College of Mental Health Nurses (ACMHN) also commented on
the failure of AHPRA to call upon those organisations with expertise and strong
communication links with their members to assist during the transition period.
The ACMHN considered that 'if the information and communication channels of the
nursing organisations across Australia had been used in the absence of robust
communication mechanisms of the AHPRA/NMBA [Nursing and Midwifery Board of
Australia], there would have been a reduction in confusion among the nursing
profession about administration changes and impacts on individual obligations
to renew their registration'.[10]
3.10
Another problem identified was the loss of many experienced and
knowledgeable members of former state boards and councils. The Australian
College of Rural and Remote Medicine commented:
From a professional college perspective effective working
relationships that had been cultivated over many years were entirely lost when
AHPRA commenced. Many of the experienced people in previous state medical
boards did not transition to state AHPRA and it has taken a long time for the
responsibilities and names of new staff members to be shared with the College–even
in those portfolios where there was active, weekly, communication required for
activities such as communication about results of overseas trained doctor
assessments.
This has led to a general decline in efficiency within the
system and confusion and lack of confidence in the new system. It has also
meant that many policy and administration issues have needed to be discussed
again and reconfirmed. This has unnecessarily wasted time and resources.[11]
3.11
The Australian Medical Council stated:
Experience with the implementation of new regulatory legislation
in medicine, as occurred in Victoria, New South Wales and Queensland over
recent years, has demonstrated the need for effective communication within the
regulatory authority itself, as well as with key stakeholders and members of
the profession. In the past major changes in processes or policy have been
assisted by the presence of existing reporting channels, experienced personnel
and established infrastructure and IT systems. However, in the case of the national
registration projects and AHPRA, there has been a complete change of senior management
with an unfortunate loss of expertise at both the state and national level. AHPRA
staff now find themselves working under new reporting and management
structures, dealing with health professions and issues which they have not
previously encountered, operating under newly developed and unfamiliar
legislation and navigating totally new and equally unfamiliar business
processes and IT systems. Any one of these factors alone would have represented
a significant challenge to a well established organisation, let alone to a new
body with no corporate memory or established administrative practice and communication
structures.[12]
3.12
Overall, submitters concluded that the implementation process was
flawed, that significant problems that should have been identified before 1
July 2010 had not been addressed and as a result the registration of the 10
major health professions was put at risk. This had the potential to
significantly undermine the provision of health services in Australia because,
as stated by the AMA, 'the management of the transition from state based
registration to national registration has been an absolute debacle'.[13]
3.13
The following provides an outline of the difficulties that arose during
the implementation period.
Timeframe for implementation
3.14
The timeframe for the implementation of the scheme was criticised by
submitters both in terms of moving from state-based registration boards to
National Boards and the practical issues such as data system testing. Professor
Richard Smallwood, Forum of Australian Health Professions Council, commented:
I think that, throughout the development of NRAS and its
implementation, there has been unease about the time lines and the speed with
which it was required to go ahead, particularly with some delay in the bills.[14]
3.15
The Australian Medical Council provided these comments which pointed to
the effect of the short timeframes on planning for the implementation of the NRAS:
The requirement to maintain the momentum of the regulatory reform
agenda necessitated short timelines on key consultations and review of key
documents in support of the new initiatives. It is likely that longer
timeframes in the consultation processes would have added insight and
opportunity to anticipate and prevent some of the problems that have
subsequently emerged from the implementation. This remains a concern in the
roll out of the new Scheme, since the National Law requires consultation on a
range of complex matters relating to the operation of the legislation.[15]
3.16
The complexity of the situation was not only due to establishing a
national register, but also to the new accreditation requirements which the
Council of Australian Governments (COAG) had agreed would be undertaken by the
one national entity. Mr Gavin O'Meara, Ramsay Health Care Australia, outlined
this issue:
It is not just a centralisation of registration function but
a whole new raft of rules, guidelines, and standards associated with it that
everybody has to get used to, so I think that a softer start—just making sure
that the resources were there, the systems and procedures worked and everybody
was clear about that—would have been a much more acceptable way of doing it. I
think that is something that you see frequently in something like this, where there
is perhaps a political imperative to get something up and running. But it is a
tremendously big task, and I think that starting more slowly and implementing
bit by bit as you learn is a better way of doing it.[16]
3.17
The Optometrists Association of Australia pointed to the effect of the
short timeframe on AHPRA's internal processes:
The current problems reflect the ambitious implementation timetable
which apparently limited the time available for stress testing of systems,
staff training and other preparations for commencement.
With the benefit of hindsight, the design and implementation
of the national scheme was such a major enterprise that difficulties such as
those experienced should have been anticipated. If there were such risk
assessments undertaken or contingency provisions put in place Optometrists
Association does not know about them.[17]
3.18
Other submitters such as the Australian Psychological Society also
supported this assessment.[18]
3.19
The committee was informed that prior to the implementation of the NRAS,
consultations took place in 2008 and 2009. During the consultations, issues
around the time lines and the need for a focus on data transfer, training and
the complexity of melding the legislation were identified. Mr Ian Frank, Forum
of Health Professions Councils, commented:
There were concerns expressed that this was a very complex
exercise...because we were dismantling so many existing structures to create a
new one. I think pretty much all of the submissions that came in to the
implementation team—the project team that was looking at it—raised issues about
the complexity of the time lines, the data quality and the need for training et
cetera.[19]
3.20
Other witnesses drew the committee's attention to the implementation of
the 1992 mutual recognition scheme. This scheme was much less complex, retained
the existing jurisdictions and organisational structures and had an appropriate
lead in time, still took two to three years to fully bed in.[20]
3.21
The views of many submitters was summed up by Ms Elizabeth Spaull, Ramsay
Health Care Australia, who commented:
Many in the industry, many of whom I respect as senior
members of our industry community, said it was too much, too soon, too quick.
That is the general opinion in the industry.[21]
Committee comment
3.22
Establishing the NRAS was always going to be a difficult task: there
were delays in passing legislation, more than 500,000 health practitioners were
covered by the new scheme; large amounts of data had to be migrated from a
range of databases; new offices had to be established and staff employed and
trained. Coupled with the establishment of the national accreditation system,
it is apparent to the committee that the timeframe for the implementation of the
NRAS was significantly underestimated.
3.23
The committee considers that the problems with the timeframe should not
have come as a surprise: major stakeholders were raising concerns during the
consultation period and the implementation of the 1992 mutual recognition
scheme pointed to the complexities inherent in amalgamating state and territory
systems into a national scheme.
Data quality
3.24
Much was made during the inquiry about the problems faced by AHPRA
because of the quality of the data received from the state and territory
organisations. Again, submitters commented that this should have been
recognised, and planned for, in the implementation process.
