The Australian Psychology Board's proposed training redesign (with Kate Crosher)

[00:00:05] Bronwyn: Hello Mental Workers, you're listening to the Mental Work podcast, the podcast about the realities of working in mental health for early career psychologists. As always, I'm your host, Bronwyn Milkins, and today we are talking about the Australian Psychology Board's Training Pathway redesign proposal. What a mouthful!

If you are an early career psychologist, registrar student, or someone considering the profession, the Psychology Board's proposed training reforms could shape everything from how psychologists are trained to what future career pathways look like. So today we're going to be unpacking what the proposal actually means, what consequences it could have, and how you can have your say before the consultation period closes.

Our guest today is Kate Crosher. Hi Kate.

[00:00:48] Kate: Hi.

[00:00:49] Bronwyn: It's so nice to have you on the podcast. Thank you for coming on on this important topic. Could you please start us off by telling listeners who you are?

[00:00:56] Kate: I'm an educational and developmental and a clinical psychologist, and I'm the founding director of AEDPA. That's the Australian Educational and Developmental Psychology Association. So at the moment, I hold the early career portfolio. I'm responsible for providing resources, guidance, advocacy around those who are earlier in their career.

For most of my career, I've worked primarily in schools, but I've also worked at regional level for the education department in Victoria supporting allied health professionals. I've also lectured and supervised at tertiary institutions and student clinics. And at the moment I mostly work in private practise supervising people at all stages of their career for the registrar programme as well as for CPD, and doing some neurodevelopmental and psychoeducational assessments. I live in Far East Gippsland in Victoria. So that's me.

[00:01:40] Bronwyn: Amazing! What a career, you do a lot of things.

[00:01:42] Kate: Yep. Got my fingers in lots of pie.

[00:01:45] Bronwyn: Yeah, I'm so glad that you're the early career representative as well.

[00:01:49] Kate: Thank you.

[00:01:49] Bronwyn: Yeah. The reason why I reached out to the AEDPA in the first place was because you guys have been quite vocal about the pathway redesign proposal, more than I think other people, I've just seen a lot of stuff from you guys, you've been quite active... why is this?

[00:02:02] Kate: Well, I think that it's really important for educational developmental psychologists to have their own voice heard. Our larger organisations have to advocate for the majority, which are generalist psychologists and we wanna make sure that our area of practise doesn't get lost amongst all the noise of what's happening with those early pathways. And nothing changes unless we say something. My colleagues and I started this organisation to say things loudly and proudly, and to advocate for the unique competencies that educational developmental psychologists can bring to our profession.

And the training redesign represents that first step a student will take towards becoming a psychologist. So it's important we get this right. When we first saw the redesign, there were a number of things that left us with concern. So we felt it was important to prioritise advocacy in this space so our members and the public could become better informed. And the more people who put in submissions, the more evidence the board has to take to the government, so adjustments can be made.

[00:02:52] Bronwyn: Yeah, absolutely. It makes sense why you guys would have a big stake in this. So for listeners who have seen bits and pieces online but are feeling overwhelmed, can you please give us a plain English overview of what the Psychology Board is proposing and just why these reforms are being considered in the first place?

[00:03:09] Kate: Absolutely, I'll try and give a bit of an overview as quickly as I can. Basically the board has been given a briefing by the government to redesign the pathway for training psychologists. They've been given some clear guidelines around what they have to work with. Primarily the government wants a single shorter way to general registration rather than having a five plus one over here and two year masters in this over there, they want psychologists to be trained quicker. They wanna have training that's more consistent with other a AHPRA regulated professions and they want more practical training earlier in the process so psychologists can come out of their training more work ready.

And so they're proposing a single five year university sequence, and that includes skills training from the second year. And a lot of us would be really excited by that because most of us did our third- three year training and we're like, oh my God. It's all theory, no practise. So it, it, there is definitely some good things about this.

Our meetings with the Board have found that exactly what this looks like is not yet been spelled out. There are gonna be further requirements from the Psychology Accreditation Council, which is APAC that gives guidelines for trading institutions on what exactly this will look like. So there is some flexibility on this. However, ultimately the government wants a clear single five year pathway, so AHPRA doesn't have to manage all of the different pathways they are at the moment.

[00:04:24] Bronwyn: Make it tidier, make it neater.

[00:04:25] Kate: Make it tidier, make it neater. They're comparing to the other AHPRA regulated professions that do have, most of them, a singular pathway and they want it to be easier and simpler to regulate. And it kind of makes sense. I mean, the reality is, is the government always wants things to be easier for them to regulate, cheaper for them to do, if we're being really honest, it makes things less complicated and neater.

