Today’s correspondent asks
Re: Paramedic registration in the future, will persons holding the Diploma in Paramedicine be able to register under AHPRA, or only persons with a degree in same?
It’s impossible to answer questions like this with precision as final decisions will be up to the Paramedicine Board which is yet to be created and members appointed. This is what the fact sheet Health Practitioner Regulation National Law Amendment Law 2017: Frequently asked questions says (on p. 13):
How will ‘grandparenting’ of existing paramedics work?
The National Law sets out ‘grandparenting’ provisions, which apply for three years from the commencement of registration of paramedics (the participation day), in order to enable a person who is working as a paramedic to apply for registration even if the person does not hold an ‘approved qualification’ for registration, but has another relevant qualifications/s, training and experience practising the profession.
‘Approved qualifications’ for general registration for paramedics will be decided by the National Board after it is established. The intent is to ensure that practitioners who are legitimately practising the profession have a way of seeking registration and are not disadvantaged because they are not recent graduates. This is especially important because no state or territory in Australia currently has a registration system in place that could ‘automatically’ transition state and territory registered paramedics into paramedics registered under the National Law.
The proposed grandparenting provisions in the draft Bill state that an individual is qualified for general registration in paramedicine if the individual:
- holds a qualification or has completed training in paramedicine, whether in a participating jurisdiction or elsewhere, that the Paramedicine Board considers is adequate for the purposes of practising the profession; or
- holds a qualification or has completed training in paramedicine, whether in a participating jurisdiction or elsewhere, and has completed further study, training or supervised practice in the profession required by the Paramedicine Board for the purposes of this section; or
- has practised paramedicine during the 10 years before the participation day for a consecutive period of 5 years or for any periods which together amount to 5 years and satisfied the Paramedicine Board that he or she is competent to practise paramedicine.
As indicated above, these grandparenting provisions will not apply in relation to the NSW vocational qualification specified in the Bill.
It is also important to note that all of the other eligibility requirements for registration, for example criminal history and identity checks, set out in section 52 of the National Law will apply to everyone seeking registration.
The more detailed COAG Health Council, Summary of the draft Health Practitioner Regulation National Law Amendment Law 2017 says, at p. 39:
This new section provides for grandparenting of qualifications for the existing paramedic workforce to enable them to obtain registration under the National Scheme, for a period of three years from the participation day (note that another provision, outlined below, deals with practitioners who hold a Diploma of Paramedical Science issued by the Ambulance Service of NSW).
This new section provides that an individual who applies for registration in paramedicine before the “relevant day” (a defined term meaning the period of three years from the participation day) is qualified for general registration in paramedicine … [if they hold the qualifications and/or experience listed above].
Unfortunately the draft Bill is not available so all we have to go on is these documents. The first paragraph, above, might suggest that the grandparenting provisions allow a current paramedic to ‘obtain’ registration for three years, leaving the inference that during that time they have to obtain a board ‘approved qualification’ (unless the Board approves their current qualification) to continue their registration after three years.
The second paragraph, on the other hand, says that an individual with the training and experience listed and who applies for registration within the first three years of the registration scheme ‘is qualified for general registration in paramedicine’. The implication there is that provided the person obtains their first registration within three years, they will be eligible for general registration and will be entitled to continue that registration after the three year period. This would be consistent with the stated aim of ensuring ‘that practitioners who are legitimately practising the profession have a way of seeking registration and are not disadvantaged because they are not recent graduates’.
My understanding is that it is the second interpretation that is intended: that is a person with a current qualification and/or experience will be able to apply for general registration within the first three years of the scheme and once registered will be able to maintain their registration without having to upgrade to a Board ‘approved qualification.’ As noted however, without the actual text of the Bill, and more importantly the Act when passed, it is impossible to confirm that one way or the other. Those that have been actively involved in the development of registration and who have seen the draft Bill may be able to add more comment here.
The reference to ‘the NSW vocational qualification’ is important. To ensure that NSW joined the national scheme it was agreed that the vocational paramedic qualifications offered by NSW ambulance would be sufficient for general registration. Whilst the Board will determine the approved qualifications for general registration for paramedics, they will have no choice but to accept a person who holds a paramedic qualification issued by NSW is (subject to them meeting the other requirements for registration) eligible for general registration. The relevant qualifications are (COAG Health Council, Summary of the draft Health Practitioner Regulation National Law Amendment Law 2017 p. 5):
- Diploma of Paramedical Science;
- Diploma of Paramedical Science (Ambulance);
- Advanced Diploma of Paramedical Science (Ambulance);
- Diploma in Paramedical Science (Pre-Hospital Care); or
- Advanced Diploma Paramedical Sciences (Pre-Hospital Care).
It should be noted that a paramedic is eligible for registration if he or she ‘holds a qualification the National Board … considers to be substantially equivalent, or based on similar competencies, to an approved qualification’ (Health Practitioner Regulation National Law s 53(b)). If the NSW Ambulance qualifications were ‘approved qualifications’ then anyone with a ‘substantially equivalent’ diploma could also seek general registration and be exempt the grandparenting provisions (that will only apply for 3 years). To stop that happening the Bill (COAG Health Council, Summary of the draft Health Practitioner Regulation National Law Amendment Law 2017 p. 40) will declare that the NSW Ambulance qualifications are not:
… an “approved qualification” for section 53(b).
The Paramedicine Board will decide what qualifications are “approved qualifications” for section 53(a) and (b) after it is established. A person will only be qualified for general registration in paramedicine under section 53(b) if they hold a qualification which is substantially equivalent to, or based on similar competencies as, an “approved qualification” decided by the Board.
What this means is that if you hold a Diploma in Paramedicine issued by someone other than the Ambulance Service of NSW, you will not be able to argue that this qualifies you for general registration on the basis that your Diploma is ‘substantially equivalent’, or even identical, to the NSW Ambulance issued diploma.