3.25
The Australian Medical Council commented that data migration was one of
the most significant challenges facing the NRAS. Not only were there problems
with the quality of the data transferred to the national registers from the
existing state and territory registers but also with the IT infrastructure to
support the registration activities of the National Boards. The Council noted
that the experience with the implementation of the 1992 mutual recognition
scheme for medicine indicated that approximately 10 per cent of the data
collected from the state and territory medical registers contained duplicate
entries as a result of incorrect matching of the data held on individual practitioners
on the separate state registers.
3.26
The Australian Medical Council was of the view that since the
introduction of mutual recognition, considerable efforts have been made to
improve the quality of data on the state and territory medical registers. However,
it appears that the quality of data varies considerably across the different
professions that are now part of the national registration system. The Council
concluded:
Addressing this variability would require very thorough data
cleansing procedures prior to the transfer to the AHPRA-administered national
registers. Since the AHPRA data set was a compilation of data drawn from the
State and Territory registers, a significant number of the data quality
problems experienced by AHPRA were inherited from these systems.[22]
3.27
Mr Ian Frank, Forum of Australian Health Professions Councils, also pointed
to the implementation of mutual recognition in 1992 and commented:
So when the national registration scheme was implemented we
expected that something of that order could be expected in transmitting the
data across into the new national system.
That process usually requires cleansing the data well
beforehand. With mutual recognition we had about a year or two to do that, but
in this particular instance they did not. They could not transfer the data
until bills B and C were both implemented. There was a very short timeframe to
get that across and get it up by 1 July.[23]
3.28
While noting that the quality of the data had improved since 1 July 2010,
Mr Frank commented that systems were not properly implemented or tested in
the lead up to AHPRA taking over. Further, before the bills were passed by the
states and territories, there was no legal authority to provide the data to
AHPRA, so no live testing could take place.[24]
AHPRA confirmed this and stated:
In the transition period, issues with data AHPRA has received
from some previous state and territory boards has affected the initial renewal
process for some health practitioners. Until the National Scheme started on 1
July 2010, all data about health practitioners was held by state and territory
registration boards, not by AHPRA. In the first months of operation, AHPRA has had
to rely on these data, which were migrated to AHPRA, including the contact
details of health practitioners.[25]
3.29
AHPRA also stated:
The National Scheme began full operation from 1 July 2010,
the day immediately following cessation of operation of over 80 state and
territory boards. As such, there was no break between the start of the National
Scheme and the end of previous state and territory-based regulation. This meant
there was no opportunity to run or test new systems in parallel for any time.[26]
Case study 3.1
My
registration details were incorrectly translated from the Dental Board of
Queensland (DBQ). Initially AHPRA staff tried to tell me that one of my Dental
Specialties did not exist and could not be registered and that I am entitled to
be registered in two specialities was beyond the understanding of the staff I
dealt with. Then later with the renewal forms two specialties were not
accommodated with space on the generic renewal form sent November 2010.
Over the last 20 years I have had no problems with the
Dental Board of Queensland. I estimate about 10 phone calls and 5 emails to
sort this.
Source: Name
withheld, Submission 211, p. 1.
3.30
In addition, AHPRA stated that it had established its own ICT system as
'the work made it clear that, greenfields ICT would be required for AHPRA with
only limited re-use of existing systems and infrastructure likely'.[27]
Mr Peter Allen commented that:
The judgement about the preferred platform for the new
national scheme was made well before the start-up of the scheme. It was made
sometime I think in 2009; that was when the decision was made to go with the
Pivotal system as opposed to any of the existing state or territory systems.[28]
3.31
The Australian Psychological Society summed up the problems with
migration of data as follows:
The enormity and complexity of providing appropriate services
to half a million registrants, while inheriting a mishmash of databases and
previous Registration Boards' processes, is acknowledged. However, AHPRA should
have had an awareness of the likelihood of difficulties arising in
transitioning database information which should have been grounds for caution
and considerable care. There appears to have been insufficient planning for the
transition from jurisdictionally-based registration to one that is nationally
based, and the necessary risk management strategies to mitigate against
possible glitches in the new system.[29]
Committee comment
3.32
The committee considers that there were pointers, for example, the
difficulties experienced with the 1992 mutual recognition scheme, which should
have alerted AHPRA to likely problems with data migration. However, this
appears not to have been the case and as a result there was inadequate planning
and provision of resource.
3.33
The committee has noted AHPRA's comments about the delays in passing the
state legislation and the inability of AHPRA to access the data. However, the
committee considers that this is a somewhat disingenuous argument. The
committee does not believe that such a large undertaking would have been planned
without scrutiny of the databases which were to compromise the new national
register. Therefore, the committee, while acknowledging the size of the task,
does not believe that the fault lies with the former state boards, rather it
lies with AHPRA. AHPRA was able to quantify beforehand the number of databases
and the number of registrants. The Agency Management Committee was appointed in
March 2009. With AHPRA commencing on 1 July 2010, the committee considers that
there was more than adequate time to identify issues and to implement action to
ensure a smooth transition of data.
Contacting AHPRA
3.34
One of the major difficulties identified by submitters was the
difficulty in contacting AHPRA and accessing advice and the quality of that
advice. While AHPRA had established a 1300 local call number, many submitters
stated that accessing advice from AHPRA through the telephone help service was
at best problematic and at worst non-existent.[30]
Ms Melissa Locke, Australian Physiotherapy Association, commented that there was
a fault with the 1300 number and it was some time before it was fixed.[31]
When it was working, the committee heard evidence of very long delays on the
1300 number with one witness stating that a practitioner had waited for five
hours to have their call answered.[32]
3.35
Mr Stephen Milgate, Australian Doctors Fund, also commented on the
difficulties and noted that 'the process was [circular], with 1300 numbers
going to websites going to 1300 numbers going to websites'.[33]
3.36
The alternative way of contacting AHPRA is through its website. AHPRA
submitted that it had established 11 websites (one for AHPRA and one for each
of the national boards). However, evidence received by the committee again pointed
to significant problems: there were delays in responding to emails or, in many
cases, no response was received at all. In addition, the AHWMC commented that
on 5 July 2010 the online registers for each profession went live.[34]
3.37
The Australian Psychological Society (APS) provided the following
evidence of the problems encountered:
From July 1 2010, the APS was repeatedly informed of
overwhelming difficulties in accessing AHPRA staff either by telephone or
e-mail. Beside phone lines being continually engaged (and in Queensland initially
being diverted to an oil company) and the website frequently being offline, the
online website enquiry system also experienced significant delays, resulting in
delayed registration of health professionals. Another Victorian psychologist
trying to renew her registration was reportedly standing in a queue at AHPRA on
January 31 (last day of grace period) having failed to make contact with AHPRA
staff by either phone or email since mid-December.[35]
3.38
Ramsay Health Care Australia provided extensive assistance to its staff
who experienced difficulties with contacting AHPRA with registration inquiries.