So in a practical sense, I guess some of the things that this means is they don't wanna have a plus one internship, so that would be removed. There would be no more provisional registration for domestic graduates. Now that was something we were relatively quite concerned about, but what we found that it doesn't actually mean there's no registration at all for students, that was our original concern. But what it means is that the university can monitor performance during training and AHPRA will have a student registration. But that's just like other AHPRA professions.

[00:05:16] Bronwyn: Yeah, my understanding with that one is that Doctors, for example, have, uh, a student registration.

[00:05:21] Kate: Yeah, and, um, nurses have a student registration, um, and even teachers, like, it's not with AHPRA but teachers have a student registration as well. Um, and so a has a backup for supporting universities for any students who perhaps demonstrate some concerning behaviours or have some concerns in their training, but AHPRA won't be coordinating that in the first instance. And so there will be this introduction of student registration rather than provisional registration.

And in fact, the comment was that was made to us was that, uh, psychologists are overregulated. By having provisional registration, we actually have more regulation than is necessary. And that was created because we had internships, you know, long ago before AHPRA, certainly in Victoria we had, um, registration... I believe that not all states had registration, but in Victoria we had probationary registration. And that was for the four plus twos and then the, the plus ones, you know, when, when it moved to AHPRA. But support from a university level as well as AHPRA provides this double up, I guess, of regulation.

[00:06:24] Bronwyn: ' Cause I was thinking like, why did we have provisional registration in the first place? Because I think we're the only profession that does have it. So that makes sense, it's actually a hangover from when we had that probationary period and we had the internships.

[00:06:35] Kate: Yeah, exactly. And the plus one as an internship actually was created because there was a lot of backlash about getting rid of the plus two altogether. I've been a psychologist for 25 years and when I trained and I did my undergrad in the nineties, we knew that the plus two was going to be removed. That's why I chose the two year master's programme, 'cause I'm like, well, I can't get full registration with the APS if I only have an a, a four plus two, so I might as well do the six year master's because I'm gonna need it eventually. Anybody who says they didn't know it was going to happen and we're going to lose the internships actually just meant that they didn't know it was happening, but it was actually like we've known for a long time.

So anyway, back to the current redesign. There are going to be no more psychology exam for domestic pathways because the university will regulate that. And that again, that reduced the costs for the government. If we're being a bit cynical, government likes things to be cheaper for them.

There are also going to be practical placements embedded in the university courses. So moving to that single qualification just opens the door for the profession, and things that the profession has needed for a long time, and that just provides things more consistent and equitable. That's the theory.

[00:07:45] Bronwyn: Yeah. So I guess the proposal is that this will be a one in a generation training reform that will result in more consistent, equitable training costs, it will reduce financial barriers, inequities between pathways and reliance on limited postgraduate places. Maybe we'll just say before we go into this, I just wanna say that this has been confusing for me to understand!

[00:08:05] Kate: Absolutely, yes.

[00:08:07] Bronwyn: As I was saying to you off pod, I'm nine years registered, so I was, I did my five plus one in 2017, and I'm finding this so difficult to understand and I've tried reading it, um, I've tried understanding, but I'm just finding this so overwhelming.

[00:08:21] Kate: Yep, yep. And absolutely the same thing. You know, the board in AEDPA is a team of 10, and, we have all of our heads getting together and looking at it and reviewing it. And, some of us have more time than others, but not all of us understand every little nuance about every part of the new pathway. And it's same as you 25 years in, and there's some things that I'm like, oh, is that what that means? So it makes sense that early career people will be finding it difficult to understand too, it's complicated.

[00:08:48] Bronwyn: The APS actually just released their statement and proposal-

[00:08:52] Kate: I saw that too.

[00:08:53] Bronwyn: -so I downloaded that and that's 23 pages. And the AEDPA's response is 10 pages as well. So it's like there's a lot here. So I actually felt much better yesterday because I was like, Jesus, there is a lot here, you know?

[00:09:03] Kate: There is a lot here.

[00:09:05] Bronwyn: Yeah. So let's go into like some of the challenges and maybe feasibility that people can try and wrap their heads around. And at the end of the episode, we're also going to go through how they can submit, because that's the aim of this episode. I really wanna encourage listeners to make a submission. Like, your voice is really important and Kate and I just wanna help you be able to do that.

So one of the challenges I've had reading the consultation documents is figuring out what the practical implications are. So when you read the proposal, what were the changes that stood out to you as having the biggest impact on students, prov psychs, and early career psychs?

