RAPS Response to Accreditation in Safety and Healthcare

RAPS have sent the following response on the Accreditation and Safety Issues to the APS board directors: Ros Knight – Tim Carey – Joseph Gagliano – Deborah Wilmoth – Aaron Frost. We are awaiting their response. The link to the relevant consultation paper on patient safety and quality improvement in primary care, published by the Australian Commission on Safety and Quality in Health Care is here.

Quality and Safety Standards

A Client Centred Response

  1. Safety: The greatest danger to clients is the lack of access to timely and affordable services, particularly in rural and remote areas. The primary function of any body purporting to protect the safety of clients should be to advocate for more accessibility for clients.
  2. Cost: There is insufficient funding now for client mental health. Any diversion of mental health funding to administration will inevitably result in less direct service to clients and political lamentations about the explosion of the cost of health care.
  3. Existing Oversight: General Practitioners are responsible for the preparation of Mental Health Care plans and their review. Support for this process might be useful.
  4. Client Feedback: A useful starting point for a review of existing services would be to contact clients who have used mental health services and ask for their experiences and concerns.
  5. Centralisation of Service Provision: There seems to be a tendency for Mental Health Services to be centralised into larger organisations, rather than small locally situated practitioner services. Inevitably this tendency leads to the provision of triage and the assignment of clients to waiting lists, with the associated delay of treatment.
  6. Caution: Improvements in safety and quality service are unarguably desirable. There needs to be thorough investigation and identification of current practices. Important criteria for improvement in the safety and quality of service are that the provision of services must be
  • Timely
  • Affordable
  • Accessible
  • Effective

Any current shortcomings in the delivery of timely, affordable, accessible and effective services need to be redressed. The people best suited to judging these criteria are those to whom the services are directed – the clients.

5 thoughts on “RAPS Response to Accreditation in Safety and Healthcare

    1. Hi concerned psychologist

      No reply yet, actually, going on past form, don’t expect one. Recently a RAPS supporter received a reply from the ED to a complaint that supporter had made over a year ago. The reply was a total marketing style exercise and didn’t address the issues in any way. That supporter was incensed … imagine waiting over a year and then to receive something like that!

      One thing we are considering either for the new web site or forum is to keep a collection of submissions made to various bodies (including the APS) and the replies (and any further correspondence). We could include de-identified supporters individual submissions in this collection.

      We are also needing to make a submission to SIRA (the NSW State Insurance Regulatory Authority) regarding the submission made by ACPA about a two tier system for WorkCover (thank you for bringing this to our attention).

      Anyone interested can download the ACPA submission here. We urge supporters to also make a complaint to AHPRA about this submission, it is a clear violation of the code of ethics.

      You will all be more informed of how much RAPS is doing when the new web site is launched and when you join the community forum – a means of congregating together so we know how many of us there are and so we can communicate directly and personally is vital for the overall effort. Once again …

      We know that the numbers of non-clinicals in the APS are a large majority.
      We need to be able to contact and talk with more of these people. So let’s bring them into a community forum.
      If you are considering leaving the APS, please reconsider as the overall effort and interests needs a unified front. Splintering will feed very nicely into the overall strategic directions of the APS clinicals. It will be very difficult to change the two tier system by working only from outside the APS – we need a representative APS board.

      Betrayal is a strong emotion and we are all experiencing that. We can use that emotive energy in any way we choose, let’s use it for positive unified purpose.

      Please think of RAPS as a voice conduit, a conduit for all generalists in Australia. Generalists who are APS members and those who aren’t, therein lies our unity of purpose and only through that unification are we likely to be successful.

      If you have left the APS and joined another body you may want to contribute to the unified purpose by re-joining the APS, at least for awhile. A big call on the emotions and value system, we do realise, but the unified purpose – the overall needs of all generalists in Australia – is what you would be contributing to, not the APS in it’s current makeup.

      1. Interestingly on 21/12/17 I too received such a response to concerns I sent to the ED and APS Board on 15/12/16 from the ED via the administrative worker. Wonder how many more members who complained received the same!

        Re their response: In my opinion, the APS basically wiped their hands clean, referring to my concerns as AHPRA/PBA business and listing all the APS initiatives that support my practice thereby dismissing their responsibility in this whole process!

        We know that the APS was instrumental in advising and implementing government policy re transition from state to national registration and AHPRA endorsement and Medicare fiascos (and more recent PHN agenda)! Is the APS liable? What other “initiatives” has the APS informed that we are not aware of? There is alot of politically strategic activity happening behind the scenes!

        If we as non college members have no access to internal information via a clearly defined support system as per college frameworks we remain ignorant and blinded by the APS propaganda machine.

