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Q&As about Registration

1- Why is the NHAA wanting Registration?

Just like you would not want to be operated on by someone pretending to be a surgeon, why would you want to have Herbs, Nutrients or other Naturopathic treatments prescribed to you by someone pretending to be a Naturopath or Herbalist?
The NHAA has supported a form of statutory registration for Naturopaths and Herbalists since the 1920s. This is because registration ensures minimum practitioner education standards and provides protection of title. Protection of title means that only those who are qualified can practice under the title of ‘Naturopath’ or ‘Herbalist’.

Importantly, professional registration protects the public from untrained or poorly trained practitioners claiming to be something they are not. The only way to guarantee the bona fides of a naturopath or herbalist is through registration. It is a form of protection for the profession and the registered members of that profession. Anyone calling themselves a naturopath or herbalist without the proper training and registration can be prosecuted for ‘holding out’ or making false claims.

Registration provides many other benefits, including:

  • A readily accessible and publicly available register of accredited practitioners
  • Assurance that practitioners are suitably qualified to practice
  • Easier access to an independent complaints process
  • Improved communication between health professions

Registration also benefits the practitioners within the profession itself, (Naturopaths and Herbalists), in many ways. These include:

  • Ability to communicate more readily with other healthcare professions
  • Ability for other healthcare practitioners to find a registered practitioner who they can be confident has the required training and ethical standards so they can refer their patients without fear of taking on a vicarious legal liability.
  • Assured continuing access to herbal medicines and other tools of trade
  • Increased community confidence in the professions and its practitioners, with the ability for the public or prospective patients to check whether a practitioner is registered or find a registered practitioner who they can consult with.

2- Why now all of a sudden?

Over the NHAA’s history, we have worked on many initiatives to build and sustain high-quality education standards, support clinical practice and access to our medicines, as well as advocating for the profession and promoting the value of our services in health care.

Something that the NHAA has consistently viewed as integral to the continuation and development of a sustainable and valued profession is registration. This has been one of our priorities for many years, and while the process of government moves slowly, we have continued to make progress on this issue. Right now, we are closer than we’ve ever been to advancing the cause of registration.
As a member of the Australian Naturopathic Council (ANC), we have the opportunity to submit an official registration proposal to the National Registration and Accreditation Scheme (NRAS). The first step in this process is to update the Lin report from 2005, which was the last report that recommended naturopaths and herbalists be registered. Updating this 484-page report required the expertise of a health policy consultant, who, through a generous donation from Marcus Blackmore, alongside contributions from the profession itself has been engaged for this task. This means we can take this next step with care and consideration.

3- Will our Scope of Practice be constrained?

The Australian Health Practitioner Registration Agency (AHPRA) provides a framework for a Naturopathy Registration Board to oversee the profession.
The Naturopathy Registration Board, which will be established when naturopathy achieves registration, will be made up of members of the profession, with one Naturopath representing each of the states and territories. The only other people on the Board would be two community representatives, with AHPRA simply providing administrative support. Currently, practitioners are more controlled by the government than they would be if we had registration. For example, if someone makes a complaint about a Naturopath, it is reviewed by the health commissioner (or equivalent depending on the state/territory), with no input from any representatives of the profession to provide context. With statutory registration, however, the profession itself determines its own practice and education standards.

If anything, with statutory registration our scope of practice has the potential to broaden because in Australia Scope of Practice is determined by what you have been formally taught with very few Health Practices restricted by law.

The primary goal of APHRA is protection of the public through protection of the naturopath title so that only those who have the appropriate training can, by law, call themselves a naturopath.

4- Will I miss out if I don’t upgrade to a Degree?

Practitioners who are currently working as naturopaths or herbalists and hold non degree qualifications (acquired before the end of 2018) which allows them to be a member of most professional associations, will be covered with the transition to professional registration. Anyone who graduates after 2018 should be required to hold a bachelor’s degree to become a member of a professional association. Eventually, the minimum qualification for practice will be a bachelor’s degree. However, in the initial stages of registration (usually the first five years) there is a process referred to by AHPRA as grandparenting; this provision ensures that practitioners who are skilled and practising are not unjustly disadvantaged because they have not completed an approved qualification. For example, in cases where a bachelor’s degree was not available at the time that practitioner trained, they would still be able to obtain registration via this pathway.

5- What about our Traditions? 

Naturopathy is a system of healthcare with a deep history of traditional philosophies and practices – our traditions define who we are as a profession:

  • First, Do No Harm (primum non nocere)
  • Healing Power of Nature (vis medicatrix naturae)
  • Treat the Cause (tolle causam)
  • Treat the Whole Person (tolle totum)
  • Doctor as Teacher (docere)
  • Disease Prevention and Health Promotion

These principles have international recognition and acceptance confirmed by the World Naturopathic Federation in 2016 after a worldwide review to collect and codify the foundational knowledge of naturopathy including naturopathic history, definitions, principles and theories from around the world.