[00:09:39] Kate: When I had a look at this question last night in preparation, the first thing that actually came to mind was I actually don't think there's gonna be very little change for anyone who's currently in training or early career. The short answer is I wanna reassure people, I don't think you're gonna have a big impact yourselves in the short term.

The changes that are currently coming through are really gonna impact people who are currently in high school or perhaps mature age students who've not yet started their psychology training and wanna come back. And if history shows anything, it's that the government has to finalise people who are on a specific pathway already. So if you are doing an internship, you will still finish your internship. It took many years for the four plus two to phase out and it'll take many years for the five plus one and the current area of practise, two years master's programmes to phase out too. So it's not gonna be a black line drawn, nobody's gonna be able to do what they're gonna be able to do. If you're currently on a pathway. My prediction would be it's going to continue that way, so don't panic.

But it might change things for those people who do want to do a registrar programme. If the cutoff for doing it is reached, then things might shift. Of course we can't predict it, but it might have that implication. In a practical sense for those who do go through this pathway, the things that will change will be that there will be greater opportunity for people to learn practical skills earlier. So there's gonna be no three year degree that has no practical counselling skills or other things, you'll learn real stuff from the first from the second year.

There is possibility that you'll have to decide that you wanna work towards being a psychologist right from the beginning. So for those people who maybe go into a bachelor of Arts or a Bachelor of Science to test out a few things and then decide that might be a risk for some people. So that's definitely something to be mindful of.

And there are some financial implications potentially for roles that have lower level training. That's the big concern for us in a feminised workforce with salaries already capped in so many workplaces, this is just another opportunity to limit women's working capacity.

[00:11:33] Bronwyn: That something that stood out for me as important as well, I saw the AEDPA say that. I think there was a report that you guys compared it to you were like, look, they're actually saying that we need to benchmark and increase our salaries, and now this AQF potential reform, changing from AQF nine to eight might impact our capacity to earn as an 80% feminised workforce.

[00:11:54] Kate: Yeah, absolutely.

[00:11:56] Bronwyn: One other thing I wanted to ask you about the practical implications is that, okay, it sounds good to have more practical skills early in the university degree. My question is around funding. I'm just like, will there be more university funding to be able to staff that, to have people do placement coordination? I already know for placement coordinators of postgraduate courses that it is such a challenge to find placements and practical, um, pathways to students. And I'm just like, I don't know how feasible it is to be able to do these practical things earlier in the, in the degree?

[00:12:27] Kate: And this is something that hasn't been unpacked. This is one of those things that they haven't addressed specifically because the Psych Board's remit is to provide guidelines to the government on what they recommend the pathway should look like. The implications of what that looks like afterwards is not part of this redesign.

[00:12:48] Bronwyn: Cool.

[00:12:49] Kate: So there are going to be a lot of things that are gonna need to be thought through. And one of them, and I'm probably jumping ahead a bit it seems relevant to say it now one of them was as a student on placement your obligations or your expectations or what people allow you to do is different than what somebody who might be doing in a postgraduate perspective.

So one of the ways that as a supervisor, I have been able to argue that a provisional psychologist is able to do things independently is because they are in a postgraduate training pathway. And I can say, they're registered as a provisional psychologist, and they are at their postgraduate level of training, so they can work independently compared to, and my experience has been in schools and in multidisciplinary teams, speech pathologists, although they're not AHPRA regulated, a speech pathology student is very rarely left alone to do things by themselves. A nurse is very rarely left alone to do things by themselves. A doctor is very rarely left alone to do things by themselves.

But psychology by the innate nature of what it is doing counselling with a client, they often need to be by themselves. And so what are gonna be the implications of this? I've had students go into schools independently and work independently and grab kids from the classroom, I'm not there to watch them every single time. We have students out in placements all the time in Victoria doing things by themselves.

So there's going to have to be a shift within the workforce around what this looks like if we do have student registration alone, and the professions that we work with are going to have to, and the organisations that we work with, are gonna have to shift their expectations on what is acceptable perhaps in some of these industries.

[00:14:37] Bronwyn: Yeah. It's like the more we dig into it, the more questions arise about implementation and feasibility.

[00:14:44] Kate: Yeah.

[00:14:44] Bronwyn: That's outside the scope of the current reforms, they just, they propose the model, but then the next step would be-

[00:14:49] Kate: The next step, how do we actually implement it? So there's the first step to propose the model, second step is implementation. We also then have APAC coming in. So APAC is the Australian Psychology Accreditation Council and they are the ones who will create the competencies and they'll create what the training pathways require.

