August 2018

Issue 19

• Chair's message
• News from the Board 
  • CPD triennium finishes 30 November 2018
  • Medical Radiation Practice Conference — Regulation and Practice
  • Facilitator training in November — express your interest!
  • What's your scope of practice?
  • Medical radiation practice and veterinary imaging and therapy 
• National Scheme news 
  • New research framework launched to improve patient safety 
  • Vexing not vexatious: research finds more risk in not reporting
  • Public consultation on review of accreditation arrangements
  • Consultation paper on the draft guideline for informing a National Board about where you practise
  • 700,000th health practitioner registered
  • AHPRA designated a WHO Collaborating Centre for health workforce regulation across the Western Pacific
  • Closing the gap by 2031: a shared commitment
• Keep in touch with the Board

Chair’s message

Welcome to the Winter edition of our newsletter.

While I was preparing to present at the Australian Society of Medical Imaging and Radiation Therapy (ASMIRT) winter meeting in Tasmania I spent a bit of time researching some of material, for the presentation which provided a few more continuing professional development (CPD) hours. It also reminded me that the end of the CPD triennium was near.

In this month’s Board newsletter we talk about the expiration of the current CPD triennium (and quick tip for all those reading, audit is likely to go ahead early in 2019!). We also provide some generalised advice about scope of practice and its connection with CPD. And on the topic of diversity of practice we look at the difference between a health service and a veterinarian service, and yes, they are different and noting that practice in veterinarian practice does not meet the obligations of a registered health practitioner.

I also want to take this opportunity to let you know about the upcoming conference that the Board will be hosting in late November 2018 in Sydney. The theme of the conference is ‘regulation and practice‘ and it will look at a range of issues that impact on how you practise and include an interactive session where we get your views on proposed changes to the Professional capabilities. And for those who need some CPD hours before the end of the triennium, the conference could be a good opportunity.

Happy reading.

Mark Marcenko
Chair, Medical Radiation Practice Board of Australia

back to top ↑

News from the Board

CPD triennium finishes 30 November 2018

The current CPD triennium is ending in November this year, and a quick heads-up, audit is likely to occur in the early part of 2019.

As you know, the Board’s CPD registration standard requires that as a registered medical radiation practitioner, you must complete a minimum of 10 hours of CPD in a registration period (1 December to 30 November each year), and a total of 60 hours of CPD over a three-year triennium.

30 November 2018 not only marks the end of the current registration period (1 December 2017 to 30 November 2018) but also marks the end of the CPD triennium (1 December 2015 to 30 November 2018).

So what does this mean? For those of you who have put CPD on the back burner for a while, now might be a really good time to assess where your CPD hours for the triennium are up to.

When it comes time for you to renew your registration you will be asked if you have met the CPD registration requirements. For the 2018/2019 renewal, with respect to the CPD standard, you are declaring that you have:

1. completed a minimum of 60 hours of CPD activities over a three-year cycle, with a minimum of 10 hours in any one year
2. ensured that at least 35 hours are substantive CPD activities, and
3. maintained evidence of CPD activities that includes reflection on activities.

An important component of CPD activities is your reflection on these activities. 

Reflection is something that the majority of practitioners do, although it’s often done in a more subconscious way. As an example, think about a ‘near miss’ that you may have experienced, whether in practice or in your personal life. Often we think about how that event occurred and how we might avoid it, or what steps we can take that ensure a ‘near miss’ does not happen again. This is the process of reflection.

When it comes to CPD the Board is asking that you follow your natural review process but in a more conscious way. That is, think about the CPD activity in a critical way. Consider what the CPD activity gave you in terms of information or learning and then how that might change or improve your practice. The changes you make to your practice do not need to be momentous; it can be as simple as taking a different approach to explaining an examination or treatment to a patient. In other cases it may be that the CPD activity confirmed what you already knew.

Reflection doesn’t just record what you learnt from a particular CPD activity. The overarching benefit of CPD is that by understanding what you know and what you don’t, you become more aware of how you practise. It is this insight into your own practice that helps to ensure that patients receive the very best of care.

For more information about what a substantive CPD activity is, evidence and reflection, read through the Board’s CPD Guidelines.

back to top ↑

Medical Radiation Practice Conference — Regulation and Practice

The Board will be holding a conference on medical radiation practice in Sydney on Tuesday, 27^th November 2018. The theme of the conference is Regulation and Practice and we will be looking at a range of different aspects of regulation.

The topics that will be covered at the conference include:

• Investigating complaints against practitioners
• Outcomes of notifications
• Data and research in the National Scheme
• Audit and compliance data

In one of the sessions we will be providing conference attendees with an early look at proposed changes to the Professional capabilities. This will be an interactive session where we get your thoughts on the proposed changes. 