6- But what about “Evidence based Medicine”? Won’t we need a double-blind study for everything?

When a profession becomes registered education and practice standards are established. This means that the Bachelor level degree curriculum will the accepted standard of training that will determine the standards of practice (with appropriate grandparenting arrangements in place), including philosophies, traditional evidence, diagnostics etc. Even the TGA acknowledges the value of Traditional Evidence, our traditional understandings and practices are more protected with Registration as the people who decide what is acceptable Naturopathic practice are members of the profession itself, because the Naturopathy Board is made up of practicing Naturopaths from each state/territory (and two members of the public).

7- I hear we will have to conform to the “Medical Model”.

Same answer as for Question 3 .. but re-posted here for convenience. The Australian Health Practitioner Registration Agency (AHPRA) provides a framework for a Naturopathy Registration Board to oversee the profession.

The Naturopathy Registration Board, which will be established when naturopathy achieves registration, will be made up of members of the profession, with one Naturopath representing each of the states and territories. As well as naturopaths on the Board there will be two community representatives, with AHPRA providing administrative support only.

Currently, practitioners are more controlled by the government than they would be if we had registration. For example, if someone makes a complaint about a Naturopath, it is reviewed by the health commissioner (or equivalent depending on the state/territory), with no input from any representatives of the profession to provide context. With statutory registration, however, the profession itself determines its own practice and education standards. If anything, with statutory registration our scope of practice has the potential to broaden because in Australia Scope of Practice is determined by what you have been formally taught with very few Health Practices restricted by law. The primary goal of APHRA is protection of the public through protection of the naturopath title so that only those who have the appropriate training can, by law, call themselves a naturopath.

8- Is Registration about being covered by MediCare?

Registration and being able to claim on MediCare are two completely unrelated concepts. The work to add Naturopathy to NRAS has never been about expecting the government to pay for Naturopathy.

9- Will this make it easier for GP’s to refer to Naturopaths/Herbalists?

Currently if a GP refers to an unregistered practitioner, they can be held responsible for errors the practitioner they refer to might make. With Registration the Practitioner is regarded as an independent registered professional which makes it easier for other healthcare practitioners to find an appropriate practitioner who they can be confident has the required training and ethical standards so they can refer their patients.

10- I hear AHPRA don’t want us, is that true?

There was no official pathway to add professions to AHPRA until September 2018. There has not been an application since the establishment of AHPRA via the official pathway so there is nothing to support this claim. AHPRA is responsible for implementing the NRAS across Australia, they do not decide which professions are registered. The Council of Australian Governments (COAG) Health Council, which is made up of the federal, state and territory health ministers across Australia, decides which professions are registered.

11- How can Naturopathy possibly be considered dangerous?

Just like you would not want to be operated on by a pretend Surgeon neither should the public be treated by pretend Naturopaths. You need to understand how the body works in order to prescribe Naturopathic treatment safely, you need to understand pharmacology in order to understand potential interactions, you need to understand the correct dose to prescribe in a way which heals instead of harms, you need to know when to refer to another health professional, particularly general practitioners. Generally, the harms fall into two categories: 1. Acts of commission: failure to observe contraindications, inappropriate dosage, inappropriate duration of therapy, failure to identify and avoid known interactions with pharmaceuticals, inappropriate discontinuation of other treatment. 2. Acts of omission: failure to detect significant underlying pathology, misdiagnosis, failure to refer, failure to disclose known potential adverse effects of a treatment (Lin et al., 2005, p33ff)

12- I hear the last report failed – is that true?

The last report people are talking about in this context is probably the Lin et al., (2005) report. Rather than failing to achieve registration it convinced the Victorian government that Naturopathy and Western Herbal Medicine needed to be registered along with Traditional Chinese Medicine (TCM). The Vic government decided to register one profession at a time and started with TCM, however, during that process and before Naturopathy and Western herbal medicine could be added it was decided to move health professional registration from state jurisdiction to federal under AHPRA overseen by NRAS. When the dust finally settled on the formation of AHPRA there was no official pathway in place for the addition of Health professions. We have been asking for this to be made available and in September 2018 it finally became available. Of course, enough time has now elapsed that we need to update the original Lin report.

13- What about Friends of Science – won’t Registration just give them more ammunition?

Friends of Science have so much less power than people give them credit for. Our greatest allies are our patients, who continue to utilise our services and pay no attention to groups like Friends of Science or others who try to dismiss naturopathy and herbal medicine. The more we are frightened of them the more power we give them.