So this project isn't gonna unpack all of the little nuances, this is the first step. This then gets to the government. The government still has to accept it. They might decide they don't want and don't like certain things in this proposal. So there's lots of layers and lots of steps from behind the scenes that we don't always get to see.

[00:15:25] Bronwyn: Yeah, absolutely. So as we mentioned earlier, there is a proposal for the single five-year pathway to general registration. Are there any benefits to that change and are there any other concerns about implementation that the AEDPA have?

[00:15:40] Kate: Good question. I think that a single five year pathway and what the AEDPA thinks is that has lots of potential to streamline the training for psychologists in general. So that will mean that we will all come out as true generalists. There's no competitiveness between different areas of endorsement, and we don't wanna get too political here, but let's be honest, professional pathways versus area of practise pathways, clinical versus everyone else, there's a lot of competitiveness and variable opinions about a lot of that. So this has definitely a chance, a real chance to level the playing field for all of us.

[00:16:17] Bronwyn: I like that because I think, like having come into this profession almost 10 years ago now, I feel like I came into like a volcano. I, I guess I just noticed that there was a lot of competition or people had varying views about the, um, merits of different pathways and of the people who were trained in those pathways. And I just wanted us all to get along. I've talked about it on the podcast, how like that was quite a naive view, um, but I would love a pathway to unite us and so we can have that collegiality.

[00:16:45] Kate: Yeah. And I think if we all came out the same and then made the choice to go into what pathway we wanted to, there's definitely some merit in that. There's an excess of clinical training pathways, there's too many clinical psychologists. Clinical psych by its nature is supposed to be hospital based, complex mental health. 25 years ago when I trained, you know, I feel myself going back in my day, but 25 years ago, that's what it was. I didn't, I didn't wanna be a clinical psychologist 'cause that felt too scary.

But, you know, and having trained and supervised many clinical psychs over the last 10 years, they don't necessarily wanna do this work. Many choose clinical psychology because they've been told it's better. It's a great pathway and it's necessary and it's an important part of our field, but it's not the only one and it's not necessary in many settings. So I really do think that this has the chance of really making things more level.

[00:17:38] Bronwyn: Are there any concerns about the single five-year pathway?

[00:17:41] Kate: I think that the way that it's worded on the image, and if anybody, if you're wondering there is the image of what the pathways look like and it says Bachelor of Psychological Science or something like Bachelor of Professional Psychology. If you think of it as an undergraduate bachelor, as we've alluded to, there's the AQF level, the Australian Qualifications Framework level that reduces the level from a nine to an eight. So that's a particular thing, and we can go in that a little bit more a bit later.

But, the other things that we've been thinking about is a single five year pathway where you have to decide from the get go that you're going to be a psychologist means that someone will finish high school and maybe a generalist psychologist fully registered by the time they're 23. This is pretty young. Like, are 23 year olds ready for this kind of complex work across the lifespan? I'm not saying they're not, you know, I remember myself at 23, but this is something to think about when we know adolescence goes up to 25.

[00:18:32] Bronwyn: I started university when I was 16 actually. So the thought of me picking to be a psychologist when I was 16, I'm just like, "no"!

[00:18:38] Kate: Just crazy, right!? And then you alluded to this earlier around do we have employment pathways that will provide the learning opportunities and career structure for these young psychologists? There's gonna need to be a shift in the workplace, sometimes people can't do things alone. So we're gonna need to really think about expectations from employers and organisations.

[00:18:59] Bronwyn: So I've got two concerns. So I do wanna talk further about the AQF and then I wanna talk about the international comparison actually, because I was reading the APS very briefly last night and they had concerns about our international standing as well.

So let's talk first about the AQF nine to eight. So, my understanding with AQF9 is that that is benchmark to a master's degree, and then AQF8 is benchmark to a bachelor with an honours year. So kind of, uh, just one step above-

[00:19:26] Kate: Fourth year, yeah.

[00:19:28] Bronwyn: Yeah.

[00:19:28] Kate: Yep, yep.

[00:19:29] Bronwyn: So can you just tell us why this distinction matters? Why should we care?

[00:19:34] Kate: It's unheard of for a salary level to drop. AQF9 and having a certain training at master's level tends to equal the level of income that you will make when you exit. Now I don't want it to be all about money because that's not the be all and end all of everything. The AQF level also is about competency that you will develop within that period of time. And there are implications for PhD level training for those who might wanna move into academia. If they only have a level eight, then that's not gonna actually help that they need that level nine to be able to move into PhD. So how will universities get students working towards these higher degrees where they're not embedded in the training pathway as easily?

