Student and registrar questions answered by Psychology Board and CCN

Brin Grenyer, Chair of the Psychologist's Registration Board of Australia, has kindly answered a number of questions posed by CCN student members. Brin's responses are listed below each question below (BG). I have added some notes on behalf of the CCN to the first 3 questions (FB)

1.     Are 'General Psychologists' able to practice under the Medicare scheme if not enrolled in the Neuropsych Registrar Program?

BG: Yes

FB: However, with the Better Access to Mental Health scheme, they are only able to offer items under the FPS, or "focussed psychological strategies." Neuropsychological assessments and cognitive assessments are not included under these items.

2.     Are 'Neuropsych Registrars' able to practice under the Medicare scheme?

BG: Yes if they have a Medicare number (as general medicare providers not providers of clinical services)

FB: Again, under the FPS items, not the clinical psychology items. The legislation for the Better Access items clearly state the types of services that psychologists can offer under these items. They are not typically the kinds of services offered by neuropsychologists. The permitted services do not include neuropsychological assessments. Although some psychologists have called the Medicare help line enquiring about providing neuropsychological assessments under the items, and have been told that they are not excluded, this does not mean that they are included. The permitted services are listed in the item description. Any services not listed in the legislation for the item are not permitted. Medicare items do not usually list the excluded services - imagine how many there would be!!! Providing services under Medicare codes that do not cover these services is wrong, even if a GP sends a referral for neuropsychological assessment to be done under the Better Access scheme. Doctors have been charged with fraud for billing for services that are not covered under the item used. They have had to pay back thousands of dollars if they have billed for services under the wrong code. Don't even think about doing it in order to get more neuropsychological experience. 

The CCN has been working hard with the APS for the last 6 years to get our services covered under Medicare. We are hopeful that we might finally be successful in the next 12 months.

3.     Does the Neuropsych Registrar program necessitate that the individual be employed in a paid position? A number of institutions appear willing to take on Neuropsych Registrars but do not have the funding available for a salary and have suggested the program be undertaken on an unpaid basis. (Are institutions allowed to do this?)

BG: Positions do not necessarily have to be paid and the Board does not differentiate between paid and voluntary positions – as long as the work role enables the registrar to meet the competencies for the registrar program. It is the responsibility of the registrar to negotiate their own salary arrangements with the employer.

FB: it should not be necessary for Registrars to enter into unpaid work arrangements in order to gain their supervision. There are vacancies in neuropsychology positions around the country, particularly in South Australia and regional areas. Employers should provide appropriate specialist supervision to all psychologists as a matter of course, and especially to new graduates. It can be useful to join your state's psychology union to gain assistance in industrial issues like this. The CCN is endeavouring to compile a list of vacancies to make it easier for neuropsychologists to find paid employment.

4.     Do at least one of the Registrar's supervisors need to be employed at the institution where the Registrar is undertaking their work? Most students realise that at least 50% of their supervision must come from a fully registered Neuropsych and member of the college. They are, however, unsure as to the requirements for working in the same institution as their primary supervisor or any of their supplementary supervisors that make up the other 50%.

BG: Not necessarily, while an onsite supervisor is preferable, the regional boards may approve off site supervision arrangements as long as the supervision requirements are still met. At least 50% of supervision must be provided by the principal supervisor who must have unconditional general registration and a clinical neuropsychology area of practice endorsement. APS College membership is not a Board requirement. Up to 50% of the supervision may be provided by secondary supervisors who do not necessarily need to have a clinical neuropsychology endorsement.

5.     Is the Registrar obliged to work only at one institution or are they able to take positions, paid or unpaid, at a number of sites? Does the nature of their supervision impact on this?

BG: More than one work role for the registrar program is acceptable. Supervision plans that propose two or more work roles are considered case by case by the regional boards and the primary considerations are whether the requirements of the registrar program can be achieved in those roles.

6.     What are the limitations around clinical hours being completed as part of research (PhD in the combined Masters/PhD program, RA work, Post Doc) being used towards the total number of hours required to be undertaken in the Registrar Program for endorsement?

BG: Hours completed as part of research would not usually be counted towards the hours for the registrar program, however applications are considered on their individual merits by the regional boards when the application is received.  The registrar program accepts the broad definition of psychological practice, therefore research and other psychological roles including administration and management can all be counted as hours within the registrar program, and there only needs to be a minimum of 176 client-related hours per year. 

7.     The entrance exam for General Reg is being brought in mid-2013. Students completing the Masters or combined Masters/Ph.D degrees are unsure if they must complete their Masters component and apply for general Reg before this time to be exempt from examination, or whether the currently enrolled students have until mid 2016 to apply for General Reg. Please clarify.

BG: Transition provisions for the National Psychology Examination are currently being considered. However it is proposed that applicants who have completed a Masters, Doctorate, or combined Masters/PhD be exempt from the exam regardless of when they complete their qualifications, so these students should not expect to have to complete the exam.

8.     some universities are reluctant to assist neuropsychology postgrad students to obtain general registration after completion of their coursework and placements and the required progress on their research project because it may interfere with the students' completion of their PhD. Are universities allowed to do this? It seems manifestly unfair to deny students the opportunity to gain employment as registered psychologists while completing their PhDs, and it means the universities are contributing to the workforce shortage of psychologists by slowing down entry of qualified psychologists into the workforce.

BG: The Board’s Policy for higher degree students applying for general registration enables early registration in order to commence the registrar program once the student has completed what is substantially equivalent to a Masters qualification. It is the responsibility of universities to determine whether the student has made sufficient progress. If universities do not want to sign the PDEC-76 form to enable early general registration the Board cannot compel them to do so. This policy is currently under review and the Board intends to improve the policy to assist Heads of School with certifying completion of the Masters components needed for general registration. Updates on this will be published on the website.

9.     Is there any update on whether fees for probationary psychologists undergoing postgraduate training will be waived or reduced, given that these students are often living close to the poverty line, are not allowed to work more than 8 hours/week, and that they are covered by the university insurance policies for their professional placement activities?

BG: The waiver of the application for provisional registration fee that was approved in 2010 is still in place. The Board will review this waiver before the end of the current financial year and any changes will be published on the website.

9. The title "clinical neuropsychologist" is protected under national law to psychologists with PsyBA endorsement in the field. The advertising standards say that psychologists should not give the impression that they hold expertise in an area of specialist endorsement for which they are not endorsed. Does it not follow that psychologists without endorsement in clinical neuropsychology are in breach of the advertising standards and general guidelines if they say they conduct "neuropsychological assessments", or if they write in their reports that they have conducted a "neuropsychological assessment"?

BG: Psychologists with general registration may practice in any area of psychology that is within their scope of competence. However only psychologists who have been granted an area of practice endorsement may use the protected title associated with that endorsement, such as Clinical Neuropsychologist. Additionally a registered health practitioner must not knowingly or recklessly claim to hold an endorsement that they do not hold.  The essential issue is whether the public is likely to be misled into thinking a person was a clinical neuropsychologist in the way they present themself and their professional work. If you are concerned that a psychologist is in breach of the advertising guidelines you should make a notification to your local office of AHPRA so that the matter can be investigated.