Stepped Care does not mean Three-Tiers!

RAPS is concerned that the Green paper appears to be garnering the support of non-clinical AoPEs for a model that may continue to discriminate against them as much against non-AoPE psychologists. This is a clear attempt to attract the support of endorsed psychologists, shore up numbers and create even greater division within the profession. However, the APS has not been clear about which AoPEs have the competencies to work with severe categories (which was highlighted at the ‘town hall’ calls) and RAPS suspects (strongly) that this will be used to continue discriminating against non-clinical psychologists on the basis that they do not have the required “competency.”

RAPS was on one of the ‘town hall’ calls when a member/caller asked the question “I am confirming, AoPEs will be included in the severe step”. The APS CEO’s reply was a categorical “Yes”. However, a few questions later, a member/caller asked “so, a GP will be able to refer a client in the severe category to an organisational psychologist but not to me a non-AoPE psychologists with over 20+ years experience in treating these clients”.

APS CEO’s reply was a categorical “No. Because that would be operating outside their competencies.” This is nonsense without knowing the competencies of individual psychologists. It highlights the caveat in the Green Paper that only AoPEs “operating within their area of competency” will be included in the severe step, but this has not been fully disclosed.

RAPS is concerned that this lack of transparency is intended to garner the support of AoPEs for a model that will ultimately discriminate against non-clinical AoPEs as much as it discriminates against non-AoPE psychologists. It seems that the clinicals are just using the AoPE’s to get their paper passed and that AoPE psychologists will by no means ‘automatically’ be included in the severe step.

It would seem incumbent on the APS Committee to state their position on this caveat asap for full transparency – and should be called on loudly to do so.

In response to recent criticisms, RAPS categorically states that the stepped care model for mild, moderate and severe clients should not be seen as an excuse to the create a 3-tier rebate system for psychologists. All psychologists should be able to work on the three steps and attract the same rebate.

RAPS position is that the stepped care model proposed by the APS is in itself clumsy and unworkable in practice. It reveals a lack of understanding about client experience and mental health and is likely to cause more confusion than good in treating mental in the community. It is a model that is not backed up by evidence or experience.

RAPS is cognisant however that the APS (for all the wrong reasons) remains an influence on government. It is therefore necessary as part of any approach to address the Green Paper and push for changes that would make it fairer for all psychologists (this is not to support it but ensure that if it does go through, all psychologists are fairly represented). As such, the APS needs to recognise in its proposal that the mild to moderate steps are the backbone of all psychologists’ caseloads. Recognition of prior learning and experience should allow all psychologists to continue to work at this level for the same rebate and using the same evidence based psychological therapies. Recognition of prior learning and experience should allow all psychologists to continue to work at this level for the same rebate and using the same evidence based psychological therapies.

With respect to the third tier, if psychologists have to demonstrate they can work with these clients, the requirement should apply to all psychologists, not just anyone who is not a clinical psychologist. All psychologists should have to demonstrate proficiency based on training and experience, including non-AoPE Psychologists, AoPE and Clinical psychologists.

It is accepted that working at this higher risk level requires greater dedication and should rightfully attract a higher number of sessions and higher rebates but every psychologist with the requisite experience should have this opportunity. How this is assessed poses additional questions but years of experience, training and experience in the relevant areas should be a requirement, not simply the particular area of study in university. The APS Green paper does not have the right to restrict psychologists working on any of these steps in the future. Any attempt to do so is discriminatory and in contravention of the APS’ duty to its members.

We reiterate that our position is one tier across all client groups. The APS should be called upon to explain in more detail how its proposed stepped care model will work in practice, particularly around determining severity and arrangements for continuity of care if clients progress through the mild, moderate and severe tiers as well as accountability for monitoring the system for effectiveness. Currently, these details are lacking raising more questions about the model than answers.

The below blog link will take you to a post that provides clarity on what the very real impact the APS Green paper will have on the many thousands of clients currently under our care if taken on board.

Vote on Green Paper Poll HERE

RAPS is also calling on all psychologists to take action. Non-endorsed psychologists still make up the majority of psychologists. Our concern is that there are still too many who are unaware of the threat to their profession and livelihood who continue to support the APS and believe in the rhetoric. It is incumbent on all psychologists to speak up, talk to their colleagues and spread the message. Psychologists cannot rely solely on others to speak for them. Everyone must take individual responsibility and actively join in the fight. As individuals our voice is small but as a united group we have the power to change things. Individual actions include withdrawing membership (financial support) from the APS, joining AAPI, joining RAPS and AP, contributing to blogs, writing to local and federal ministers (we are told that calling is even better) and talking to colleagues and/or other health professionals, including the GPs. We need to communicate to the APS and the government that we are serious and will not take this treatment lying down.

We have included the details of contacts and advocacy groups that you can send to your colleagues – see below.



Australian Psychologists Facebook Page
Search Australian Psychologists on Facebook and request to join the group

Australian Association of Psychologists Inc (alternative to APS)

You can send responses to the APS submission to

(Also cc your local MP and opposition leader into the message, stating clearly you want one-tier/rebate for all psychological services).

You can also support ACCC legal action through the Australian Association of Psychologists Inc (AAPi) Fighting Fund by donating to:-
– EFT to BSB 182 512 Account No. 961170248
– BPay to BPay Code: 667022; BPay Reference: 961170248 – Cheque to PO Box 107, North Melbourne, Victoria, 3051.
– Credit Card phone 0418 391 820

Receipts will be issued for all donations For further information telephone 0418 391 820 or email

Current petitions include: