Another Watershed Moment of the Two-Tier System


A Primary Health Network (PHN) Ostracises Psychologists Who Are Not Clinically Endorsed

Time to wake up, unite, and facilitate change!

By Clive Jones PhD MAPS


A colleague from the RAPS blogsite, going under the pseudonym of Concerned Psychologist, has drawn attention to a new development in the ever-growing divide between the clinical psychologist and the ‘generalist’ psychologist.

The new development is outlined below and relates specifically to psychologists currently practicing within the South-Eastern Melbourne PHN District:

Basically, because of this new initiative established by this PHN, if you are a psychologist in clinical practice in the South-Eastern Melbourne PHN District:

  • with a master’s degree in an endorsed field of practice other than clinical, or
  • 4+2 or 5+1 trained; and
  • regardless of your capacity and skill as a diagnostician and clinician in mental health,

you may be better off leaving psychology and re-training in social work, mental health nursing or occupational therapy.

But why?

Please read the statement below from South-Eastern Melbourne PHN to grasp where all this is going.

South-Eastern Melbourne PHN states; “Mental Health Integrated Complex Care (MHICC) services offer support for consumers with severe mental illness and complex needs” that are “delivered by mental health nurses, clinical psychologists, psychiatrists, and eligible mental health workers, social workers and occupational therapists.”

Statement by South-Eastern Melbourne PHN.

Does everyone clearly understand the ramifications of the statement above by South-Eastern Melbourne PHN?

The statement from this PHN is clear. The trained social worker, mental health nurse, occupational therapist and other eligible mental health worker (e.g., degree trained counsellors?) are seen to be better equipped than psychologists when it comes to treating severe mental illness and complex needs.

That’s how some key stakeholders are seeing it now.


While it is clear not every PHN will take this approach, it does represent another watershed moment in the new era of mental health treatment and care where psychologists are, in some instances, very literally and overtly ostracised from the system.

Those who are not ostracised completely are often rolled up in to the ‘generalist’ ball in PHN website spools irrespective of:

  1. the level and type of training the psychologist holds,
  2. the years of service in clinical practice they may have, or
  3. the extent of clinical expertise they’ve attained.

The psychology ‘ship’ continues to spring leaks like this and the only lifeboat available has ‘Clinical Psychologist Only’ written all over it.

Psychologists in clinical practice within the South-Eastern Melbourne PHN Region who are not clinically endorsed do have another option.

Specifically, if you are a psychologist in that PHN district, you could jump ship and swim across to either social work, mental health nursing, occupational therapy or become the other eligible mental health worker qualified to work “with severe mental illness and complex needs”, that I presume would include degree and post graduate degree trained counsellors.


I personally have no idea.

From my perspective the APS national board either:

  1. doesn’t realise the seriousness of the issue and so continues to sleep at the wheel,
  2. doesn’t care and will just go with the flow of ‘whatever’ eventuates,
  3. doesn’t want to get involved and thus embrace a laissez-faire approach, leaving it to the survival of the political fittest,
  4. agrees with the changing landscape and so does nothing to counter it,
  5. agrees with the changing landscape and is involved directly in making it happen,
  6. disagrees with the changing landscape but is out of its depth in having any real influence to facilitate change against it.

Maybe RAPS could run a poll to see where each of us think the APS stands in relation to the six different positions outlined above. Better still, it would be great to have from the APS board a clear action plan that openly acknowledges the problem and offers a clear plan of action towards a solution.


How is it that some key stakeholders in the set up and facilitation of systems that aim to treat severe mental illness and complex needs, choose to:

  1. ignore the expert clinical skills of psychologists who are not clinically endorsed, while at the same time;
  2. acknowledge and accommodate the training, skills and expertise of social workers, mental health nurses, occupational therapists and university trained (undergrad and postgrad) counsellors?

Unfortunately, while the RAPS movement is about raising awareness of this problem and acting to prevent it, there are other psychologists who intentionally promote the ‘problem’ as a positive step in the right direction.

