APS White Paper

Australian psychologists must understand some very important points about the APS White Paper, especially in relation to the extra sessions that are proposed. They come at considerable long term cost. Essentially, what we will end up with is a two-tiered system but with much more division between generalist psychologists and endorsed psychologists than the existing system. It is also very unclear whether the inclusion of endorsements will make much difference as the definition of “advanced competency” remains unclear. It is possible that the purported inclusion of endorsed psychologists at the higher rate will be in name only if the advance competency assigned does not include being able to work with clients of greater complexity or higher intensity.

The White Paper is presented as APS’ vision for psychological services under Medicare, with a view to strengthening access to high quality and safe mental health services for Australians. And yet, clients will be ‘stepped’ through ‘levels of psychological care’ not simply on the basis of their need but also on the basis of diagnosis and the so-called ‘expertise’ of the psychologist.

Psychologists without an Area of Practice Endorsement (AoPE) will be restricted to providing Psychological Therapy under the Low Intensity Disorder Pathway. All psychologists, with or without AoPE will be able to provide services under this pathway. However, clients of Clincials and other AoPE ), depending on their area of advanced competency, will get the higher Medicare rebate. The APS is proposing an increase to a maximum of 20 sessions per year under this pathway, with feedback and review after each course of (max 10) consultations. Clients can be referred to this pathway if they do not meet criteria for the High Intensity Disorder Pathway. And so the plot thickens.

The proposed High Intensity Disorder Pathway is limited to clients diagnosed with Eating Disorders, Psychotic Disorders, Conduct Disorders, Borderline Personality Disorder and Recurrent/Persistent Depressive Disorder. Under this pathway, clients can access up to 40 sessions per year, with feedback and reviews after each course of (max 10) sessions. Not all psychologists will be eligible providers under this pathway. The psychologists who can provide Advanced Psychological Therapy will be those with an AoPE, working within their area of ‘advanced competency’ as determined by the PBA and APAC. It is unclear how advanced competency will be assessed. Critically, the basis for inclusion in the High Intensity pathway is NOT based on peer-reviewed, researched criteria for severity, but on opinions compiled from focus-groups. The insanity continues.

Additionally, the APS recommends that:
– up to 3 so-called ‘developmental neurocognitive assessment’ sessions be made available in any 12-month period, conducted by psychologists with AoPEs in clinical neuropsychology or educational and developmental psychology only. So, if you have been working in this area for sometime and are not a AoPEs in clinical neuropsychology or educational and developmental psychology your clients will not be able to get a Medicare rebate. Thanks APS.
– up to 3 neuropsychological assessment sessions be made available in any 12-month period, to be conducted by psychologists with AoPE in clinical neuropsychology only.
– up to 3 ‘independent mental health assessment, opinion and report’ sessions be made available in any 12 month period, to be conducted by psychologists with AoPEs in clinical or counselling psychology only.
– The two-level rebate system under Medicare continues, extending the higher rebate to all psychologists with AoPEs, increasing the scheduled fees for psychological therapy items and increasing the scheduled fees for assessment items to 1.5 times those for individual treatment sessions.

While some of these proposals seem positive, the differentiations between psychologists with or without AoPEs and the corresponding higher versus lower rebates remain. Clients of psychologists with AoPEs will enjoy the higher rebates, depending on their area of advanced competency, while clients of the majority of psychologists will not. We know from past experience that GPs will likely increase referrals to those offering higher rebates as well as more consultations.

Recall when the 2-tier rebate was introduced in 2006. Most psychologists thought it was great because there was a rebate for all, even if they were lower for the clients of the vast majority of psychologists, most of them ‘generalist’ and endorsed psychologists other than clinical. After a number of years, it became obvious that clinical psychologists were favored by many GPs and many clients, simply based on the higher rebate. Not based on qualifications, expertise, or experience. Purely based on a higher rebate. This has significantly damaged our profession over the past 13 years.

The proposal to allow more sessions for the clients of all psychologists and to include all endorsed psychologists in the provision of ‘Advanced Psychological Therapy’ under the High Intensity Disorder Pathway with higher rebates means that history is about to be repeated. Clients will be restricted from accessing experienced psychologists if they are not endorsed despite years of experience and/or expertise in the area.

Once again the APS, the peak body for ALL psychologists, has produced a model that favours different groups, to the detriment of what is still the majority of psychologists and their clients. Moreover, they have not allowed for any consideration of prior learning or experience to be taken into account so that newly graduated psychologists with little experience will still get paid more than a generalist psychologist with years of experience. This is not good enough but psychologists need to act. There are options available to send a clear message to the APS but apathy is not one of them at this stage.

You are encouraged to read the document carefully. Our profession is on the edge. Your future work and practice are in danger of being further devalued and restricted.

Reference 36 in the White Paper to support only clinicals and AoPE should be on top tier- exists all right but.

It is a report based on the opinions expressed in 3 workshops (N=58 people).

The workshop was firmly set within the Dept of Health stepped care model, so unsurprisingly that’s what they recommended.

There is no mention whatever of clinical psychologists, let alone whether they are more/less appropriate. Professionals recommended include GPs and ‘people with certificate IV in mental health’.

It recommends use of DBT although in a later appendix it is acknowledged that this treatment has not even been tested for most forms of Pers Dis.

This does not constitute evidence for anything much, let alone the efficacy of clinical or other AoPE psychologists.

Please read the White Paper carefully and provide your feedback to the MBS Review who continue to accept feedback at MBSReviews@health.gov.au and the Health Minister. What needs to made clear to the government is that if the changes recommended in the White Paper are passed it will come out (because we will get it out) that these huge financial decisions were based on spurious and unsubstantiated evidence and a biased agenda perpetuated by a minority of psychologists acting in their own best interests.