Scope of Practice Review Issues Paper 2 – Findings, Proposed Reforms, Peak Body Responses
With the release of Issues Paper 2, the Scope of Practice Review shifts to a solutions focus.
The second phase of the Scope of Practice Review now complete, The Department of Health and Aged Care has published Issues Paper 2: an overview of the evidence collected from the first two rounds of consultations, paired with a set of primary care reform options that extend across the axes of workforce planning, regulation, and funding.
Issues Paper 2 is solutions-focused with a call-out for further submissions, and it reads well for AHPs who care about working to top of scope in multidisciplinary primary care environments; the most vocal reactions to it have so far come from medical professional bodies RACGP and the AMA—more on this below.
Led by Professor Mark Cormack, Unleashing the Potential of our Health Workforce – Scope of Practice Review was commissioned in response to the February 2023 Strengthening Medicare Taskforce Report, and has since been examining the available evidence concerning benefits, risks, barriers and enablers to health practitioners working to their full scope of practice—with a view to improving the efficacy of primary care in Australia.
For a better understanding of the background, have a look at our previous commentary on the Strengthening Medicare Taskforce and the Scope of Practice Review here.
The Review has so far been positively received by allied health professional peak bodies; Allied Health Professions Australia (AHPA) was guardedly optimistic in its February statement. According to the Scope of Practice Review, consultation respondents have thus far been 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.”
Allied health professional peak bodies which have made submissions to the Review include Speech Pathology Australia, Australian Physiotherapy Association, Optometry Australia, Exercise and Sports Science Australia, Australasian College of Paramedicine, Australian Orthotic Prosthetic Association, and Occupational Therapy Australia.
The second consultation and online submission process was held between January 23 and March 8, 2024, and received 247 online submissions, in addition to a series of face-to-face and virtual consultations which were attended by over 500 participants.
Issues Paper 2 – Findings
Based on both rounds of consultations, the Review has identified a range of challenges preventing primary care health professionals from working to their full scope:
- Poor recognition of the skills that primary care health professionals have: “…one of the most common comments received by consumers and health professionals alike during consultation.”
- Inadequate preparation for primary care. Lack of exposure to primary care environments during their training leaves health professionals under-prepared.
- Legislation impedes health professionals working to their full scope: “Legislation and regulation were acknowledged as fundamentally shaping scope of practice. Stakeholders identified overly restrictive or specific legislation as a significant impediment to primary care professionals working to their full scope.”
- Funding and payment arrangements impede health professionals working to their full scope: “Current funding mechanisms were noted to disincentivise some, particularly non-medical, health professions from contributing to primary care teams, due to the inability to access fee-for-service arrangements.”
Issues Paper 2 – Proposed reform options
Issues Paper 2 outlines system and policy reforms available to address the barriers to primary healthcare professionals working to full scope.
The paper has proposed eight reform options under three broad themes: workforce, regulation, and funding.
Essential to all of the reforms listed below is the ‘National skills and capability framework and matrix’, meaning the skills of each healthcare profession need to be mapped out.
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Workforce design, development and planning
- National skills and capability framework and matrix. Identifies the specific skills and capabilities of health professionals at entry to practice that informs local authorisation processes, the composition of the care team, and workforce planning consistent with community need. (This informs all of the reform options listed.)
- Develop primary health care capability. Ensure health professionals develop the skills needed to work in primary healthcare.
- Early career and ongoing professional development, including multi-professional learning and practice.
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Legislation and regulation
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- Adopt a risk-based approach to regulating scope of practice to complement protection of title approach, and
- Set up an independent, evidence-based assessment of innovation and change in health workforce models.
- Harmonise drugs and poisons regulation across states and territories to support a dynamic health system.
- Adopt a risk-based approach to regulating scope of practice to complement protection of title approach, and
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Funding and payment policy
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- Develop and implement funding and payment models that will create incentives for multidisciplinary care teams working to full scope.
- Direct referral pathways supported by technology, with the intention of improving collaboration and communication.
Responses and reactions
Allied Health Professions Australia (AHPA) are currently reviewing the document, stating that they will be working “with the self-regulating health professions to identify any areas that specifically impact their regulatory roles and any proposals for future reforms.”
Writing for Croakey Health Media, Charles Maskell-Knight said, “Decoding all this, the problem is that under the current system GPs act as monopoly providers, gatekeepers or supervisors for many services that could be provided within the scope of their training by other health professionals.”
In an article penned for The Conversation, health economist Stephen Duckett observed, “Do I really need to see the GP every time I need a prescription renewed for my regular medication? This is the nub of the “scope of practice” issue.”
Reactions to Issues Paper 2 from medical circles have not been positive. The concern amongst Australian GPs—as articulated by the AMA, RACGP, AusDoc, and the Medical Republic—that increased scope of practice for non-medical health professionals in primary care settings will lead to fragmentation of care, rather than enhanced primary care outcomes, remains unchanged.
The paper’s mention of: direct referrals between professions; mooting UK and Canadian funding models for allied health services; and pivoting to a risk-based regulatory approach, appear to have raised the alarm with some medical professional bodies.
In a pre-emptive shot across the bow, RACGP President Dr Nicole Higgins stated the week prior to the paper’s release: “Our members are very concerned the current review appears to be giving serious consideration to a model of care that would reproduce the failures of the UK health system.”
In a statement to The Medical Republic, following the release of Issues Paper 2, Dr Higgins said, “I’ve already told the Health Minister that there are 40,000 GP members who are really going to push back.”
The third phase of the Scope of Practice Review is underway, and is open to public submissions until May 26. | View a series discussions around allied health scopes of practice on the Advanced Practice Collective community of practice.