Ramsay Health reported the following statistics:
-
on average, for 234 employees seeking assistance and advice it
took AHPRA 29 days to return calls/emails if at all;
-
178 employees never received a response and we assisted to seek
resolution/answers by phoning policy officers directly on their behalf; and
-
the National Workforce Planning arm, Ramsay Health Care
Australia, placed on average 107 calls/emails a month to AHPRA seeking
clarification and assistance. Of the 107 calls/emails lodged only 10-12 of them
would yield a response in the form of a return email or adequate verbal
instruction.[36]
3.39
The Royal College of Pathologists of Australasia provided the following
example:
Communication with AHPRA has been very bad, in particular,
time spent on the phone awaiting service and not being able to speak to the
appropriate people when they finally get through. One example of poor
communication is a Fellow returned a phone call from someone in the Sydney AHPRA
office, got put through to the Melbourne switchboard and was told that no-one
of that name worked in the organisation.[37]
3.40
Mr Robert Boyd-Boland, Australian Dental Association, commented:
...at some point in the process, when it became clear to ADA
and its branches that there was an issue with the new registration process, at
times branches approached AHPRA directly for confirmation and information about
what is going on and did not receive any correspondence back. That was in the
form of letters, telephone calls and emails, and there was no response from
AHPRA, which indicates systemic lack of communication not only with those
registrants but also with their professional bodies.[38]
Case study 3.2
NURSE C
-
October 2010 – applied for
registration No acknowledgement of her application was ever received. Emails to
AHPRA seeking a progress update on the following dates:
-
15 December 2010
-
6 January 2011
-
21 February 2011
-
3 March 2011
-
7 March 2011
On all but 2 occasions,
Nurse C was given the following standard response:
"Thank
you for contacting AHPRA. Your enquiry has been escalated to a
information/registration specialist who will advise you via email
accordingly."
Nurse C never received a response from AHPRA. On the
other occasions she received the standard response that applications are
assessed in date order and they could not give her any idea on how long her
application would take
-
In Nurse C's email of 7 March, she
advised AHPRA that their non-responsiveness and the time taken to process her
application was insufficient and inadequate. She notified them of her intent to
make a formal complaint. She received a response to this email to say that all
her emails had been forwarded on and that they were receiving a high volume of
emails and therefore applicants were waiting "a little longer than
usual" for a response.
-
Nurse C also made several phone
calls over this period, all with the same answer – "your application is in
the system to be looked at". March 2010 – she received a letter to say
that she needs a letter from her College showing that her education was in
English.
-
Nurse C's application has taken 5
months and she has still not been granted registration. Nurse C was expected to
start with RHC in January 2011, but the hospital is still waiting for her to
join them. Nurse C has come to Australia on a working holiday visa and is
working as an Assistant in Nursing whilst she continues to wait for her
registration to be granted.
Source: Ramsay Health Care Australia, Submission 35, p.
9.
3.41
The ACMHN commented that the website is not user friendly and lacks even
some basic information such as the different types of registration.[39]
One nurse, after waiting for five hours to speak to an AHPRA operator was told
the information was on the website. A thorough search for details revealed that
no such information existed on the AHPRA website.[40]
The website is also not updated on a timely basis.[41]
3.42
Concern was expressed that in the case of a health practitioner who is
not able to provide a work address, the registrant's home address is listed on
the website. Both the ACMHN and the Royal College of Nursing Australia pointed
to privacy and safety concerns.[42]
3.43
It was noted that the delays caused took health practitioners away from
their primary task of providing health care or they had to try to fit the calls
in between patients or during breaks in shifts. This situation was exacerbated
as AHPRA did not make arrangements for after hours or weekend phone contact
arrangements for practitioners. Some submitters, for example, Specsavers
suggested that AHPRA should provide these facilities, particularly at peak
times.[43]
3.44
Submitters generally agreed that the systems within AHPRA were unable to
cope with the volume of queries through the 1300 number or lodged through the
website. Health practitioners have become so frustrated with this situation
that they have sought intervention from the National Health Practitioner Ombudsman
who then provided the contact details for specific AHPRA staff.[44]
Other practitioners have resorted to going to AHPRA offices to lodge their
paperwork in person. Mr Stephen Milgate, Australian Doctors' Fund commented:
Our doctors will not work without registration, so they are
spending enormous amounts of time on this. One doctor as recently as two weeks
ago fronted the office of AHPRA with all her paperwork. Doctors are now
physically having to go in to do it. This is not the system that we were
promised.[45]
3.45
Attempts to escalate problems to more senior officials in AHPRA proved
to be a particular problem. The Australian Physiotherapy Association commented
that the AHPRA website did not provide phone, fax or email contact details for
branch offices. The Association stated that 'AHPRA wished to discourage direct
calls to branch offices while there was a functioning call centre'. However,
given the difficulties being experienced with the 1300 number, the lack of
alternative contact details contributed to the issues experienced by health
practitioners.[46]
The Royal Australian College of General Practitioners (RACGP) commented:
It has proved almost impossible to access state or territory
offices of AHPRA, except through a central number, which is always engaged. No
local contact persons are detailed on the AHPRA website, and RACGP staff have
resorted to sourcing email addresses through networking.[47]
3.46
Ramsay Health also commented that it was, and remains, very difficult to
contact key people within AHPRA who may be able to solve problems. All contact
with AHPRA is through a 1300 number so that large organisations like Ramsay
Health were not able to contact more senior personnel to address significant
problems.[48]
The AMA also commented that during the transition relationships with health
facilities appeared to instantly cease, restricting the ability of employers to
assist medical practitioners through the registration process.[49]
3.47
The Australian College of Rural and Remote Medicine provided similar
comments and stated that:
The most significant issue that has impacted the perception
of AHPRA's performance has been its decision to severely restrict access for individuals
and organisations to contact appropriate AHPRA officers personally to discuss
new processes or status related issues. There has generally been an absence of
personal contact and, by extension, a perceived absence of care and
responsibility within the system.[50]
Committee comment
3.48
The committee considers that the difficulties experienced in contacting
AHPRA were unacceptable and point to inadequate planning and resourcing. The
task which AHPRA is to undertake underpins the efficient provision of health services
within Australia. If health practitioners cannot access the body which is to
process their registration and to provide advice, the committee considers that health
services could be significantly compromised. This is unacceptable.
Provision of advice
3.49
When health practitioners were able to get through to AHPRA, they often
found that staff were unable to respond to their inquiry or just provided
generic advice.[51]
For some members of the ADA, clarification of advice was never provided.[52]
3.50
AHPRA staff were also unable to provide updated information on the
status of applications which pointed to problems with internal information
systems. Practitioners who were required to call AHPRA more than once, found that
staff appeared not to be able to access records of previous enquiries.[53]
3.51
Professor Lyn Littlefield, Executive Director, Australian Psychological
Society, commented that 'you just could not get good answers from AHPRA, with
staff not understanding the scheme and actually giving inaccurate information.
