The APS is pleased to provide a response to the Psychology Board of Australia’s (PsyBA) second consultation of the Redesigning the psychology higher education pathway project.
In preparing this submission, the APS has listened to our members and it is clear that the proposed single five-year model carries significant risks that have not yet been sufficiently analysed, modelled, or mitigated.
The APS supports reform and improvement of the current system which can be complex, costly, and inequitable. We welcome reform that improves clarity, equity, integration of theory and practice, and work readiness. But the current proposal requires substantially more evidence, modelling, and structural safeguards before it can be considered a safe and effective redesign of the psychology training pathway.
We remain concerned the current proposal:
• Does not centre public safety and competency assurance.
• Has long-term implications for the psychological science and psychology academic workforces and ultimately the scientist-practitioner model.
• Does not adequately address core barriers affecting the psychology workforce, including placement capacity, supervisor availability, psychology Commonwealth Supported Places, funding, retention, public sector conditions and regional workforce incentives.
• Constitutes a reduction in training standards by shifting from AQF Level 9 to AQF Level 8, potentially impacting research literacy, scientific rigour, clinical reasoning, public trust, remuneration, and professional identity.
• May affect the professional standing, credibility, and international recognition of Australian-trained psychologists, ultimately impacting international equivalence and mobility.
• Does not articulate university implementation and viability, student selection, transition arrangements, and practical impacts on the academic and research workforces.
• Presents risk to some Areas of Practice Endorsement by being ‘industry led’ and ultimately dependent on employer support, location and service capacity rather than public, professional, and system need.
• Includes a “Bachelor of Psychological Assistance” before the scope of practice, supervision requirements, regulatory framework, title protection, and employment conditions for psychology assistants have been defined.
View submission