Specifically, there are some psychologists who sincerely believe that their psychologist colleagues who work in clinical practice without clinical endorsement are a risk to the community and should be stopped from practicing in this way.

Some colleagues have even said that there should be clearly defined dissuaders and penalties for non-Clinical Psychology providers who claim that they provide the same services as their clinically endorsed colleagues.

To put it simply, while you are busy in your practice treating the full scope of mental health concerns that present, some colleagues are selling you out.


In contrast to the RAPS concerns, that are communicated clearly and openly through this blog site, it’s important to understand the opposing point of view that is being promoted and having a real influence on the policy decisions of key stakeholders.

To find out more about the opposing views we can go to direct quotes made by our current APS president and our current APS president elect. Below are links to the documents that contain the quotes. Each document is easily accessed through public cyberspace (i.e., the internet).

  1. Cichello_Knight 2014 Submission.
  2. Cichello 2009 Submission.

The first link above is a 2014 submission to the Australian Psychology Accreditation Council (APAC) by the current president of the APS and the current president elect of the APS. When writing this document in 2014 the APS president and APS president elect were in their previous roles as National Chair and National Chair Elect for the APS College of Clinical Psychologists. The submission was in response to an APAC consultation process that sought opinion on Standards for Programs of Study in Psychology.

The second link above is a 2009 submission to the Chair of the Psychology Board of Australia (PBA) by the current president of the APS prior to his appointment to his current APS President role or previous national chair role. The document was in response to an invitation for submissions on the ‘Consultation Paper on Registration Standards and Related Matters’ in the lead up to the new nationally based psychology board and registration process established in 2010.

After reading the quotes below, it will become a little clearer why some key stakeholders end up:

  1. ostracising ‘generalists’ and ‘other endorsed’ psychologists from systems of mental health treatment,
  2. preferring other clinicians like social workers, mental health nurses and occupational therapists, instead of the non-clinically endorsed psychologists, to work with severe mental illness and complex.
  1. Views communicated that undermine the credibility of our training and expertise as psychologists

Cichello & Knight (2014), “Given that Australia has the lowest standards of training of professional psychologists in the Western world, any further lowering or undermining of Standards is an anathema and must be renounced” (p.1).

Cichello & Knight (2014), Registering psychologists to practice via the 4+2 and 5+1 pathway “… continues to leave Australia with the most poorly trained psychologists in the western world” (p.1)

Cichello & Knight (2014), “… training continues to be inadequate, especially given that professional training itself occurs totally (in the 4+2 pathway) or substantially (in the 5+1 pathway) within an unaccredited supervision program… these pathways to registration remain risk points for the public” (p.1).

Cichello & Knight (2014), “To lower the standard of training in Clinical Psychology places the public at significant and demonstrable risk”.

Cichello (2009), “… only 10 percent to possibly 15 percent of Registered Psychologists in Australia currently practice with demonstrated competencies in Clinical Psychology.” (p.4). 

  1. Views communicated that infer ‘generalist’ psychologists who are outside the clinically endorsed cohort place the public at risk when working clinical cases due to their lack of expertise in the field 

Cichello & Knight (2014), The current standards of training for psychologists “is an unacceptable scenario” that “places life at risk if competence of expertise is inadequate” (p.1).

Cichello & Knight (2014), “While the proposed Standards may be adequate for other areas of psychology, they are unsupportable for Clinical Psychology where there is a high level of responsibility, severity, chronicity, complexity and comorbidity of mental health problems that can lead to death if not managed appropriately.” (p.9).

Cichello (2009), “In fact, there is most probably a sound argument for the removal of Generalist Registration in that the graduating competencies of same renders a general psychologist treating the public for the range of mental health disorders as practicing beyond their limits of competence!” (p.6). 

Cichello (2009), there are no “… clearly defined dissuaders and penalties for non-Clinical Psychology providers to claim that they provide the same services.” (p.4).

