NDIS: Another Psychological Unicorn

The Clinical Unicorn has invaded the NDIS – It’s a Two-Tiered System

From the Final Report document:

You can download the full report here.

It’s time for all the disenfranchised psychologists, and the clients of the NDIS who are about to be unnecessarily out of pocket to get fully behind what RAPS is very soon to offer all of you.  It’s also time to search your own value systems and ask, “Why are you still not fully engaged with us in the cause for equity for ALL”!

Importantly, do not leave it all to RAPS, do what you can yourselves.

Very soon now our new web site and community forum will be launched.  It’s vitally important that ALL psychologists and other stakeholders who agree with RAPS purposes join this united effort.

28 thoughts on “NDIS: Another Psychological Unicorn

      1. “Primary Health Network Advisory Panel on Mental Health

        On 23 March, the Minister for Health announced the establishment of the Primary Health Network Advisory Panel on Mental Health (the Advisory Panel)

        Page last updated: 28 July 2017”

        Guess who was on this advisory panel representing Psychologists?



        Non clinical APS members in “clinical practice” WAKE UP!

        1. Guess who was a member of the Mental Health Australia Board for 10 yrs from I believe 2005 – 2015 (a time of huge change in our profession ie National Reform – AHPRA, PBA, endorsements and 2 tier implementation and other discriminatory, defamatory and restrictive trade impositions?



          Non clinical APS members in “clinical” practice” WAKE UP!

              1. Who has heard of the Australian College of Private Psychologists in Clinical Practice? They are the Victorian affiliate of the umbrella Psychology Private Australia. How about some of you Melbourne mob give us an update on that? Our local branch is the Private Practicing Psychologists NT. I love my clinical practice.

                1. Association of Private Practising Psychologists (NT)

                  Psychology Private Australia Inc.
                  Department of Health
                  Medicare Review

                  The two-tier Medicare rebate system under the Better Access scheme, provides greater payment for ‘Clinical’ psychologists’, despite the absence of evidence to justify this inequity. The latest research and post hoc analyses show there is no difference between the treatment outcomes of ‘clinical’ and other registered psychologists .

                  The negative impact on the profession of Psychology and on Australia’s mental health clients of the two-tier system include:

                  1. Disadvantage to the public due to a shortage of ‘endorsed’ Clinical Psychologists in some districts and roles, while other fully registered psychologists who have been shown to produce equivalent outcomes, are sidelined.
                  2. Unreasonable limitations to access to competent assessments and reports which can be provided by other competent registered psychologists – especially those already residing in rural and remote areas, effectively providing services with versatility, experience and understanding of local social and cultural conditions.)
                  3. Additional costs for Government, NGO’s and for-profit organisations for no benefit.
                  4. Discriminatory practices towards registered psychologists and financial disadvantage to clients of registered psychologists, who provide the same level and complexity of work and achieve similar results as ‘endorsed’ Clinical Psychologists.
                  These negative consequences of the two-tier system can be alleviated by converting to a single tier for the Medicare rebates for Psychologists under Better Access.
                  We strongly support evidence of knowledge and competence. (For example is a clinical, counselling or generalist able to do the job?) We believe all can, thus we stand on competence not arbitrary comparisons, prejudice and discrimination.
                  The APPP NT recommends that a process be developed in consultation with the psychology workforce to design and implement a competency based accreditation system which may be similar to those of other allied mental health professions (e.g. Social Workers).
                  Accreditation can be supervised by organisations such as the Australian Psychological Society (APS), the Australian Association of Psychologists incorporated (AAPi) or a ‘peak’ organisation whose members specialise in private practice, such as Psychology Private Australia incorporated (PPAi).

