Allied Health Insights Vol.3 No.4: Understanding the Scope of Practice Review in Australia and what it means for Allied Health

With the first phase of the Scope of Practice Review complete, The Department of Health and Aged Care has published Issues Paper No.1:  an exploration of the available evidence concerning benefits, risks, barriers and enablers to health practitioners working to their full scope of practice.

The first online submission process was held from September 11 to October 16 2023 and received more than 700 contributions, and while majority of submissions came from nursing, midwifery, pharmacy and medicine, all of the “key”—as worded by the Issues Paper—allied health professions were identified in submissions literature.

The list of allied health profession peak bodies which made submissions includes Speech Pathology Australia (SPA), Australian Physiotherapy Association (APA), Optometry Australia (OA), Exercise and Sports Science Australia (ESSA), Australasian College of Paramedicine, Australian Orthotic Prosthetic Association (AOPA), and Occupational Therapy Australia (OTA).

According to the paper, (and somewhat unsurprisingly), “Consultation respondents were broadly divided along professional lines about whether non-medical professionals working to full scope of practice would offer benefits compared with the existing GP-centred primary healthcare model.”

Occupational Therapy Australia‘s submission advocated for enhanced recognition and utilisation of occupational therapists across healthcare settings, emphasising their role in mental health and urging for expanded OT services under Medicare programs. It highlighted a workforce survey indicating scope of practice significantly affects OTs’ job satisfaction and retention, with only 68% feeling they work to their full potential.

Speech Pathology Australia advocated for expanding speech pathologists’ referral abilities to ease client, family, and GP burdens. They proposed permitting speech pathologists to refer clients for audiological assessments under Medicare items 82300-82332 and to cross-refer to allied health professionals for up to eight sessions for conditions such as autism spectrum disorder under Medicare plans.

Optometry Australia submitted that optometrists are hindered by funding, regulatory, technological, and cultural barriers, preventing full scope practice. Advocating for international comparisons to enhance scope, OA noted the potential for non-ophthalmologists to prescribe medications and perform intravitreal injections, underscoring the challenge of expanding collaborative care models.

The Australian Physiotherapy Association included five priorities in its submission, spanning funded first contact, direct referrals, inclusion in Medicare Urgent Clinics, leading non-operative pathways, and the leveraging of proven advanced practice models in secondary and tertiary care.

Issues Paper No. 1 – Key Takeaways and Reactions

The paper focuses on health professionals who currently provide or have the potential to provide primary care, and delves into the available evidence regarding the benefits, risks, barriers, and enablers for health practitioners working to their full scope of practice.

Based on the first phase of consultation, the Issues Paper outlines a number of opportunities for improvement, with the possibility of further exploration in the second phase. Some of these—prescribing rights and referral authority in particular—are contentious.

1. Harmonising drugs and poisons legislation across states and territories—a polite way of saying prescribing rights for non-medical professions is seen as a potential policy solution and will be further explored in the second phase. (The paper points out that the Non-Medical Prescribing Framework (UK) has created efficiencies in the UK health care system.)
2. Shifting scope of practice regulation to focus on areas of overlap based on competencies and tasks, rather than through named professions.
3. Reviewing the use of named professions and protected titles in legislation.
4. Referral authority across primary health care professions: “A combination of regulatory and funding policy changes will likely be required to maximise access to referrals across all professions, including non-medical professions.”
5. Reviewing regulation of self-regulated and unregulated health workforces. The paper suggests an alternative policy option for additional unregulated workforces or self-regulated professions to become regulated under the National Alliance of Self Regulating Health Professions (NASRHP).
6. Streamlining endorsements for advanced or specialised practice roles for non-medical professions.

Allied Health Professions Australia (AHPA) sees both opportunities and risks in above key areas, particularly valuing greater prescribing and referral rights. Greater access to prescribing and referral rights is a priority for several professions—direct referral, in particular, has been highlighted as a focus for this next phase of the review.

AHPA aims to identify all relevant professions and referral pathways for the review team: “Greater access to prescribing and referral rights are a significant opportunity and priority for a number of professions. We hope to support progress with both.” On the subject of regulating self-regulated and unregulated professions, AHPA notes this to be a complex area, with views differing across professions, stating that it will collaborate with NASRHP and relevant professions to develop responses related to this regulation during the second phase of the Scope of Practice Review.

There’s growing concern amongst Australian GPs that increased scope of practice for allied health professionals in primary care settings will lead to fragmentation of care, rather than enhanced primary care outcomes.

Writing for AusDoc, Paul Smith notes: “The next big thing? Let allied health refer directly to specialists. The idea is being floated by the Federal Government’s scope of practice review.”

Speaking at an AMA webinar on January 30, AMA vice-president Dr Danielle McMullen told Scope of Practice Review lead Professor Mark Cormack, “I see why GPs are really scared that they’re going to fall through the cracks, and that the solution will be seen as task substitution by others.”

Former RACGP president Karen Price scathingly tweeted: “GP Scope of practice is on the Gov agenda. Sadly I note there is a rush to identify scope by task=Nonsense. GP care is whole person science which has a life course trajectory. ‘Task’ suggests a complete lack of understanding of Generalism =different discipline to Hospital care.”

The second phase of the Scope of Practice Review is underway, and is open to public submissions until March 8.