There is no cost to register for the conference.

If you are interested in attending the MRP Conference please contact us at Board-MRP-RSVP@ahpra.gov.au to register your interest. Please note that numbers are limited, so get in early.

back to top ↑

Facilitator training in November — express your interest!

Clinical supervision and assessment plays an important and significant role in delivering competent practitioners both at the undergraduate level and for registered practitioners in supervised practice.

The Board has used the award-winning Teaching on the Run program (TOTR) to develop facilitators who deliver supervisor training. Teaching on the Run will be holding a two-day Facilitator training program in Melbourne on the 1^st and 2^nd of November 2018.

The Facilitator training program covers Clinical Supervision, Planning Learning, Clinical Teaching, Skills Teaching, Assessment, Supporting Learners, Effective Group Teaching and Interprofessional Learning modules that help clinically based staff become more efficient and effective in their education role.

The Board will cover the cost of the TOTR Facilitator training program and travel and accommodation expenses.

If you are interested in attending the two-day workshop and are willing to facilitate at least two training sessions for other supervisors, please email Board-MRP-RSVP@ahpra.gov.au confirming that you also have line manager/employer support to attend the facilitator workshop and deliver training to other supervisors. Please note that places in the program are limited

Further information will also be provided on the Board’s website. If you have any queries please email Board-MRP-RSVP@ahpra.gov.au.

back to top ↑

What's your scope of practice?

It’s a topic that comes up quite regularly, what is scope of practice? To assist registered practitioners, employers and those with an interest in the area the Board is providing some generalised advice about scope of practice.

The National Registration and Accreditation Scheme (National Scheme) for health practitioners is one that protects title use. That is, in order to use a protected title for a profession an individual must be registered in that health profession. In order to be registered an individual must be qualified for practice in the profession (and meet registration standards and other requirements).

Importantly, the National Scheme is not one that protects practice except in the limited circumstances described in s.121 (restricted dental acts), s.122 (restrictions on prescribing optical appliances), s.123 (restriction on spinal manipulation) and in some circumstances where endorsement of registration is required (for example, acupuncture).

The National Board defines scope of practice¹ as: the professional role and services that an individual health practitioner is qualified and competent to perform.

What this means is that there is virtually no limit on the type or arrangements for practice that a registered medical radiation practitioner may undertake, except for those areas that are protected by legislation (such as restricted dental acts) or restrictions in related legislation such as scheduled medicines.

Starting point

The Professional capabilities for medical radiation practitioners represent the minimum capabilities for general registration and they also represent the starting scope of practice for registered practitioners.

A scope of practice is personal to each registered practitioner and it is expected that, over time, an individual’s scope of practice will generally change. This may be because they focus on a particular area of practice (such as magnetic resonance imaging, paediatric radiation therapy or theranostics), or a particular patient group (sports imaging) or because they move into a different role such as a manager, researcher or academic.

What can be said is that the scope of practice for one practitioner will not necessarily be the same as the scope of practice for another practitioner. If you consider colleagues in your workplace or those in other workplaces, you will notice that some work in the area of computed tomography (CT) while others work in magnetic resonance imaging (MRI) or ultrasound. Outside of the clinical setting others work in education, or with equipment manufacturers, or in radiation licensing regulation. Each of your colleagues in those different practice areas has a skill and knowledge requirements that makes their scope of practice different. 

Indeed, it is generally not within the capacity of one health practitioner to decide the scope of practice for another registered health practitioner; scope of practice is very much about an individual practitioner’s skills and knowledge.

Evolving scope of practice

As technology changes, as we develop new methods of practice and as we come to understand better ways of practicing, each health practitioner must adapt so as to include these changes in their practice. Adapting to these changes by increasing skill and knowledge inherently produces a change in an individual’s scope of practice.

The converse, then, is also true. That is, maintaining a current scope of practice necessarily requires ongoing education and training. In terms of competence assurance there is a clear and direct link between continuing professional development (CPD) and scope of practice. CPD ensures your capabilities keep pace with the current standards of the profession. CPD ensures that you maintain and enhance the knowledge and skills you need to deliver a professional health services to the public.

The pace of change is probably faster than it’s ever been – and this is a feature of the new normal that we live and work in. If you stand still, you will get left behind, as the currency of your knowledge and skills becomes outdated.