So I think the situation was really quite bad.'[54]
Ms Wett, Pharmaceutical Society of Australia, argued that 'staff that were
obviously new being under-resourced or untrained to respond to straightforward
queries'.[55]
3.52
This view was supported by other submitters including the Royal College
of Nursing Australia which stated that AHPRA staff handling customer enquiries
do not have the knowledge, skills and expertise to respond to enquiries
specifically relating to nursing and midwifery registration.[56]
Melbourne Medical Deputising Service (MMDS) also commented on lack of basic
knowledge of the registration process:
On more than one occasion, when necessary information was not
available from the AHPRA website, MMDS personnel have experienced 'I can't give
you that information because of privacy reasons' – central call centre staff
did not seem to know that a doctor’s registration status is public information.[57]
3.53
The Albury Wodonga Regional GP Network provided this comment:
The 1300 call centre personnel are unable to answer queries
despite asking the detail of your enquiry. Not once was a telephone call from
this office transferred to a knowledgeable staff member.
The website email enquiry option provided the same result as
the 1300 number. Not once has a website email enquiry from this office been responded
to since 1 July 2010.[58]
3.54
The AMA added its concern about the lack of follow-up by AHPRA when
practitioners sought advice:
The feedback was that they made the phone call. They often
waited on the line for extended periods of time to be answered. When they were
answered they did not receive return phone calls. When they rang back they got
someone else and they often had to start the process again. They did not
receive return phone calls for extended periods and often after a couple of
attempts they would call the AMA and say, "Please, do something; we're not getting anywhere."[59]
3.55
This example provided by the ACMHN illustrates some of the difficulties
faced by health practitioners:
I had to visit the AHPRA office on a few occasions because
they refused faxes, mailed documents and because they kept forgetting I needed
certain documents despite me asking several tiqmes "Are you sure there is
nothing else left for me to sign." This carried onto a rather
discomforting phone call where the administration asked me to send in proof of
my high school education (this is about a month after I had already applied for
registration). When I engaged her in conversation on the phone she commented on
my English saying "Oh my god your English is really good!" Considering
it's the only language I spoke I was confused and she explained, "Oh I
assumed from your name you were a foreigner and that's why we wanted to check
your education status." Now I am fully aware it was compulsory to prove
you went to high school in Australia, but you can understand how inappropriate
her comment was, and how unprofessional. In my application it was very clear I
was born and raised here, yet this lady couldn't check this basic inquiry and
decided to judge me by my name.[60]
3.56
Of significant concern to submitters was the provision of inconsistent
or incorrect advice by AHPRA staff. The AMA provided the example of registrants
being told to fill in the incorrect form:
As well as that, people were sent the wrong forms and when
they rang up they were told, "Just fill it out, everything will be
fine" and in fact it was not. I have had doctors tell me personally that
provisional registrants, who expected to be fully registered at the end of
their intern year, found that when they filled out the wrong form, after being
told to fill out the wrong form, maintained provisional registration not full
registration...[61]
3.57
The Pharmacy Guild of Australia commented that AHPRA had stated in its
media releases of 20 January and 25 January 2011 that practitioners whose registration
application has been received by AHPRA could continue to practice while their
application was being processed, even after the conclusion of the one month
grace period. However, the Guild indicated that it received anecdotal reports that
AHPRA phone operators were advising pharmacists that until their application
was processed, they were not registered and could not practice.[62]
3.58
Other evidence of inconsistent advice was also provided to the
committee. For example, the Australian Nursing Federation (ANF) stated that some
nurse members were told they could not renew as an Enrolled Nurse if they were
applying for registration as a Registered Nurse. Consequently, due to delays in
processing they were unable to work as an Enrolled Nurse while waiting for their
registration as a Registered Nurse. The ANF reported that other Enrolled Nurses
were advised by AHPRA to do exactly this.[63]
3.59
The Australian and New Zealand Association of Physicians in Nuclear
Medicine also provided an example of inconsistent advice provided to a practitioner
in relation to specialist radiology. AHPRA initially advised the individual,
who holds a Fellowship of the RANZCR but has limited registration as a
radiologist, that they could practice in nuclear medicine as it is part of
radiology. On this basis the specialist accepted a position and commenced
working as an advanced trainee (registrar) in an accredited nuclear medicine
training position. However, the specialist was informed by AHPRA that their
initial advice was incorrect and that the current registration limited the
specialist's practice to radiology only and that this would not include nuclear
medicine. To work in nuclear medicine, the specialist would have to lodge a new
application with supporting documents from RANZCR confirming his eligibility
for Fellowship in the speciality of nuclear medicine. The Australian and New
Zealand Association of Physicians in Nuclear Medicine commented that in
rescinding its initial advice, which in fact turned out to be the correct
advice, AHPRA provided no option for this specialist to continue to work while
the matter was resolved. The specialist was unable to practice for several
months until the matter was resolved. The Association called for a mechanism to
allow for temporary registration in such circumstances.[64]
3.60
In relation to training of staff, AHPRA submitted:
The staff members AHPRA needed to run the new National Scheme
were focused until the last minute on winding up old boards. With more than 80%
of staff from the previous boards joining AHPRA, the requirements of the implementation
timetables and legislative uncertainty in some states up to the final moment of
changeover, opportunities for staff training and preparation were very limited
before 1 July 2010.[65]
Committee comment
3.61
The committee was very disturbed by evidence that practitioners were
provided with vastly different advice from different AHPRA staff on the same
question. This points to extremely poor training being provided by AHPRA to its
staff. The committee finds this yet another example of poor planning: surely
AHPRA could have negotiated with the former state boards to allow training of
those staff who were transferring to AHPRA before the 1 July commencement date
to ensure that they were able to provide appropriate advice on the new scheme.
Registration processes
Initial registration and
re-registration
3.62
Many of the problems experienced by health professions related to the registration
process. These problems identified included:
-
lack of notification of renewals;
-
unacceptably long delays in processing registration renewals;
-
inconsistent or incorrect advice given by call staff in relation
to requirements for registration;
-
lack of updating of AHPRA internal processes so that incorrect
information, including lack of registration, remained in databases; and
-
loss of vital documents by AHPRA relating to payment and
registration.
Lack of notification of renewal
3.63
Submitters commented that one of the problems experienced by health
practitioners was the lack of renewal notices from AHPRA. This was, in part,
due to poor data contained in databases with the committee hearing of one
instance where a letter was addressed to a medical practitioner as 'Dr Jack
Smith, Adelaide'.[66]
Case study 3.3
I
am a Sydney GP and I didn’t receive notification of the expiry of my
registration. I had to make three phone calls because my sent email was ignored
and I had to make three phone calls to obtain the renewal papers. I was told by
an AHPRA clerk by phone to attend the office in George Street, Sydney in person
with completed papers to ensure that the renewal process was complete before my
expiry date. This is absolutely indefensible. Is this the wonderful new
efficient registration system we were all promised?