Cichello & Knight (2014), “Preliminary evidence of an analysis of members of the psychology profession de-registered due to misconduct or poor practice, currently being undertaken by our colleagues at the Australian Clinical Psychology Association (ACPA), shows that, while all psychologists, including a couple of Clinical Psychologists, have been deregistered for misconduct related to boundary violations, generalist psychologists without qualifications in Clinical Psychology, working with clinical populations in mental health are deregistered also for poor, inadequate and/or unethical practices.” (p.2).

  1. Views communicated that infer the clinical master’s route is the Gold Standard for developing clinical practice expertise

Cichello (2009), “No General Psychologist or other allied mental health professional receives as high a degree of education and training in mental health as the Clinical Psychologist. Other than Psychiatry, Clinical Psychology is the only mental health profession whose complete post­graduate professional training is in the area of mental health.” (p.4).

Cichello & Knight (2014), “The changes to the current Standards proposed by APAC significantly weaken training in professional psychology.” (p.1). While the proposed training standards by APAC “may be viable for some areas of psychology, they are absolutely inadequate for the Area of Practice Endorsement (AoPE) of Clinical Psychology and possibly other areas where practice involves clinical populations, such as Clinical Neuropsychology” (p.1).

Cichello (2009), “The level of verbal and written communication for Clinical Psychologists is greater than for the generalist psychologist and differs in focus from other AoPEs [Areas of Practice Endorsement], as Clinical Psychologists are trained experts in mental health and their communication needs to demonstrate this to other mental health professionals.” (p.6)

Cichello (2009), “No [General Psychologist or] other allied mental health professional receives as high a degree of education and training in mental health as the Clinical Psychologist.” (p. 6).

Cichello (2009), “Clinical Psychologists are trained as scientist-practitioners. This added emphasis on the scientific in university training enables the profession of Clinical Psychologist to bring research and empiricism to human service delivery and thus increase accountability.” (p. 6-7). 


Ultimately the RAPS initiative was conceived out of the need to:

  1. oppose any view like those stated above, that undermines the credibility, skill and expertise of psychologists who are registered and in practice,
  2. advocate for change to remedy the impact of any initiative or policy that places unfounded restrictions on the practice of psychologists not clinically endorsed.

The RAPS movement aims to speak openly, directly and clearly on these matters, particularly regarding any misconception key stakeholders might have over our profession. In this sense, RAPS simply aims to raise awareness of these matters and take appropriate action to rectify them.


Please start by giving your support to RAPS. Sign up and put your hat in the ring to help. We need to tackle this issue together. There is real strength and weight of influence in numbers.

The first step? To establish a single tier rebate for all psychologists who are approved providers of mental health service provision under Medicare Better Access.

The second step? We need to promote (not undermine) the skill and expertise of each other in the context of the evidence.

What is that evidence?

  1. Psychology in Australia is a highly regarded and trusted profession.
  2. All training pathways are robust and educationally sound being scrutinised and refined meticulously by the Psychology Board of Australia (PBA), the Australian Psychology Accreditation Council (APAC) and the Australian Psychological Society (APS).
  3. Universities in Australia are high quality world class institutions earning more money as an export than the mining industry due to demand around the globe.
  4. Psychologists in Australia across all training pathways produce equally significant outcomes in the treatment of mental health disorders and associated concerns.
  5. Psychologists in Australia are employed successfully across a very broad and extensive range of government and private sector positions in health, corporate business, NGO’s, community organisations, schools, military, para military, elite sporting teams and squads, just to name a few.

Ultimately, we all need to start acknowledging and respecting the skills and experience of our teammates. This is a key to catalyse change in the right direction. There is no fear to peddle and no tsunami of malpractice to thwart. Mutual trust and respect is the way to go. Regardless of the field of practice the team mate is in and regardless of the pathway they’ve undertaken to get there.