The APS was pleased to respond to Ahpra’s consultation on the draft revised Recency of Practice (ROP) and Continuing Professional Development (CPD) registration standards.
While the APS broadly supports Ahpra’s objective of ensuring psychologists remain competent and connected to practice, we raise strong concerns about the proposed changes to the ROP standard for psychology.
The APS does not support the proposed change from the current requirement of 250 practice hours within five years to 150 hours in the previous 12 months or 450 hours in the previous three years. Our arguments include:
• The proposal is not sufficiently evidence-based for psychology and there is limited research supporting a specific minimum-hours threshold as a measure of competence
• Psychology competence is maintained through multiple mechanisms including CPD, peer consultation, supervision, reflective practice and ethical obligations, not just practice hours.
• The proposed requirements could disproportionately affect psychologists with part-time, interrupted or portfolio careers, including those taking parental leave, caring leave, disability-related leave or transitioning to retirement.
• More rigid requirements could reduce workforce participation and worsen existing psychology workforce shortages and access to services.
APS recommendations include:
• Retain a longer timeframe for demonstrating recency of practice.
• Introduce a clear, proportionate and risk-based pathway for practitioners who do not meet the hours requirement.
• Provide clear transitional arrangements and guidance if, despite opposition, changes proceed.
The APS is generally supportive of the proposed CPD standard, as it largely aligns with existing psychology requirements.
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