Source: Australian
Doctors' Fund, Submission 52, p. 7.
3.64
As a consequence of the problems being experienced, many of the
professional organisations stepped in to inform their members of the changes to
the renewal process. Submitters commented that members were very used to an
efficient system of receiving renewal notices under the old registration
system, and the poor AHPRA processes caused many late applications.
3.65
As AHPRA was focussed on a web-based registration process, registrants
needed a User ID and Password to submit applications. Those registrants who did
not receive notification did not have access to their User ID and Password to
enable online renewal.[67]
Even when a User ID and Password had been provided, some registrants still
could not use the online system as the system did not recognise this information.[68]
The Australian Psychological Society noted that contacting AHPRA in these
circumstances was almost impossible.[69]
3.66
Even after the initial problems with issuing renewal notices, Ramsay
Health Care Australia submitted that the process is still not working
efficiently:
The mailing of letters (for 31st May 2011 national renewal)
for nurses and midwives continues to be an issue (in that staff are not
receiving them and therefore cannot access the online renewal details without
the code provided for them in the letter). When discussed with AHPRA we were
advised that "There was [a] stuff up at the mail distribution centre in
Melbourne and that only some got away". No advice could be offered on when
these replacement letters will be issued.[70]
3.67
The ACMHN also commented that it had continuing concerns with the
registration process. Nurses will renew their registration in May 2011 and the
ACMHN stated that:
The uncertainty and apprehension within the nursing
profession about renewals in May 2011 is well founded. This date is not far
away, and some nurses still have not been notified of their renewal
requirements while others have received two emails.[71]
Processing applications
3.68
The major problem with the registration process was the length of time
taken to process applications. The Pharmacy Guild of Australia, for example,
commented that some registrants had to wait up to three months for their
applications to be processed.[72]
The ACMHN provided this response from an individual nurse who came to Australia
in October 2010 and is still unable to work as a nurse as AHPRA has not
processed her registration application:
I have also been met with poor case management, where my
documents have been lost or not internally sent as promised between Melbourne
and Brisbane office, information provided is not followed up or shared between
the team members who assess so info gets lost and not taken into consideration
of the assessment, The screening staff on the phone seems tired and untrained,
so it is always very unhelpful to telephone (both to main number and locally in
Brisbane), and the general unwillingness to guide and assist when I asked
(nearly begged) for assistance to understand why they aren't approving me.[73]
Case study 3.4
An Australian graduate and specialist who worked
overseas for four years applied for registration on December 22 2010, received
an email on February 22, 2011 from someone who was doing 'an initial
assessment' of his application for re-registration
Source: Royal
College of Pathologists of Australasia, Submission 24, p. 1.
3.69
The applications of health practitioners wishing to register for the
first time including overseas trained practitioners have taken inordinate
amounts of time to be processed. In a case provided to the committee by the MMDS,
an overseas trained doctor applied on 5 August 2010 for registration. As at
14 April 2011, registration had not been finalised. A particular concern, as
a result of the inordinate amounts of time taken to process applications, is
that the Certificate of Good Standing, a requirement for overseas doctors,
expires after three months. MMDS noted that in many parts of the world
obtaining another is 'both difficult and dangerous' and adds to costs and
further delays.[74]
3.70
This situation was exacerbated by registrants not being provided with
confirmation that their registration documentation had been received and/or
confirmation that it had been processed.[75]
Many registrants were forced to ring AHPRA, which added to the delays at call
centres, in an attempt to ascertain if their applications had been received and
processed. The ACMHN commented that the lack of confirmation of registration
also created a situation where some nurses believed that they had successfully
renewed their registration when AHPRA had failed to receive the renewal
application. The ACMHN noted the case of a nurse who had posted her renewal and
assumed that it had been received by AHPRA; she became aware that the renewal
had not been received when her employer advised that her employment was to be
terminated because she was not registered.[76]
3.71
A further matter raised by the Royal College of Nursing Australia is the
delay in providing a hardcopy certificate of registration. This can take more
than four weeks and as noted by the Royal College of Nursing Australia, casual
employees are particularly affected when no hardcopy certificate has been
issued. In this case, pages from the AHPRA website must be printed off and then
certified as a true copy for provision to employers.[77]
Case study 3.5
My
name is Pharmacist No.7. I forwarded my registration renewal in October 10. In
February 11 I had received no response. When I checked the website my date
registration date had expired. I filled out another application and paid again
only to be contacted a few weeks later to say they had received my application
in October 10 but were still processing it and now no longer required my second
application. Then late March I was notified that my credit card payment was
declined because the card date had expired at the end of February 2011. I was
required to submit a new payment before my registration would be processed. My
credit card was fine in October 2010, Nov, Dec, Jan and all of February but
because of AHPRA's delay of more than four months in processing the payment
when they finally did my card had expired. So for the third time I have sent in
information to try to re-register. To date I still have no confirmation of
registration. As the owner of a pharmacy this is unacceptable.
Source: The Pharmacy Guild of
Australia, Submission 53, Attachment A, p.22.
3.72
The delays experienced by registrants pointed to fundamental problems in
AHPRA's systems. The problems ranged from the online registration system using
the American dating system for recording the date of birth (mm/dd/yy);[78]
to poor internal processes which resulted in loss of renewal applications;[79]
loss of documents provided with applications;[80]
and loss of cheques for the payment of registration.[81]
The AMA also pointed to the use of generic application forms 'that were not fit
for purpose, which added to the difficulty and time for registrants to complete
forms correctly and for AHPRA staff to process the applications'.[82]
3.73
Dr Sorimachi, Pharmaceutical Society of Australia, provided this
example:
We had one example where two pharmacists in a pharmacy
practice together lodged and paid on the same day. One received documentation
and one did not. That one contacted, did not get any feedback and then went
back to pay again and was asked, 'Why are you paying again?'
So I think there is a gap in the processes at AHPRA in making
sure that there is a consistent delivery to the professions.[83]
3.74
The ANF also provided examples of poor internal processes. These
included letters being sent to individuals informing them that they would be deregistered
as they were not renewed, when in fact they had renewed their registration but
AHPRA had not updated the register. The ANF stated that this caused distress
for nurses in this situation.[84]
3.75
Evidence provided by Ramsay Health gives an indication of the size of
the problem. Ramsay Health employs approximately 22,000 nurses across 66
hospitals. 234 nurses and midwives reported, since 1 July 2010, that they did
not know whether or not they were registered. While registration fees had been
paid, and receipts provided, their names did not appear on AHPRA's website.