                  We believe that all competent Psychologists’ sessions are worth more than the higher medicare tier rate of $124.50. The current $84.80 generalist rate is inadequate. Properly resourcing psychological services can save the Commonwealth money and generate economic growth.
                  A macro-economic argument for greater expenditure on psychology medicare items follows: Medicare payments are paid to Australians in Australia. There is a multiplier effect of medicare payments to Australians as most of the revenue is circulated within Australia, and boosts the economy. In general, medications such as antidepressants do not properly fix mental health problems. Antidepressants down-regulate the nervous system and may consequently create dependency without cure. Yet large portions of Commonwealth MBS revenue are spent on medication and in large part sent offshore. This leads to a reverse multiplier effect which adversely impacts our national balance of payments and as a consequence harms us all.
                  We recommend the Medical Benefits Scheme shift funding from pharmacology to psychology, save money, improve outcomes and keep the revenue in the country.

                  Government mental health revenue would be far better spent on increasing the medicare rate for all competent psychologists on a single appropriate tier, thus enabling greater mental health recovery rates and keeping revenue in circulation.
                  In conclusion, a single tier system is a fairer and more sensible system for the public to have a wider choice of practitioners providing an effective range of interventions, as with other mental health professions such as Psychiatry and Social Work.

                  Implementation of this proposal will provide significant benefits for clients, practitioners and government.

                  We ask for your positive consideration in promoting fair, equitable and effective psychological services in Australia for the benefit of all.

                  Yours sincerely 25/9/2017

                  Gregory Goodluck, Chair of the Northern Territory Branch of the Association of Private Practicing Psychologists (APPNT)
                  Written in consultation with and on behalf of the APPNT membership.

                  1. The contributers to the above letter to MBS by the PPPNT included clinical psychology input. It is possible to work together for the common good. ACPA and the APS are creating uneccessary divisions. Which reminds me. When are we going to start the APS College of General Practicing Psychologists?

                    1. I dont want to subscribe to an APS College that brands me a General Practising Psychologist …

                      In my opinion…..The label ‘General’ Psychologist holds NO VALUE! … it will only serve to justify the clinical lobbying position (refer to the clinicals’ submissions) that we are only qualified to provide the basic/ general £%#*•¥ focused psych strategies! REALLY??? These are the same as psych therapy approaches WHAT A JOKE WE PROVIDE THE SAME… its not rocket science!

                      What about something like…..the APS College of Applied Psychologists?

                      And the PBA can endorse us as such!

                      We can have our own committee with reps from all subgroups! Membership open only to APS Members who do not “qualify” for other APS Colleges!

                      Scrap the APS Division of General Psychological Practice! in my opinion an ineffective forum model chaired / controlled by the APS ED and president just a clearing house of non college members grievances! There is NO SUCH THING AS GENERAL PSYCHOLOGICAL PRACTICE!

                      APPLIED PSYCHOLOGY ….According to Google….

                      “Some of the areas of applied psychology include clinical psychology, counseling psychology, evolutionary psychology, industrial and organizational psychology, legal psychology, neuropsychology, occupational health psychology, human factors, forensic psychology, engineering psychology, school psychology, sports …”

                      One way of fixing up the mess!



                      another interesting read!

                  2. College of Applied psychology sounds good. But it’s a bit General. Where do I apply?
                    I struggled with the seemingkysomewhat degrading use of the term ‘General’, but recent chats with colleagues help me to see that reappropriating the term could be useful as other oppressed groups have done with their negative labels. Think “Niggas With Attitude (NWA)”, “Dykes on Bikes”, “Queer” theory/politics, “Wogboys” etc. And then of course we have the College of General Practice among the medical profession who embrace and celebrate the honour of being versatile, flexible, multimodal, eclectic and highly responsive. I recently learned of a highly respected GP at a Private hospital who specialises in neurological pain issues, receive a referrals from neurologists and commands high fees. To me generalist are far better equipped to grapple with the complexities of difficult cases precisely because they are across many more aspects and treatments than most specialists. For example Generalist are far better prepared to assist people in complex situations such as participsnts in the NDIS, than your average clinical psychologist, precisely because General Practice makes you versatile, resourceful, holistic and integrative with a functional focus on causes not just labels and medication.

                    1. Perhaps General psychologists deserve higher fees than Clinical psychologist for remaining General across a broad range of issues and modalities making them more capable of adsisting a wider sample including but not restricted to mental health clients instead of a blinkered pathologising focus of those psychologists who claim their subspecialisation gives them superiority worthy of higher pay and respect which just disadvantaged the public.