You know, sure a lot of psychs aren't interested in research, but it is a core competency of psychology. It does distinguish us from other professions. The practitioner model is a really important part of how we operate. And most importantly, we need good researchers to be teaching our courses. Without a good pathway into PhD, we risk losing quality lecturers and professors.

So I think that's a big part of it but I'll come back to the fair work commission and standards for paying professionals because that's probably our main concern, one of the significant concerns as a very feminised workforce. The Fair Work Commission has set the standards for paying professionals. They have their rewards based upon psychologists being qualified at AQF Level 9. So that's in direct disagreement with what the government is now proposing.

Now the thing is, it's unheard of for professions to go backwards, and, again, without wanting to wave the feminist flag too strongly, we know that female dominated professions tend to reduce salary over time and they have a ceiling. And this just feels like another example of that.

My understanding is that in 2025, there was a Gender Undervaluation review and the commission proposed aligning the HPSS Award classification structure directly to these AQF levels, and it treats a psychologist as AQF Level 9, that's the Master's degree level, and that's the highest professional tier in that structure. So for a, for example, in comparison, a physiotherapist sits at AQF7, and a lot of the other professions sit at AQF7 in AHPRA. And this is where the government comes in terms of their expectations or what they've given their guidelines, what they've given to the Psych Board, they actually wanted the psych board to do AQF Level 7, just a Bachelor degree.

[00:21:58] Bronwyn: Oh, interesting.

[00:21:59] Kate: Yeah, that's really interesting. When we heard that, we had a meeting with the psych board just last week and that was a really interesting thing that they shared with us. And so the board went back and did do some advocacy for us which is really great to hear, and said, that's not acceptable. We can't do level seven for psychologists, that's not appropriate, that's not reasonable, we need to have it higher than that. And they pushed as hard as they can but the government agreed to level eight.

So the level eight is already a bit of a compromise from the government's point of view. Now that doesn't mean we shouldn't advocate for nine and that doesn't mean that we should stop pushing that in our submission, and we have pushed that in our submission, but perhaps we have a little bit more understanding of how hard it will be to push the government from where they want to be and where we currently are.

And this is where politics and bureaucracy and stuff is in play, and sometimes when you are working in these kind of spaces, you have to find a way of compromising and finding a way to make the best out of a bad situation.

[00:23:01] Bronwyn: Yeah, I find this one really difficult because from what I'm hearing, it sounds like the government is saying to us, look, we can produce a good psychologist at AQF8, why do we need a really good psychologist at nine when we can get a standard one at eight? So I guess they think that safety can be upheld with eight and like competence... Is that kind of the impression you're getting?

[00:23:24] Kate: Yeah, they think that you can get all of what psychologists need to learn in this level eight with a five year pathway. Like I tend to be the eternal optimist and this is not an AEDPA position, but I tend to be an eternal optimist personally. And so I just feel if we had to make the best of a bad situation, we probably could. If we're squishing in all of those electives you do in undergrad, and if we squished them up and we had less electives and more psychology focused training, which I think would be a great idea, maybe we can actually get further in that five years with an AQF level eight. But the biggest thing that drops is this research component.

[00:24:03] Bronwyn: Yeah. That's concerning to me, because if listeners are not aware, like lecturers most of them, to be employed as a lecturer, you need a PhD qualification.

[00:24:12] Kate: Yeah, you need to have a higher level of qualification than the course you are teaching, or at least the same. So I don't have a PhD, I do teach at universities. I can teach up to master's level, but I couldn't supervise PhDs. PhD, and doctorate trained lecturers can teach everything basically. So a master's level could teach an undergraduate, I guess in theory, if you had a Bachelor, you could teach in a Bachelor, but tends to be people at Master's level teaching in all of them, at least in our industry.

[00:24:44] Bronwyn: It does, it does concern me. I guess, so like I have a PhD and I work as a researcher and, um, I find it very valuable and obviously you know, hindsight bias as well, like, I wouldn't wanna say like, oh, I wasted my life, so I'm like, yeah, it was good choice.

[00:24:58] Kate: We all love our own pathway.

[00:25:00] Bronwyn: Exactly. So I do find it very valuable. On the other hand, I have found that employers have not really cared that I have more research.

[00:25:09] Kate: No!

[00:25:09] Bronwyn: So I have been told explicitly like, you're not being paid more because you have it, you don't use it in your practise.