Ramsay Health noted that these were the cases which had been escalated to the
central office, other cases may have been dealt with at a local level. Ramsay
Health indicated that these nurses and midwives could not be employed in this
capacity and were employed in other capacities within the organisation until the
registration issues were finalised.[85]
Ms Spaull, Ramsay Health, commented that at the time of registrations in
Victoria, she committed more than 89 hours in one week to deal with
problems arising from the registration process.[86]
3.76
The Royal College of Nursing Australia noted that while it may take a
significant period of time to confirm registration, the fees are deducted from
registrants' accounts soon after lodging their registration or renewal
applications.[87]
3.77
The AHPRA processes were so flawed that operators could not provide an
accurate update on the status of applications, to the extent that some
pharmacists were unable to confirm if their paperwork had been received by AHPRA.[88]
3.78
Mr David Stokes, Australian Psychological Society, summed up the
failures of the registration system as follows:
I guess the renewal process really highlighted their
unpreparedness for this process. We had some gross injustices on both our
members and our members of the community that followed on as a consequence.
Perhaps the worst was experienced in Queensland. We did manage to rescue a
renewal phase in Victoria and Tasmania—it could have been a bit more than it
needed. The issues that really came up in that renewal process were the failure
of members to receive a registration renewal form through any of the multiple
ways that they attempted to send these out; they just never received any of
them. Not only was that failure very potent for many of them but also there was
a strong implication that it was a failure of the registrant and not of the
process. [89]
Case study 3.6
I am one of the many pharmacists who were completely
frustrated by the inadequacy of AHPRA. Copies of my email enquiry and
consequent emails follow.
As you are no doubt aware, the 1300 419 495 phone
enquiry line was unavailable for enquiries during January 2011 and
communication could only be made by the online enquiry email. Although the
“customer service team” advised me on January 19th my enquiry would be
escalated, I had no further communication from them until 18th February 2011.
In early February I eventually had an answer on the
1300 number and was put through to the NSW office and was told “yes” my
application had been received and would be processed shortly.
Are we to go through the same thing again in December 2011?
Copies of emails sent to and from AHPRA:
18th January 2011 via Online Enquiry Form
Registration application posted XXXX P.O. 6/12/2010.
Phoned 1300 419 495 23/12/2010 and again 13/01/2011. Spoke to XXXX. She
informed me I would have received an SMS or email if Pharmacy Board had not
received my application-none received. Still currently listed as registered
till 31/12/2010. Please confirm by email current status of my application As
31/01/2011 is fast approaching I am concerned about my status as a registered
pharmacist
19th January 2011 Reply from AHPRA to Online enquiry
Dear Pharmacist 4
Thank you for contacting AHPRA. Your enquiry has been
escalated to an information/registration specialist who will advise you via
email accordingly.
Regards
The Customer Service Team, AHPRA Enquiry Contact
Centre
18th February 2011 Email from AHPRA
Dear Pharmacist 4
This email is to advise you that your application to
renew your registration has been finalised by AHPRA.
You will receive a tax receipt and a certificate of
registration from AHPRA within 4 to 6 weeks. In the meantime, if you need to
confirm your registration status, you can search the public register at...etc
Source: The Pharmacy
Guild of Australia, Submission 53, Attachment A, p. 20.
Fast track procedures
3.79
Following the issues with the registration process, AHPRA established a
'fast track' system to enable health practitioners to be restored to the
register without going through an entirely new registration process. However,
it appears that AHPRA staff were not fully trained in these procedures and the
Australian Physiotherapy Association commented that 'communication with health
practitioners around the procedures was flawed' and the 48 hour turn-around
time was a minimum with some fast track procedures taking significantly longer.[90]
The Australian Psychological Society also commented that 'they instituted a
fast track system which for many people was in no way fast tracked; it still
took a month to get a renewal through even on the fast-track system'. [91]
Errors in registration information
3.80
The Australian College of Rural and Remote Medicine commented on the
lack of quality control of data resulted in the registers containing inaccurate
and/or missing information about their qualifications and status, despite
accurate information being provided by the health practitioner and the College
concerning fellowship status. This was particularly the case where registrants
were described as 'general' rather than 'specialist'. The College concluded:
Data discrepancies such as these also have the potential to
substantially undermine the professional standing of the doctor with patients
and amongst the profession (e.g. when agencies check the register to validate
credentials as part of employment, teaching or other professional
applications).[92]
3.81
The problems of incorrect listing of qualifications was also noted by
the RACGP. The RACGP further commented that the register listed some
practitioners as lapsed when in fact they had renewed their registration while
other who had not renewed their registration remained registered on the public
database.[93]
The Australian and New Zealand Association of Physicians in Nuclear Medicine
also raised this matter and noted that when an error is pointed out to AHPRA it
requires resubmission of paperwork that has already been provided and therefore
the medical practitioner is unable to renew registration online, thereby
creating further delays and continuing inaccuracy of the online registration
record.[94]
3.82
Ramsay Health Care Australia reported that up to 30 staff received
incorrect registration types in their certificates. Seven of these staff were
told by AHPRA staff 'not to worry about what it says on the public register or
certificate'.[95]
3.83
The AMA also provided evidence of inadequate advice from AHPRA in
relation to incorrect information on the register:
To add to the problem, AHPRA's on line register lists medical
practitioners who have made the applications for renewal, but have expiry dates
well before the current date. Employers are informed to ignore the expiry date
and that if the medical practitioner appears on the register, they can be taken
as being registered.
This has been counter intuitive for hospitals and other
employers who have been advised to check against the medical register.[96]
3.84
The AMA concluded that 'the integrity of the register has been corrupted
and employer confidence in the information on the public register is significantly
diluted'.[97]
Case study 3.7
Dr C - Vocationally Registered doctor providing 35
years medical service in solo rural GP practice was very anxious that
registration renewal was paid, however, was stated as 'expired' on the AHPRA
website for months after payment had been made. This doctor was taking leave
and was very concerned regarding registration status upon return from leave.
Source: Albury
Wodonga Regional GP Network, Submission 30, p. 2.
3.85
Dr Hambleton, AMA, noted the problems arising from the flawed
registration process: many hours of health professionals' time have been
devoted to dealing with the problems, rather than direct patient care. The
biggest concern has however, been the uncertainty over registration status. Dr
Hambleton commented:
Even today some people appear on the national register with
expired registration dates but are told as long as they are on the register
everything is okay. This is certainly counterintuitive to a modern, efficient
registration system.[98]
3.86
For many, the first indication that they were not registered came when
Medicare informed the health practitioner that they were no longer registered.[99]
Ms Locke, Australian Physiotherapy Association, provided the details of
one such case:
A Queensland member received a call from Medicare on 14
January to advise that she was not currently registered and that Medicare was
aware there was a problem. They were making a number of these phone calls, and
said that they would hold her provider number until she could get her
registration fixed. She received a letter from AHPRA advising that registration
had lapsed on the same day even though she had a facsimile transmission record
of her renewal notices being sent in November.[100]
3.87
AHPRA indicated that of the registrations due between 1 July 2010 and
31 March 2011, the registration of approximately 24,894 practitioners
lapsed.[101]
Mr Martin Fletcher, Chief Executive Officer, AHPRA, indicated that:
We write to the practitioner to advise them that their
registration has lapsed. So, just to reiterate, there is a registration expiry
date; the practitioner then has a month after the expiry date called ‘the late
period’ to submit their application, and provided they have submitted their
renewal application in that period, they can continue to practise. If they have
not submitted, we write to the practitioner to advise them that their registration
has lapsed and we also have at the moment a protocol where we, on a regular
basis, transfer those data to Medicare...