Consider for a moment how practice may have looked in 1980. Computed tomography was in its infancy, there were no computed or digital imaging systems and no computerised patient information systems. Film chemistry was a daily task, cholangiograms in theatre were a bit of hit and miss affair and perish the thought of an intra-operative MRI. Take that 1980s medical radiation practitioner and fast forward them into 2018. Their scope of practice is quite different to the minimum capabilities of today. Maintaining a current scope of practice is achieved through things like CPD and other formal and informal learning.

It is fair to say then, that a practitioner’s scope of practice is not static, it must, by necessity, evolve over time to ensure that they are practising in a way that is consistent with accepted current practice.

Limiting scope of practice

An individuals’ scope of practice can be, or become, limited. This may be due to the fact that the practitioner has over time has focused on a particular area of practice. Employers, in deciding how best to utilise their workforce, may describe a role whose function has a limited scope. For example, an employer may require a medical radiation practitioner to carry out plain chest radiography only. In this case, over time the registered practitioner’s scope becomes limited to taking chest radiographs.

In terms of changing or reverting to a broader scope of practice see the section on the Code of conduct below.

Code of conduct

Whether managing your current scope of practice, returning to a full scope of practice or practising in additional areas of practice (sometimes referred to as advanced practice) the Code of conduct provides guidance for registered practitioners in relation to their obligations.

Looking at part 2.2 of the Code of conduct, the obligations of medical radiation practitioners include the following.

Maintaining a high level of professional competence and conduct is essential for good care. Good practice involves:

1. recognising and working within the limits of a practitioner’s competence and scope of practice, which may change over time
2. ensuring that practitioners maintain adequate knowledge and skills to provide safe and effective care, and
3. when moving into a new area of practice, ensuring that a practitioner has undertaken sufficient training and/or qualifications to achieve competency in that area.

In terms of those who have limited their scope of practice, if you intend on reverting to a broader scope of practice it is expected that you would follow the guidance in 2.2 part c). That is, to return to a full scope of practice you would need to be able to demonstrate what training or education you have done to ensure that you are competent and safe to practise.

Things to consider

As your scope of practice changes you should consider what impact this may have on your professional indemnity insurance (PII) arrangements. Any relevant or material changes to your scope of practice should be advised to your insurer.

1. See definitions in the Recency of practice registration standard.

back to top ↑

Medical radiation practice and veterinary imaging and therapy

Occasionally the Board has received queries from practitioners about recency of practice that involves veterinary imaging or therapy. The Board also observes that a similar question has arisen for other regulated health professions, and in short, the advice is that practice that involves veterinary imaging or therapy (nuclear or radiation) is not practice that enables a registered medical radiation practitioner to meet the recency of practice requirements.

The primary role of the Board is to ensure that that only those people who are suitably qualified and competent are registered and therefore legally able to use the titles of medical radiation practice. Only those who continue to meet ongoing registration requirements, including a prescribed amount of recent practice, can maintain registration.

As a registered medical radiation practitioner when you renew your registration with the Medical Radiation Practice Board each year you are required to declare if you meet the Recency of practice registration standard, which in summary requires 450 hours of practice in the relevant division, in the past three years.

The provision of health services to the public by medical radiation practitioners is not defined nor limited to simply using a piece of equipment. Rather the registered medical radiation practitioner uses a range of capabilities to deliver health services safely to patients.

The fact that the skills of a medical radiation practitioner can be used outside of healthcare speaks to the skills of the medical radiation practitioner; however, providing care to animals is not the same as providing care to human patients. The public expect that if a registered health practitioner is providing health services, the health practitioner meets the requirements for recency of practice. Similarly any CPD done by registered health practitioners must relate to the provision of health services to patients. Put plainly, a registered health practitioner providing health services to human patients is not the same as a veterinary practitioner providing veterinary services to animals.

If you wish to remain registered and practise on animals, whether as part of the normal course of your practice, on weekends, or without payment, you must:

• meet your professional obligations as a registered medical radiation practitioner – including recency of practice, continuing professional development (CPD), and adhere to the Code of conduct
• declare on renewal of registration that you meet the recency of practice requirements and the CPD requirements which relate to medical radiation practitioners providing health services for humans
• make your professional indemnity insurance provider aware of your scope of practice and ensure that you are appropriately covered
• make sure that you do not give the impression that you are a registered veterinarian, and
• make sure you meet any other Commonwealth, state or territory laws, including those relating the provision of services to animals, noting that if you breach these other laws you may put your registration at risk.

If you choose not to be a registered practitioner then you are not able to use a protected title for medical radiation practice. If you practise in circumstances which give an impression that you are registered with the Medical Radiation Practice Board of Australia you may be in breach of the ‘holding out’ provisions of the National Law.

