FOI Documents

Here are the freedom of information (FOI) documents for all of the official APS submissions related to Government about the formation of the present Better Access scheme. It was lodged with DoHA on 19 June 2009 and included all letters and formal documentation sent by the Australian Psychological Society (APS) to DoHA during the years 2005 and 2006, excluding the main text of email correspondence.

In total there were three proposals on how the scheme should be structured: one lodged in late May 2006, a revised proposal in early July 2006, and a final proposal in mid August 2006.

The main document is the 2006 May 28th submission that the APS made to the Department of Health and Ageing (DoHA) on the development of the Better Access to Mental Health Care scheme.This document is the first APS Proposal (28 May 2006) which states on the second last sentence of page 2

“All applicants will have to meet a range of requirements equivalent to those for eligibility to the APS College of Clinical Psychologists in order to be admitted to the Register”.

That term ‘Register’ refers to a single list of Medicare approved psychologists, which the APS defines in each document in terms of status as a clinical psychologist or equivalent.

There is no mention in any document that the APS submitted to DoHA in either 2005 or 2006 of another category of practitioner – that is, no mention of generalists, or a lower tier.

These documents demonstrate that the APS did advocate for a single tier system, however, that tier was structured in a way that is identical to what is now the top-tier.

That is, eligibility to be a Medicare provider of psychological care was assessed in terms of membership of (or equivalence) the APS College of Clinical Psychologists.

The above quotation is important because it directly contradicts what APS members have been told. For example, in the June 2009 edition of InPsych Lyn Littlefield states:

“It is worth noting here that the original APS position in the negotiations before the introduction of the Better Access initiative was for a broader definition of a ‘clinical and mental health specialist psychologist’ that was not restricted to those eligible for Clinical College membership.”

There was no evidence in the documents obtained via FOI that the APS ever advocated for what is now the lower tier of ‘generalist’ psychologists. Not a single submission was provided to DoHA about that in either 2005 or 2006 prior to the scheme launching.

The FOI investigation captured every official policy recommendation from the APS about the Better Access scheme, as the program was being initially developed across 2005 and 2006. The two-tiered system for psychologists was then launched in November 2006.

The response from the APS to this FOI request was obstructive and stalled the process for nearly a year, forcing the decision to go to the Administrative Appeals Tribunal.

On each occasion, the APS waited until the last few days of the 30 day objection period, then at the last minute objected. That action stalled the process for the maximum time possible.