One of the things we did was set up a hotline so if Medicare
contacted them and they said they had not heard from AHPRA, they had a dedicated
hotline that they could ring.[102]
Students/graduates
3.88
Difficulties have arisen with the processing of registrations for new
graduates. The ANF commented that the processing of applications takes place in
the state or territory where the course leading to initial registration was
undertaken. This is irrespective of where the person was living whilst
completing the course and where they are living at the time of their
application for registration. This has caused delays in the registration
process and in many instances new graduates were unable to commence graduate
programs. The ANF commented that both graduates and employers were considerably
compromised and in some cases the offer of employment was withdrawn due to the
graduate's inability to provide evidence of registration.[103]
3.89
The Royal College of Nursing Australia also noted that newly graduated
nurses who attempt to enrol in post graduate courses are unable to do so
without proof of their registration.[104]
3.90
Another matter of concern in relation to new graduates was the lack of a
pro rata fee for registration. This matter was raised by the ANF which stated
that initially there was a provision for a pro rata fee. However, on 1 November
2010, 'without consultation or notice', pro rata fees were no longer allowed. This
meant that if an initial applicant finished their course at the end of the year
they pay an application fee in addition to a full 12 month registration fee
despite the fact that they will only be registered for a part period. The ANF
provided the following example:
An ANF member has lodged a written complaint with AHPRA as
they had to pay $115 to apply, then $115 for registration as a nurse, and
another $115 for registration as a midwife. Although the ANF member was
registered on 3 February 2011 which meant they would be required to renew by
31 May 2011 (four months), they were charged for 12 months.[105]
3.91
The ANF commented that the AHPRA website indicates on initial
registration both an application fee and a fee for annual renewal of
registration apply. 'Annual' by definition, means a year or returning once a
year. The ANF went on to state that it acknowledged that the process for pro
rata fees is only until all states are in line with the same national annual
review date. However, the processing for pro rata fees should have been
straight forward.[106]
3.92
AHPRA has made changes to the registration process and these are
outlined in this chapter. AHPRA also commented:
A core challenge in health practitioner regulation is
balancing the at times competing priorities of workforce supply and the safety
and quality of health services delivered to the Australian public. Assessing
and making determinations about eligibility for registration is not just an administrative
process. To undertake its statutory role responsibly, AHPRA makes sure its operational
processes support a thorough assessment of applications for registration. It
also aims to do this in a timely way, noting that there are no externally
agreed performance benchmarks for registration processes beyond the maximum
period specified in the National Law.[107]
Committee comment
3.93
The committee again reiterates the importance of efficient registration
processes to the provision of health care to the Australian public. The
evidence points to extremely poor processes, in particular, the lack of
confirmation of receipt of applications. It is normal business practice to
acknowledge receipt of applications and payments. The committee considers that
this matter should not have been overlooked when processes were established. In
addition, the deregistration of practitioners without notification was
unacceptable and pointed to significant system failures.
3.94
The committee also notes the comments made by AHPRA about balancing
workforce supply and protection of the public. However, the committee considers
that in the transition period, the reduction in workforce supply was not a
function of protection of the public but of AHPRA's system breaking down.
Funding of AHPRA
3.95
A significant concern raised in the evidence was the issue of the funding
of AHPRA. Professor Smallwood, Forum of Australian Health Professions Council,
commented that under the previous accreditation scheme government provided
funding assistance. However, the NRAS, following initial funding by the
Commonwealth, is a user pays scheme. Professor Smallwood went on to comment
'the issue of any immediate change of government support will really mean that
registration fees and accreditation fees may need to rise sharply'.[108]
3.96
The Australian Dental Association indicated that fees for its members
had increased.[109]
Professor Jackson, RACGP, also commented that fees had increased. Professor
Jackson went on to state that these extra costs were 'for what is far less
effective registration work than we have had previously is also an ongoing
problem as those costs will have to be passed on to our patients'.[110]
The AMA also supported this view and stated that registration is costing more
and 'has not delivered an efficient system to justify the increase'.[111]
3.97
The AMA went on to comment:
No economies of scale has been identified. Under the previous
State and Territory boards there was a surplus of funds despite the registration
fees being approx 50 per cent less than they are now. Despite this surplus being
transferred to AHPRA as part of the national contribution, the registration
fees for medical practitioners increased significantly.
The medical profession will not tolerate any further increase
in the registration fees to cover the increasing costs of the scheme. AHPRA
must now perform its functions within the existing budget by working with the
respective professions to identify the efficiencies of each of the registration
processes and develop business protocols to ensure consistency around the
country.[112]
3.98
Submitters stated that if AHPRA requires more resources, then the
initial estimates for the funding needs of the NRAS were unrealistic.[113]
Mr Ian Frank added that funding for similar bodies overseas is much higher:
It is perhaps worth noting that, if you take all the 10
health professions together that are involved in bringing together the scheme
and you look at the 85...different regulatory bodies that existed across the
states and territories to look after those, none of those could be described as
being flush with resources. We work with colleagues in Canada and the US and we
know that the resourcing of the regulatory process in Australia is
significantly lower than it is in those two countries alone. So the resources
that already existed on the ground prior to NRAS were probably fairly thin, you
might say.