For more information on your obligations and registration requirements go to the Board’s registration standards page or contact the relevant professional association.

back to top ↑

National Scheme news

New research framework launched to improve patient safety

In January, National Boards and AHPRA published a research framework to help transform health practitioner regulation to improve patient safety.

A research framework for the National Scheme: Optimising our investment in research sets out the research priorities and principles for National Boards and AHPRA to focus their research efforts.

The framework includes the priority research areas of: defining harms and risks related to the practice of regulated health professions, regulatory taxonomy or classification scheme, risk factors for complaints and/or poor practitioner performance, evidence for standards, codes and/or guidelines, evaluating regulatory interventions, stakeholder satisfaction and engagement, work readiness and workforce capacity and distribution.

It has been published to provide a solid base to facilitate risk-based research and evaluation activities, with a clear focus on translating the outcomes of research into initiatives that will inform regulatory policy development and decision-making to maximise the public benefit.

back to top ↑

Vexing not vexatious: research finds more risk in not reporting

New independent research commissioned by AHPRA has looked internationally at vexatious complaints, finding these are very rare and that there is more risk from people not reporting concerns than from making complaints in bad faith.

The report found that the number of vexatious complaints dealt with in Australia and internationally is very small, less than one per cent, but they have a big effect on everyone involved. The research also confirms that the risk of someone not reporting their concerns is greater than if the complaint turns out to be vexatious.

Most of Australia’s 700,000 registered health practitioners provide great care, but patients also have the right to make a complaint when things don’t go so well.

The best available evidence suggests that truly vexatious complaints are very rare, and that under-reporting of well-founded concerns is likely a far greater problem.

There is a common misconception that a complaint must have been vexatious if it resulted in no regulatory action. However, a decision by a National Board not to take regulatory action does not mean that the complaint was unfounded or made in bad faith. For example, a risk to the public may have been adequately addressed between the time the complaint was made and when the investigation concluded.

The report will be used to inform best practice for reducing, identifying, and managing vexatious complaints and helps to identify opportunities to work with others to help reduce their frequency and adverse consequences.

The report is available on the AHPRA website under Published research.

back to top ↑

Public consultation on review of accreditation arrangements

National Boards and AHPRA are consulting on future accreditation arrangements from mid-2019, when the current term of assignment of accreditation functions ends.

The National Law sets out the accreditation functions in the National Scheme; these include developing accreditation standards, accrediting programs of study against approved accreditation standards and assessing overseas-qualified practitioners.

Public consultation closed on Monday 14 May 2018. The consultation paper is available under Past consultations.

back to top ↑

Consultation paper on the draft guideline for informing a National Board about where you practise

The Board has published a consultation paper on the draft guideline for informing a National Board about where you practise.

In September 2017, the Queensland Parliament passed the Health Practitioner Regulation National Law and Other Legislation Amendment Bill 2017. The Bill contained a set of amendments to the Health Practitioner Regulation National Law (the National Law), as in force in each state and territory except Western Australia. Corresponding legislation has also been passed in Western Australia. These amendments include changes to the information a registered health practitioner is required to provide about their practice arrangements when requested by the National Board (referred to as ‘practice information’).

The draft guideline has been developed to help medical radiation practitioners and other health practitioners provide practice information in a way that meets their obligations under the National Law.

Public consultation closed on 25 May 2018. The consultation paper is available under Past consultations. Submissions have been published.

back to top ↑

700,000th health practitioner registered

AHPRA and the National Boards have welcomed the 700,000^th health practitioner to be registered in Australia since the start of national regulation in 2010, Victoria-based enrolled nurse Alison Tregeagle.

Ms Tregeagle graduated in March 2018 as a mature-aged nursing graduate. Her registration with the Nursing and Midwifery Board of Australia was confirmed and published this month on the national Register of practitioners. While Alison was studying for her Diploma in Nursing, she was working in part-time and casual jobs at an aged care facility, a hospital and a pharmacy and is excited about embarking on her new career as an enrolled nurse.

Reaching the 700,000^th registered practitioner milestone comes almost eight years after the launch of the National Scheme on 1 July 2010, when AHPRA and the National Boards for 10 health professions began their regulatory partnership governed by a nationally consistent National Law.

In 2010, the registration of over half a million health practitioners transferred to the new National Scheme, with a further four health professions joining in 2012 and growing the number of registered health practitioners to more than 590,000 for the year to 30 June 2013. This year the number will grow further as paramedics join the National Scheme in late 2018.

AHPRA’s first annual report showed there were slightly more than 530,000 registered health practitioners across Australia as at 30 June 2011 so hitting 700,000 represents significant growth over that time. It demonstrates that regulation is enabling the growth and mobility of a registered health workforce to support the delivery of health services to Australians.