[00:25:14] Kate: Little do they know? Little do they know how much you actually use in terms of research.

[00:25:19] Bronwyn: I use it every day in my psychological practise. I'm using it, I'm thinking, I'm thinking about how to craft this, how to test hypotheses, create hypotheses. Can I consult the research literature? What does it say here? What are the gaps? How can I apply that to my practise? So I do think research is incredibly important, so it does make me a little bit sad that we may lose that potential pathway.

[00:25:39] Kate: Yeah, absolutely, I agree. I think that it, a research component to our training is such an important part that's undervalued by a lot of us early in our career. And I've, I was very clear, I don't wanna be a researcher, I don't wanna do this, but I'll do it because I really wanna be a psychologist.

And people who don't work in psychology or don't understand psychology a lot of them are the ones making these decisions and they're like, what do you need to do that to be a counsellor? They equate psychology with counselling and that's what they think that we're doing. And we're not, we're doing more than that. We are synthesising and analysing so much information. We're not just sitting there listening to people and helping them process their feelings. That's part of what we do, but we are more than that.

And reducing the AQF level has definitely the risk of reducing the competency and the extensiveness of what we learn alongside potentially reducing our minimum award, 19 to 31% reduced, which will impact on super, which will impact on other things. Okay, we'll start work a year earlier, so we perhaps get a year more work, but there's definitely some risks in all of that.

[00:26:48] Bronwyn: Yeah, I agree. I find this quite persuasive. Like if I was to make a submission and I know I could, I've tested the AEDPA... I will, I will make the submission, and I tested the AEDPA submission generator, and you can pick your positions and you don't have to select them all. And I picked, I would pick the AQF one as a focus for me.

 I tried to think of a, an example of this, and one of the things that I came up with, with how important research is, was I remember quite early on when I was doing my five plus one internship, my employer said to me, you need to deliver emotion regulation strategies to autistic kids that you are seeing. And at the time, there is no such thing as emotion regulation therapy. Like there's no EMT for autistic kids. So me, I'm trying to think, well, how do I deliver... like, am I just picking and choosing little strategies and is that a cohesive therapy and is this something evidence-based that I can offer to my autistic kids? And is this safe and is this effective?

So for me, I feel like if I didn't have research brain, I would've been like, oh yeah, I just pick and choose window of tolerance. And then I do a bit of like blue zone and green zone, and then I'm all good and that'll help my autistic kids. But I, I don't find that very satisfactory. And I think that's, that speaks to why research and our scientist, practitioner focus is very important because autistic kids deserve better too.

[00:27:59] Kate: Absolutely, and I think that distinguishes us from other professions. If we didn't have that, and with all due respect to the other professions that I'm about to label, of course, 'cause they're great in what they do, but if we didn't have that, then we might as well just be a teacher. If we didn't have that, we might as well be one of these other professions because a teacher can pull out window of tolerance, a teacher can pull out some social skills training and they'll do a fine job, but they won't necessarily have that next step of being able to look into the research and work out what's actually evidence-based and look at the client and actually figure out what that client needs in the context of everything else going on around them.

And that's across the lifespan. A nurse can do a great job of this stuff. Anybody can pick up these tools and do it. A parent can do it. But without our training, the way that we are trained, they don't have the same ability to look at that information. And I think that is such an important part of why we have concerns around this.

Now having said that, as I said, it is possible that this is something that's a done deal that we haven't got any power over. We should still say something, 'cause the more we say something, the more maybe the government will listen. But in that case, one of the things that AEDPA has shifted in the way that we are going to put our proposal together is to actually talk about, if there is a shift to AFQ Level Eight, what should that look like and what should we make sure still exists in our training pathway to ensure that it is adequate for purpose to build the competency of psychologists.

So if you are-, when you are making a submission, if there are things that we need to sort of, sometimes we just need to suck up changes, right? If there are things we need to suck up and just deal with then, putting in some ideas about what you think. If you insist on having AQF Level 8, this is what you should do and this is what we need to make sure happening, then that's a good way perhaps to compensate for some things that we just don't have any power to control or change.

Um, it's not our ideal, but we are trying to be realistic and acknowledge that there might be, there might be limited changes we can make in that or advocate for. So we're trying to perhaps hedge our bets both ways. We want this, but if we have to have this, this is what we want it to look like.

[00:30:10] Bronwyn: Yep, that makes sense. One of the other areas that listeners might be interested in is our areas of practise endorsement. So currently psychology has eight areas of practise endorsement, and so the proposal includes changes to registrar programmes and the idea of industry accredited workplaces.