To then create something on the scale that they have talked
about here by simply saying, 'Oh, well, we'll take all of the resources that
currently raise the registration fees, assets et cetera and bring them across
into the new system but to a completely different new system,' I think suggests
that perhaps that had been underestimated to start with, because if you try to
build something totally new from the ground up it is going to be more expensive
than just finetuning existing systems that are already out there. As Professor
Smallwood has already said, for those of us who have worked with mutual
recognition and worked in IT systems before, the thought that $19 million was
the seeding funds for this would probably not even cover the costs of IT
consultants doing this sort of development work. So we had concerns from the
outset that that was probably a bit of an underestimate of the complexity and
of the need that would be required to support this exercise.[114]
3.99
It was argued that health practitioners should not be asked to provide
additional funding, however, as the AMA commented 'in the event that AHPRA
requires even more resources, we believe the Health Ministers will not provide
the additional funding required, but instead seek to increase registration fees
to cover this'.[115]
The Optometrists Association of Australia were also of the view that any
additional funding should be provided by government:
Similarly, if additional resources are needed from time to
time to establish the national scheme as intended then those resources should
be provided by governments as agreed originally when the decision to proceed
with national registration was announced. While ongoing operations were to be
funded from registration fees the costs of establishing the scheme were to be
met by governments and resolving start-up problems such as experienced thus far
should be accepted as part of establishment.[116]
AHPRA's response
3.100
In evidence, AHPRA acknowledged the issues that had arisen since 1 July
2010. Mr Martin Fletcher, CEO, AHPRA commented:
AHPRA has recognised that there have been shortfalls in our
service to practitioners in the early days of the scheme. We are now embedding
robust systems which are getting stronger all the time and of course our
systems not only need to work well from an administrative point of view, but
they also need to make sure that we are discharging the objectives of the
national law around public protection and patient safety.[117]
3.101
AHPRA's submission provided details of the initiatives it had taken to
address the problems experienced during the implementation phase of the NRAS,
and these include:
-
data: more than 500,000 data records were cleansed,
processed and migrated as active practitioner records into the AHPRA database. Despite
these efforts to establish accurate and complete records for each registered practitioner
and each profession, there were a range of issues with the accuracy and completeness
of the inherited data which became apparent as AHPRA renewed the registration
of practitioners. AHPRA has undertaken significant work on data quality,
including a data audit and continues to ask practitioners to update their
information to ensure the integrity of the data AHPRA holds;[118]
-
service delivery: improvements in service delivery have
been made through:
-
addressing problems with contacting AHPRA, for example, through
boosting resources for customer service teams and establishing new back-up and
peak demand capacity;
-
improving the renewal system to decrease the incidence of lapsing
of registration, for example, through establishing a fast track application
process;
-
improving practitioner awareness of new registration and renewal
requirements through work with professional associations, employers, education
providers and students;
-
addressing delays in providing certificates for example, through
establishing an online process to enable registrants to request a certificate;
-
developing and embedding standard operating processes;
-
improving services for employers checking employee registration
online; and
-
improving online services including a registration tracking
process and expanding the range of online services.[119]
3.102
In particular, AHPRA noted that it has implemented a fast track application
process for registrants whose registration has lapsed but who wish to remain in
practice. This fast track process is open for one month after the end of the
late period. In the first year of the NRAS, there are no additional
registration fees for the fast track registration process. Because these
practitioners have been registered until very recently, the fast track process does
not require proof of identity; does not require verification of qualifications
(if this was recorded as part of previous registration); does not require
verification of English language skills; and does not require registration
history or work history. The process does require practitioners to make
declarations about their continuing professional development and criminal
history. AHPRA indicated that these applications are usually finalised within
48 to 72 hours of receipt of a complete application, provided that the
practitioner has not made an adverse criminal history declaration.[120]
3.103
AHPRA also provided information on how it is approaching the renewal
process for the 330,000 health practitioners who are renewing in May and June:
We have substantially ramped up our communications and
approach to renewals, so we are looking at renewals in the form of a campaign.
Our theme has been to renew on time, online. We are using a variety of emails,
letters, working with employers and professional associations to raise
awareness and understanding. I just looked at the 210,000 practitioners who are
due to renew their registration by the end of May, as one example. We have
email contact details for 160,000 of those practitioners. We have now sent
three email reminders, which totals 350,000 emails to those practitioners. In
addition, we have sent 169,000 letters where people have either not responded to
the email or did not have their email contact details with us, and as of
yesterday more than 57,000 of those registrants have already renewed, which
represents 27 per cent of those registrants, so that is a substantially ramped
up approach to making sure that people understand their obligations to renew on
time and have timely communication around that.[121]
3.104
In evidence AHPRA also indicated a number of additional matters it has
addressed. In relation to registration certificates, AHPRA stated that from the
middle of the year a new online service will be introduced so that a
practitioner can log on to the AHPRA website and print their own registration
certificate. Graduates, from approved programs of study, will also be able to
register online from the middle of 2011.[122]
3.105
In order to address criticisms concerning lack of national consistency,
Mr Martin Fletcher, AHPRA, provided examples of the work being undertaken
by AHPRA:
...we have developed standard operating procedures in all of
the key areas around both management of registrations and notifications, and we
would be more than happy to table information about that if that would be of
interest to the committee. We have invested substantially in a program of work
that we call 'business improvement' led by a national director which is
focusing on issues such as making sure our IT systems do what they need to do
to support the work. We have the business processes clear around how we manage
our business of registration and of course we invest in things like staff training
and the like.
A final example is work that we have been doing with our
directors of registration, which we have in each of our state offices, and our
directors of notification around things like standard templates, standard
letters, forms and the like, all of which are important parts of consistency,
and of course we work very closely with national boards in how we do that.[123]
3.106
AHWMC commented that since its formal establishment on 1 July 2010,
AHPRA has reviewed and improved its capacity and ability to undertake its key functions.
An example of this is the recent appointment of a Director of Business
Improvement and Innovation in acknowledgement of the need for AHPRA to build
its capacity in business improvements.[124]
3.107
In addition, AHWMC informed the committee that at ts meeting of 17 February
2011, the AHWMC agreed that action needed to be taken to address the concerns
being raised about registration processes during the transition to the new
Scheme. It was agreed to provide additional support and expertise to assist
AHPRA in managing the registration function. Additional monitoring of AHPRA has
been introduced and AHPRA will be required to report to future meetings of
health ministers.[125]
3.108
The AHWMC concluded that:
Whilst it is clear that there have been some operational
difficulties in the establishment of NRAS, these have largely been the result
of bringing 10 professions across eight jurisdictions into a system that was to
be operational from day one without any interruption to service provision...
Any difficulties in bringing these systems together should
not overshadow the importance of this key health workforce reform and the role
of AHPRA in achieving a national scheme with a focus on the health and safety
of the public and nationally consistent standards for health practitioners. The
Scheme has significant potential to deliver improved public protection,
improved professional standards, greater workforce mobility and better quality
education and training and AHPRA is well placed to play the key support role in
delivery of these benefits.[126]
3.109
The Department of Health and Ageing also indicated that the Commonwealth
had offered support to AHPRA: the chief nurse is available to AHPRA to discuss
nursing issues; Medicare has offered to pick up call centre overflows; and
assistance has been offered with the integrity of AHPRA's IT systems.[127]
3.110
In relation to funding, AHPRA commented:
The intent into the future is that AHPRA is funded entirely
from registration fees. The space we are in now is the issues associated with
start-up and government has both provided money and accepted a qualified
broader responsibility to assist AHPRA where it is agreed that it needs that
assistance in dealing with the start-up costs.[128]
3.111
The AHWMC also commented on the funding issue and stated:
While governments support NRAS and some have provided
additional financial support to AHPRA in the establishment phase NRAS should
become self sufficient and there should not be an ongoing reliance on Commonwealth,
state and territory government funding. This means that the financial
obligations of AHPRA and the National Boards need to be fully considered when
setting registrant fees.
As has been noted above, AHPRA and the National Boards are
reliant on registrant fees for funding, and at the present level AHPRA has
resource constraints which limit capacity and performance. It is important that
financial sustainability is an element in all decisions about the structure and
scope of NRAS.[129]
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