                    2. OK so isn’t that good if APPLIED PSYCHOLOGY encompasses ALL.

                      Good luck to doctors. We are not GPs.

                      As we know… ALL Psychologists in Australia have GENERAL registration!

                      I believe that the APS continues to promote generalist psychologist because their vision was always to have 2 areas of psychology (equating to 2 tiers) ie those with masters and endorsements would be the specialists (level 1) and those without the generalists (level 2)… i believe they were advocating and lobbying gov for two levels of registration ie specialist and generalist… then something happened and National Law did not recognise specialist or specialisation in psychology and to state you are contravened law with huge penalty up to $30000.

                      Dont you recall the APS marketing their SPECIALIST DIVISION and GENERALIST DIVISION?

                      I believe many clinicals have been public in viewing themselves more expert in mental health than psychiatrists and have advocated for prescribing rights!

                      In my opinion it would be easier to introduce a new title than to try to repackage a misconceived old title where in trying to do so the public remains clouded and confused re the mirky and defamatory definition of GENERAL.

                      In my opinion to achieve what you propose… possibly a psychology nirvana…. unless there is a well funded and targeted apology from APS and PBA via intensive education, advocacy and marketing campaign to inform ALL National consumers and policy makers and the International community of what you state or redressed endorsement via a grandfathering process I predict a bleak outcome…

                      “General” in the view of the activist arm of clinicals and other endorsed psychologists in my opinion and based on all the evidence to date from within and external to APS including PBA and gov health/mental health/ TAC WorkSafe, Centerlink, DVA , job recruitment processes etc equates to BASIC SKILLS, BASIC TRAINING, LOWER REBATES/FEES

                      Dont you see? If we are Generalists then with the proposed changes in legislation that clinicals and others are lobbying for all endorsed psychs will become the default Specialists and many have multiple “specialties” without the evidence of multiple master degrees and the 2yrs of supervision for those areas! You would be a very old person practicing under multiple up to 3 or 4 endorsements if you had followed the rules for attaining multiple areas of endorsement! Obviously they were easily bridged! I wonder who signed off on the multiple endorsements for many APS College members?

                      In my opinion we the non endorsed have been pushed aside, left behind in the stampede of those status seeking colleagues… must’ve been hard as a WA registered clinical psychologist to lose a specialist title and the justification of greater renumeration…

                      We the non endorsed need endorsement status for our right to be recognised as competent within our areas of practice as defined under National Law.

                      I cant see how this will ever be achieved as we are continuously discredited, defamed and discriminated against, viewed as the radical aggrieved minority who should be ever thankful for being registered.

                    3. Thank you CP for raising this again. I agree – the term ‘general psychologist’ is quite misleading and promotes the idea of specialist psychologists that do not exist. We should rightly reject it in favour of ‘applied psychologists’ or perhaps ‘professional psychologists’ in line with the growing number of 5+1 Master of Professional Psychology programs. I think it’s critical to espouse that all psychologists, regardless of pathway to registration, are professionals with considerable training and expertise; something that certain sections of the profession seem unable (or unwilling) to acknowledge.

                    4. Thank you James C.

                      Are we not ALL professionals?

                      I dont like “ professional psychology” which is advertised as a basic GENERALIST masters to qualify graduates for GENERALIST supervision for GENERALIST REGISTRATION according to monash website…. (as if there is another form of registration!) again in my opinion we will be unworthy of recognition of expertise…the academics are gearing up for the generalist/specialist registration dichotomy….

                      According to the Monash Uni website….
                      “Professional Psychology
                      The Master of Professional Psychology is a one year course designed to meet the requirements of the Australian Psychology Accreditation Council (APAC) and the Australian Health Practitioner Regulation Agency (AHPRA) for a generalist fifth year in psychology.

                      The course prepares selected psychology graduates in advanced psychotherapeutic skills required for general registration as a psychologist. It develops your professional capability to apply the theoretical, research, assessment and therapeutic skills involved in psychology. Following graduation, you will be eligible to undertake one year of supervised generalist practice – you will then progress to full registration as a psychologist.”


                      WE ARE NOT GENERALISTS!

                      We need a title that STANDS OUT and ENDORSES OUR VARIED COMPETENCIES

                      Maybe you are right Gregory due to our comprehensive multi modal training and therapeutic application and competence acquired over many years WE The non endorsed SHOULD BE THE APS COLLEGE OF SPECIALIST PSYCHOLOGISTS….

                      After all the APS preaches to their non college members that we are a broad church….

                      I have lost all faith in any change and if this crap persists I will be transitioning to an early retirement !!!!

                      ITS A JOKE

                  3. Hi Concerned Applied Psychologist, (reached the end of the blog thread capacity, hope RAPS fixes the blog soon). In response to your response…
                    You and I are on the same page. Reading the submission for Specialist recognition by our fearless President that you gave us a link to, deepens our understanding of the diabolical long-term campaign to boost demand for extended university careers. Thanks. In it, some years ago, our current APS president stated he believes psychology associations are reluctant to support specialist titles because of political and economic expediency of having a majority membership of General psychologists, or words to that effect. He is Now the president of one of such psychology peek bodies that neither openly supports nor decries the push for specialisation and artificial discrimination he so desperately advocated for back then.
                    The other interesting enlightening factor is that our President is oft quoted as referring to Australian psychologists as the worst trained in the western world (presumably because there are less “doctorates” here although different countries have different definitions and requesits for different titles, and as we all know, a fully registered psychologist working in the field and keeping up with the research is excellent.).
                    As there is no real standardisable evidence of quality of psychological training across the globe, what does our President mean by “in the Western World”. Given that his illconceived failed attempt in his earlier submission to maintain specialist registration for Western Australian clinical psychologists and roll it out over Australia has its factual epicenter in Western Australia, what is his meaning by “The Western World”. Surely not “Western Australia”. Could he be interpreted as saying Australia has the worst trained psychologists in Western Australia? Surely not! But what standardised comparisons is he drawing on? please explain Mr President. Why did you say Australian Psychologists are the worst trained in the Western World. Clarification is needed. Do you only believe in university? The world is bigger than that just as Australia is a supracategory to Western Australia. Perhaps WA should secede after all. It tends to want to be unique in most COAG matters throughout time.
                    Secondly, Concerned, Applied psychology is the distinction from Theoretical psychology and may also be distinct from research psychology, but is way broader than alot of the clinic based mental health and wellness practice alot of us do.
                    (There are ways of ascertaining competence in mental health assessment and treatment without higher degrees. other disciplines do it.)
                    I think “Applied” psych is too broad and “generalist” is not ideal either, but we need to appropriate it moving forward. We need to sublimate our rage, transubstantiate the label, transcend the condescension and choose our way forward with names that we choose.
                    Personally I find the term Psychologist sufficient and a subdiscipline of my own Specialisation, holistic psychosocial mental and emotional health and community wellbeing work.
                    If people ask me what kind of psychology I do, I tell them what I do.
                    Consulting Psychologist is one title esteemed colleagues use.
                    Mental Health Psychologist is similar to Mental Health Occupational Therapist etc.
                    Integral psychologist is getting around as is Integrative Psychologist along with integrative medicine. There are functional medicine doctors and there should be functional psychology psychologists. There are Holistic Psychologists with Bio-Psycho-Social-Cultural-Spiritual paradigms of integrative care and assessment, of which I am one who would love the chance to do a doctorate in applied integral psychology and functional medicine.
                    Meanwhile we have to deal with the narrow minded Kafkaesque career climbers who want their tiny subspecialty to be the be all and end all so they can feel important and get rich.
                    I embrace ‘generalist’ as holism and integralism and hope to be a doctor of General and integral psychology one-day. I don’t need the title to apply the processes and paradigms. My ego can cope and needs to be subordinate to my soul (AKA Psyche) anyway. So thanks for helping us see the folly in too much hangup on titles. Specialisation is a dinassaur. Integral holism is the way of the future and with computing power and growing algorithms it is now very very possible to be very General and very deep. unlike those who choose to continue to promote the antiquated “iron cage” of rationalisation and specialisation written about by Sociologiist Max Weber at the beginning of last century (“The Protestant work Ethic and the Epirit of Capitalism.” 1905), where modes of production (of goods and services) are so specialised that we lose the forest for the trees.
                    Our APS President sees some of the forest but cares only for trees of his own species. No. actually he is a dinosaur grazing on the trees. We are the trees and the forest and he is a preditor..

  1. Looking forward to the RAPS website and facebook page. Importantly these web links can be ‘shared’. Hoping that a paper or letter (as you like) written by a RAPS member recently posted on this ‘reform APS’ site will be available as it gave a very good explanation of the constructed divide of the issue of clinical vs generalist.

    1. Hi K.B.

      Which paper/letter are you referring to? If you tell us we can make it available. Also we have been talking about a Community Forum which is a very different thing to Facebook.

  2. I am a very skilled and experienced clinical professional. No worries.
    The NDIS is about matching services to needs. Complex cases requiring complex interventions get more money. It is that simple. Consumers get to choose their providers.
    This is going to get very, very interesting!!!!

    1. Hi Gregory, I have not gone the path of registering for NDIS yet. I am interested to know how do they judge if you are very experienced? Is it a generalist vs clinical, a how long you have been practicing thing or something else? Thanks in Advance.

      1. Hi Leanne, The whole thing is a work in progress. Alot of these terms are open to interpretation. At the end of the day the consumer is supposed to have greater power. This issue really brings into sharp focus the issue of discrimination within the profession of psychology and the self serving superiority complexes of the clinical lobby versus the rights and wishes and needs of the consumers, many of whom have trusted psychology clinicians that they are already engaged with or may be recommended that are not ‘endorsed clinical’ by virtue of clinical college membership.
        This is another opportunity to highlight the lack of empirical evidence and injustice towards the public.
        There needs to be a different yardstick for clinical competency than endorsement or college membership. Because as we already know only too well, having a special star stamped on your belly doesn’t make you a better sneetch than everyone else.
        Many excellent General Psychologists can do exceptional clinical work with clients that bedazzles many endorsed clinicals. Many excellent General Psychologists train clinical psychologists and supervise them in clinical practice.
        This is a bureaucratic madness born of laziness, to simply categorise people by the most obvious distinguishing characteristic available. It is called discrimination and bigotry in other words.
        Sick to death of the smug clinicals blowing their own trumpet to create a market scarcity they an cash in on. It really is a travesty against the most vulnerable members of society and their families.
        This sort of arbitrary discrimination against the majority of excellent psychologists that may well create gap payments for the public or preclude them from using the excellent clinicians they wish to use, has to be appealled against by General Psychology and the consumer groups together.

  3. This needs to be exposed to all psychologists, the general public and to politicians. Yet another FOI request is warranted. The clinical dominated APS has been at it again. AAPi needs to be contacted about this.

    1. Im wondering if the clinicals are double dipping!

      If they qualify as both “registered psychologist” AND “clinical psychologist” which seems to be how government funding bodies etc are categorizing us ie Medicare and now NDIS can they access the funding of sessions under BOTH TIERS ie ALL ITEM NUMBERS? So essentially with Medicare 10 + 10 individual and 10 + 10 group and with NDIS all funding ie less complex to more complex????


      Can someone with influence please inform government that the “clinicals” DO NOT BY DEFAULT have more experience working with COMPLEX “clinical” cases?

      1. Hi Everyone,

        If you want to protest with regards to this decision below you will find Some Contact Details:

        Dan Tehan

        Minister for Social Services

        190 Gray Street
        Hamilton, VIC, 3300

        Telephone: (03) 5572 1100
        Fax: (03) 5572 1141
        Email: dan.tehan.mp@aph.gov.au

        Jane Prentice

        Assistant Minister for Social Services and Disability Services

        Phone: (07) 3378 1599
        Fax: (07) 3378 1399

        PO Box 704
        Indooroopilly, QLD, 4068

        Email: Jane.Prentice.MP@aph.gov.au

        Rob De Luca

        CEO NDIA

        Email: ceo.office@ndis.gov.au

        Regards, Jenny

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