So after five years, we're all generally registered psychologists, and then it's driven by the workplace and there'll be these accredited workplaces, where you can work for one or two years and then gain your endorsement. What are the potential risks and opportunities? When I saw this, I was like, is this gonna be the death of everything but clinical?

[00:30:45] Kate: It's definitely something to be concerned about, I guess, isn't it? In the first instance, the areas of practise endorsement is due to have its own review soon. So once the training pathways are done, areas of practise will be also reviewed and will be considered alongside, I guess what they've already decided on the training pathway.

It's very likely that areas of practise endorsement will change anyway with or without this change in the way it's being trained, because we just have some areas of practise endorsement, very unfortunately, that just don't have the numbers for it to be sustainable. And the areas of practise endorsement were really simply decided upon the way that the APS had its structure of interest area groups, so the colleges, and that was the literal extent of the thought that was put into it. So it is really good for us to have a review on what areas of practise endorsement might look like.

Now we're all a little bit scared and we all have passion about our own areas of practise endorsement for those of us who are endorsed. But I think there is something really exciting about that idea of this- again, it's once in a lifetime, way of reviewing what's happening. It's a once in a lifetime chance. So we have a definite possibility here for things to be good.

Having said that, the risk to industry based workplaces is that they are not necessarily gonna provide the breadth of training that endorsement does. Having a workplace that is linked to your title and your professional title means that the workplace dictates what you do as a professional. And workplaces have their own motives for what they teach they, and things that they want psychologists to know. That's not independent learning, that's bias for their settings. And that's really risky as psychologists because as psychologists, one of the things we learn about is confirmation bias. So we wanna make sure that the things are developed... the public gets the service they need, rather than the industry dictating what they want psychologists to do.

An industry accredited workplace will risk shaping training around the priorities of that employer or that commercial setting, rather than broad transferrable skills and endorsements meant to address. So that's gonna narrow a psychologist clinical exposure and maybe entrench these setting specific practises over evidence-based standards. And for example having worked in the Victoria Education Department for some years, a job that I really, really enjoyed and found, I learned a lot in, you can definitely see people changing their practise because of what the government wants in the way that they want assessments done.

So we use funding, for example, the way that the funding is applied in a school setting, or the way the NDIS funding applies, changes the way we write reports. We're not now doing an assessment to assess what this client needs broadly and to provide a label and a diagnosis or identify a neurotype for somebody because of what's actually happening for the client. We're impacted by whether or not this particular diagnosis will create funding, whether we like it or not. And I don't want that, I don't mean that to be controversial, and I'm not saying these diagnoses are not real, they absolutely are. I'm just saying that we don't realise how impacted we are by the way, an industry and a government creates the rules around things.

So there's definitely danger in our professional autonomy, our ethical decision making and client interests becoming secondary to the organisational or governmental objectives. And that erodes our independence and consistency of standards.

[00:34:21] Bronwyn: Yeah.

[00:34:22] Kate: On the flip side, there are some really good opportunities for collaborations, and I know Western Australia has a really great school psych programme.

[00:34:27] Bronwyn: We do.

[00:34:28] Kate: Yeah, there's, um, Ann Lord over there, she does an amazing job. There's definitely some great collaborations that could occur in medical settings that could work well, and maybe even NDIS and other bits and pieces. So there's definitely possibilities.

However, I really believe that the endorsement programme and being a registrar and being endorsed is more than just the skills of a workplace. So, for example, although I identify as a school psychologist, my identity as an Ed and Dev is not only about schools, and I see school psych as different to educational psych endorsement has these unique competencies and experiences that are not specific to a workplace, and they should be separate. And that allows for a much broader and more extensive skillset.

[00:35:10] Bronwyn: Yeah, I agree. Yeah, some opportunities, but also some concerns. As you were talking, I was just reflecting my own experience of working in a private hospital, and a lot of it, unfortunately, it's just driven by share prices...

[00:35:23] Kate: Yes, share prices, money. Yeah, absolutely. It's about money.

[00:35:27] Bronwyn: If we've got bums on seats, we don't mind what therapy delivered to the clients as long as they're in there and we can get the health insurers to pay. Um, and that's not controversial. That's just reality.

[00:35:35] Kate: It's just reality.

[00:35:36] Bronwyn: So I'm like, I just wouldn't like it if it was I guess if we were more constrained or there was, difficulties with being able to do what's best for the patient in front of us.

