Government & Industry Submissions

 Representing the interests of NHAA members and the professions of Western herbal medicine and naturopathy, the NHAA Board regularly works on submissions to Government and related industry bodies in a range of areas. See below for more information and copies of the submissions.

ARONAH Standards & Guidelines consultation March 2013

AronahThe Australian Register of Naturopaths and Herbalists (ARONAH) was established to develop minimum standards of education and practice for naturopathy and herbal medicine. They requested input from all major stakeholders in these professions into the first draft of the following standards and guidelines documents: Code of Conduct; Advertising; CPD; Patient records; Proof of Identity; Insurance requirements; English language proficiency; Criminal history; Recency of practice.

For more information on ARONAH go to   

Download: NHAA submission - ARONAH standards & guidelines

Review of Govt PHI rebate for natural therapies Jan 2013

piggybank stethoscopeThe 2012-2013 Federal budget included proposed changes to the regulatory framework of private health insurance and announced a review of the PHI rebate for natural therapies. For practitioners, this meant the eligibility of various modalities would be reviewed to ascertain if the Government should continue to subsidise health fund rebates for those with PHI. I.e. patients may no longer be able to claim for services such as naturopathy and herbal medicine from their private health insurer. 

Read more: Review of Govt PHI rebate for natural therapies Jan 2013

Evidence to support indications for listed medicines August 2012

The NHAA did not do a submission to the TGA on this issue for a number of reasons. Some members also expressed concerns that this will lead to a similar situation as has been experienced in the UK and America.

Read more: Evidence to support indications for listed medicines August 2012

Aust Health Ministers' Advisory Council (AHMAC) April 2011

AHMACThe AHMAC paper “Options for the regulation of unregistered practitioners”, sought comments on the adequacy of current protection available for consumers who use the services of unregulated health practitioners, including naturopaths and western herbalists. Options outlined for consideration were to make no changes to current mechanisms, to strengthen self regulatory arrangements, or to strengthen health complaints mechanisms. 

Download: AHMAC Submission  

Criminal Law Enforcement drug schedule March 2011

To comment on the Implementation of Model Drug Schedule for Commonwealth Serious Drug Offences. This discussion paper sought comment on various points including classification of some nutritional substances (such as minerals), as drug precursors and the expanded list of plant species under the model schedule for controlled plants. NHAA expressed concern that the paper cast a very wide net and had the potential to cause legitimate users of plants and some minerals to become criminals in the conduct of their daily lives. Enactment of this draft legislation would put many of our members outside the law simply because they practice herbal and nutritional medicine.

Download: Criminal Law Enforcement submission  

Page 3 of 6