A Reaction to the ACPA Submission to SIRA on WorkCover Fees

We recently read the Australian Clinical Psychology Association’s (ACPA) submission to the NSW State Insurance Regulatory Authority (SIRA) on WorkCover (Psychology and Counselling Fees) order 2018 that attempts to raise up “Clinical Psychology” at the expense of “General Psychology” and Psychology in General.

ACPA has embedded lies about all other psychologists in an important submission, in a transparent attempt to subliminally undermine the status of “general psychologists”.

It’s not the first time and you can bet your bottom dollar it won’t be the last time ACPA tries to malign anyone not eligible to be a member of ACPA due to the endorsement system.

The mixed feelings that resulted from this reading have increased our ambivalence about Australian Clinical Psychology.

On the one hand, it is deeply moving to see ACPA’s commitment to getting a fairer deal for psychologists working at the coal-face of the difficult and complex workers compensation sector; but on the other hand, it is sickening to see Clinical Psychologists once again turn against hardworking, intelligent and resourceful members of their own discipline of psychology.

The writers of the submission are at once impressive in their dedication to their own kind and in their tenacity of purpose in self-promotion and self-interest in their attempts to distort the truth and bamboozle with, glamour and subterfuge, the intelligence of the Work Cover insurance fee regulators, by attempting to make themselves look better and more valuable by means of denigrating their own psychology colleagues.

What a shame ACPA seems hellbent on climbing over all other psychologists to get to the top of the heap of clamberers for imagined and manufactured scarcities of funding.

A more collegiate approach would bring us all together in a much stronger unified front.  But this will never happen while ACPA keeps singing it’s tune of psychological superiority and attempts to bury all other psychologists in a cloak of second-rated-ness.

This just degrades psychology in general.

While it is true that the APS recommends $246 per session and SIRA only pays $183.60 and undervalues time spent on preparing reports and treatment plans, and that longer sessions should be allowed for PTSD and other complex sessions, there are also large chunks of deception and untruth placed semi-strategically in ACPA’s submission to SIRA.

This meanness is a real pity, because it not only denigrates, by association, the other valid points made in the submission, but it also degrades Clinical Psychology and Psychology in general to have such an implausible piece of writing submitted to a government authority, thinly disguised as serious social-science or health-administration on behalf of professional Psychologists.

Right from the outset, in the first paragraph of the submission, there is distortion of facts …

The most blatantly incorrect is:

“…general psychologists who have no accredited qualifications in professional or clinical psychology, and are less able to assess and treat those presenting for services under WorkCover.”

By way of explanation:

  1. Clinical psychology qualifications are not the only post-graduate professional psychology qualifications. There are many others.
  2. All psychologists in Australia are, by legal definition, registered to work as professional psychologists.
  3. The highest specialisation in psychology under AHPRA and PBA regulations is “Registered Psychologist” by a number of pathways all of which require a minimum of 6 years of intensive training for full registration and there are no legal specialisations acknowledged beyond that, only subspecialties and areas of special interest.
  4. In practice many psychologists practise clinical psychology very well and they don’t need to be endorsed as a clinical psychologist to practice professional clinical psychology.
  5. There is no scientific or other evidence provided in the submission to prove a generalisation that people with PBA endorsement as “clinical psychologist” practice clinical psychology any more effectively than non-endorsed clinical psychology practitioners with the highest specialisation of Registered Psychologist.

The next distortion of fact by ACPA to SIRA is found in the first complaint on the list in the submission stating:

“1: The gazette fee does not adequately differentiate between generalist and clinical psychologists.

 “Generalist psychologists are required only to hold an undergraduate degree in the science of psychology plus two years of supervised practice.”

 The undergraduate degree consists of three years plus one year of honours, graduate or post graduate, plus an intensive internship of two years in practical professional psychology which is a lot more than just ‘supervised practice’ making a total of 6 years intensive training. Furthermore, many so called ‘generalist psychologists’ hold one or more post-graduate, graduate or undergraduate degrees beyond their full psychology registration training of 6 years. The clinical psychology endorsement is held by some who have not done a masters; and for those who have a masters, the two years ‘registrar program’ is little more than compulsory supervision (not an internship), which all psychologists undergo to some extent these days.

Calling Clinical Psychologists’ requirement to be supervised for 2 years after graduating with MPsych Clinical, a “registrar program” appears to be an attempt to align with the medical model of credentialing in an attempt to appear more credible.

At this juncture it would be worth noting that the British Psychological Society’s Clinical Psychology Division have just brought out a paper1 in January outlining and endorsing a meta-framework for psychological work (Johnstone, L. & Boyle, M. (2018) that goes way beyond the attempts of ACPA use of biological reductionist medical models of categories of pathologies and points out the folly of trying to reduce complex psycho-social and emotional states to biological systems and categories alone, and instead advocates a much broader systemic, multifactorial approach as all psychologists should!

If only the ACPA and the APS would follow the BPA CPD’s lead and educate the public, other disciplines and sectors and medical sciences about the true contexts, aetiology and treatment of causes of psychological distress.

The ACPA submission also bemoans:

“…less qualified generalist psychologists being attracted to provide WorkCover services, and those with accredited qualification in clinical psychology not undertaking this complex work, for which they are trained.”

 Presumably because they want to be paid more. And it seems to be an oxymoron to say that generalist psychologists are doing the work that they are not really able to do.

Take note that ACPA submission makes a lot of noise about endorsed Clinical Psychologists having special training and abilities to undertake “complex work” then later says this about complexities with the WorkCover system:

 “Most experienced clinical psychologists do not take on injured workers because of these complexities. As such injured workers miss seeing higher quality clinical psychologists and as a result their recovery is set back. This could have an impact on their ability to return to work.”

Apart from the fact that there is no scientific or other evidence to prove endorsed ‘clinical psychologists’ get better outcomes than all other psychology clinicians, it really does read as though ACPA is trying to spin itself as superior and indispensable in any way it can, even if their own platform is full of internal inconsistencies and distortions to try to make themselves seem more capable of the complex interventions, yet reluctant to undertake them because they want more money.

At this point it is important to see the distinction between, a) ACPA – The Australian Clinical Psychology Association – a break away from the APS, and b) APAC – The Australian Psychology Accreditation Council – in their emphases of what makes a good psychologist good or a better Psychologist better.

ACPA the clinical psychology break-aways are still hooked on the ‘Inputs’ side of the equations, while APAC has finally woken up to the real importance of the ‘Outputs’ side of the equation and the importance of Outcomes and Competencies and ways of quantifying these so we can get on with being a profession fit for the 21st century in our care and treatment of complex human problems.

ACPA is really bogged down in obsessions with, “who had the most years at Uni?” and in what course, while APAC has seen the light and knows the truth that more and more university training does not make a psychologist superior in their abilities and outcomes.

Under point 6 of the ACPA submission to SIRA the catch word ‘complex’ appears again when ACPA states:

“The fee schedule specifies that if psychologists wish to charge different fees for a severe injury that this must be negotiated with insurer. In practice, it has been difficult for clinical psychologists, who are most able to serve complex populations, to obtain agreement of insurers to allow the setting of more appropriate rates.”

Once again, a self-spun assertion, building up the notion that, of all the fully registered Psychology Specialists in the Art and Science of Psychology only those endorsed as Clinical Psychologist can deal with anything complex and are ‘most able to serve the complex populations’.

The people who are most able to serve complex populations are generalists and multidisciplinary teams who have a broad range of skills and abilities.

Modern Clinical Psychology in Australia does not deal with complexity in systems or people very well at all, because it is reductionistic and satisfies itself with slapping labels on people and reducing their complex problems to medical categories in imitation of psychiatry.

Nevertheless, the preceding points notwithstanding, we thank ACPA for bringing it to the attention of the authorities that all psychologists are underpaid by WorkCover according to the APS rates.

Meanwhile, for the sake of Australian Psychology we urge ACPA to publicly apologise to all Psychologists in Australia for their remarks and to withdraw their submission to SIRA.

Also for the sake of the future of Psychology in Australia, we implore the APS to make a public statement condemning attempts by ACPA to degrade the professionalism of Australian Psychologists for their own gain.

And last but not least, if you are one of the very many honourable colleagues who is endorsed as a Clinical Psychologist, we advise you to give the ACPA breakaways a wide birth and exert whatever influence you can on reforming ACPA’s ways which are causing so much destruction to your subspecialty and the profession of psychology; because psychology is already starting to be overlooked by planners and funders, for more ostensibly sensible, disciplined and well-rounded professions like Occupational Therapy, Nursing, Social Work, Welfare workers, Community workers and the like.

If you are a clinical psychologist, for goodness sakes don’t support ACPA.

You can download the ACPA submission to SIRA here.


1Johnstone, L. & Boyle, M. with Cromby, J., Dillon, J., Harper, D., Kinderman, P., Longden, E., Pilgrim, D. & Read, J. (2018). The Power Threat Meaning Framework: Towards the identification of patterns in emotional distress, unusual experiences and troubled or troubling behaviour, as an alternative to functional psychiatric diagnosis. Leicester: British Psychological Society


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