        The DGPP in my opinion is a one-sided “watch dog”. It welcomes our concerns so that it can use the information to prepare its “argument” and appear unbiased! All part of the clinical “plan”! I remain very skeptical re any value re the DGPP for the non college APS member! It is like a clearinghouse of information… take from us what they want to present themselves as fair, balanced, inclusive, unbiased etc etc……

        Have you noticed that the APS 2018–19 Pre-Budget Submission December 2017 posted on the APS Matters 25/1/18 publication has “confidential” splashed on each of the pages? Are they now protecting themselves? So as financial members of the APS are we now not able to disseminate and/or contest any such document without their permission? So now the APS is by default my voice, it knows what’s best for me, keeps me in my place, even if I do not agree with their policy position! What are my rights? Who do I consult with? The DGPP? I think NOT!

        In my opinion seems the APS Board is tying off loose ends….. are they preparing and/or protecting themselves from a potential RAPS legal contest!

        The APS, thanks to our ongoing generous annual membership contributions, and funding generated from APS provided workshops, resources, conferences etc., has access to a huge pool of money to purchase legal and lobbying advice from the best “spin doctors” available…… the clinicals are now the gatekeepers infiltrating all systems within the APS and external to it including PBA, academic institutions, gov and non gov organisations… you just have to read the job postings… the clinical masters and endorsement is the default gold standard! They purport to be experts in ALL AREAS OF PSYCHOLOGY!

        Follow the money trail and be mindful of hidden agendas…… as Members of the APS we have a right to know how our funds are being administered. How and with whom are they, the Directorship and their representatives, consulting for legal and lobbying advice?

        I posted on the RAPS blog my concerns re overseas psychologists working in Australia as “clinical” endorsed psychologists…. From memory, the APS is the gatekeeper and membership of the APS from o/s candidates and examination is part of the visa administrative and selection process and AHPRA registration requirements…..Seems the APS Board now represented by “clinicals” is invested in increasing the numbers of their “clinical” membership even if it means recruiting externally i.e. UK and other countries rather than grandfathering from within! A sense of kinship/comradery clinicals supporting “potential” clinicals……. A huge marketing campaign….. overseas practitioners know there is good money in any work that is “clinical” in Australia!

        In my opinion, the APS Clinical College is a well-oiled covert machine with many tentacles and “group-think” mentality!

        “Groupthink, a term coined by social psychologist Irving Janis (1972), occurs when a group makes faulty decisions because group pressures lead to a deterioration of “mental efficiency, reality testing, and moral judgment” (p. 9). Groups affected by groupthink ignore alternatives and tend to take irrational actions that dehumanize other groups. A group is especially vulnerable to groupthink when its members are similar in background, when the group is insulated from outside opinions, and when there are no clear rules for decision making.”
        Janis, Irving L. (1972). Victims of Groupthink. New York: Houghton Mifflin.




        Has there been a breach of our Code of Ethics and is there a current conflict of interest within the current APS Board Directorship which is comprised of clinically endorsed psychologists (-1 Director) invested in their own agenda?

        and if there is… who is brave enough to fight the beast and lodge a notification with AHPRA?

        In my humble opinion the government and the Australian patrons of our services have been, and continue to be, misinformed.

        RAPS how will you ensure that clinicals with hidden agendas do not infiltrate the RAPS membership and sabotage our efforts for National reform?

        1. Hi concerned psychologist

          A lot of question/issues you raise in that post. Really snowed under here and not likely to be able to answer many … maybe later.

          One though, you ask:

          “RAPS how will you ensure that clinicals with hidden agendas do not infiltrate the RAPS membership and sabotage our efforts for National reform?”

          There can be no watertight guarantee on this, depends upon how clever individuals are in ‘certain areas’. In order to register for the forum certain information must be input to ‘required fields’ in a registration form. Those details are sent to RAPS who then vet each person and send them a confirmation email that their account has been approved. So there will be an approximate 24 – 48 hour wait period (sometimes longer) for account approval.

          Also there will be a ‘terms of agreement’, any community member not complying with those terms may have their account removed.

          Finally, within the community, we can determine ‘levels of access’ so very sensitive information may not be viewable by all community members. Obviously we would prefer that all members have complete access and we will be initially proceeding with that notion … and, then see what develops.

  1. I came across a blog which provides insight into the role the APS seems to have had and continues to have, in assessing UK applications for purpose of working visas for our UK collegues particularly those wanting to work as “clinical” psychologists in Aisyralia because they have been told/found out that there is a shortage of clinicals in Australia!!!

    So not only am I being pushed out of “clinical” practice, Im also competing with overseas practitioners!

    In this blog our system has been described as punitive and very “medicalized”. Makes good reading over a period of time….

    …and yet I cant work overseas because Im not endorsed in any area of psychology!


    they also mention a facebook page

    UK/Overseas Psychologists in Australia

    What do others know about this?

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