[00:35:43] Kate: And the standard setting in an organisation is that things reflect what's convenient to deliver rather than what's clinically ideal. For example, and then this may be controversial and there's a whole podcast on this but in private hospitals when nurses are supporting new mums into breastfeeding or not breastfeeding, it is based upon reducing the risk to the hospital. It is not necessarily based upon what the mum wants to do. And so women don't get the advice that they want to feel confident in their decisions around whether they want to breastfeed. Most women go in wanting to breastfeed, but many women don't because they don't get the right supports. And that's not criticising women who end up formula feeding,

'cause you do what you need to do and it is better that you are healthy and happy and connected, that's fine. But when most women want to breastfeed and yet many don't, it means that they're not getting the support that's required to achieve their own goals. And that's based upon the organisational demands and the risk that organisation is willing to take, which may be different to what the person wants, the client wants.

[00:36:46] Bronwyn: Mm, absolutely. So Kate, if a listener is thinking, I'm only a student registrar or an early career psychologist, surely my opinion does not matter. What would you say to them? Why is it important that they engage in this consultation process?

[00:37:01] Kate: I would say that right now it might feel like it doesn't matter, but by the time it does go through, you will have more experience. You'll be the one supervising the early career psychologists, and you'll be wanting to make sure that you are working with people who have the skills and the competencies to be effective practitioners.

Your voice actually does count. Your voice counts more than mine. Your opinion is exactly what's needed. You've got a long career left. You'll be the ones dealing with the fallout down the track, if they get this wrong.

[00:37:29] Bronwyn: Very persuasive!

So for people who want to make a submission before the 10th of June deadline, what's the practical steps they can take and how can they use tools like the AEDPA submission generator to make the process less intimidating?

[00:37:46] Kate: So the first step, of course, is to get onto the AHPRA website, have a look at all the resources. If you don't have time, you can just use something like the submission generator, um, or your own other professional organisation tools. Check out the resources, their pro formas to follow, that you can put your information in.

It is vital, however, that you are not basing submissions on misinformation. So don't rely on random people making controversial statements on social media. If you put anything in your submission that is inaccurate information, they cannot include your submission at all. That was what we were told last week. So make sure that you are not using this information to provide your response.

You can respond to everything or you can just respond to small parts. If you don't understand it all and you don't wanna make a comment on that part, don't worry, don't put it in, just respond to the bits, you know, every little bit counts. They'll put it all together, they'll take it all on board. And, you know, in the end it's really just... the pro formas all exist, and then there's our submission generator where you go in, you choose the bits that you agree with or don't, you know, if you don't agree with it, don't choose it, and it'll just pop out a nice little thing for you to send in.

[00:38:53] Bronwyn: Yeah, I quite liked it. As I said, I was playing around with it yesterday and I thought it was very sensible and well written.

[00:38:58] Kate: And listen, most of the professional associations do have a document of some sort that you could use to inform your submission. But certainly I like ours, of course!

[00:39:08] Bronwyn: Yeah, I thought it was really great.

Kate, thank you so much for coming on. I think this has been really informative and I think it'll be really helpful for listeners. Is there anything else that you want them to take away most from today?

[00:39:19] Kate: I think that it's so important that we need to understand we can't sit back and say nothing. Psychologists tend to be quiet and agreeable and understanding, but without noise, action just doesn't happen. So join your professional associations and help them do the work that they need to do.

Now here's my little advertising spiel. We have membership categories for generalists as well as that Ed & Devs, all are welcome. We're all volunteers just carving out a small window of time in our busy weeks to get these messages out there. And we'd love to have more people involved in advocacy.

So making your own submissions, using our generator. If you don't have time to do anything else, just get something out there and get your voice heard. Don't be passive if you just get something in... things need to be said. Even if you agree with the changes that needs to be said too. You don't, we don't want everything to be disagreeing, so share what you liked about it as well as what you didn't like about it. This is a once in a lifetime opportunity to have your opinion heard.

[00:40:11] Bronwyn: Awesome. Thank you so much Kate. I really appreciate your clarity and thoroughness. And as I said, I think listeners will find it really helpful. I'll make sure I put all those links in the show notes. So I'll put a link to the AEDPA and your submission generator and I'll put a link to your submission document as well.

[00:40:28] Kate: Awesome.

[00:40:29] Bronwyn: Listeners, if you have found today's episode helpful make sure that you share it with a colleague who needs to hear it so that they can be more informed too. And you can also follow the Mental Work podcast and leave a rating and review.

And that's a wrap, thanks so much for listening to Mental Work. I'm Bronwyn Milkins and catch you next time. Bye!