Unleashing the Potential of our Health Workforce - Scope of Practice Final Report Summary

Unleashing the Potential of our Health Workforce - Scope of Practice Final Report Summary 

On 5 November 2024, the Final Scope of Practice Review report was released.

The review process involved open submissions and structured and targeted consultation sessions. Osteopathy Australia attended multiple consultation sessions and provided detailed feedback via three formal submissions (one of which was a confidential submission). You can read more about our submissions here.

The review identified a range of issues that impact the ability of all primary care health professionals to work to their full scope of practice including:

• Consumers and health professionals have limited awareness of the scope of practice of other health practitioners.
• Legislative and regulatory settings restrict scope of practice in primary care.
• Funding and payment policies restrict scope of practice.

Eighteen recommendations have been put forward with the intention of removing major barriers that impede health professionals from practising to their full scope and that prevent multidisciplinary teams from providing the best care.

Osteopathy Australia is pleased to see that many of the key recommendations in this report align closely with those we have actively advocated and lobbied for, including:

• Developing a skills and capability matrix (Recommendation 1)
• Moving towards activity-based regulation rather than profession-specific regulation (Recommendation 6)
• Provision of direct referral rights to specialists (Recommendation 12)
• Ensuring governments commit to adopting and implementing these recommendations and reforms (Recommendation 13)

A complete list of the recommendations is available in  Appendix A.

We will continue to advocate for governmental agreement and action to see these recommendations and reforms implemented for the benefit of osteopaths and patients alike.  

Key recommendations that directly impact osteopaths:

Recommendation 1:

The development of a National Skills and Capability Framework and Matrix (the Matrix) to support workforce design, development, education and planning in primary care.

The Matrix aims to make the skills and capabilities of the healthcare workforce transparent. The Matrix intends to remove incorrect assumptions about the scope of practice of different professions. This will be a great tool to communicate the roles and capabilities the osteopathic profession holds and how they fit into the wider healthcare workforce to other professions, funding bodies and government agencies. A consumer-facing Matrix will also be developed to support consumer understanding.  

Recommendation 2:

The Australian Government establish a primary care workforce development program to support the development and retention of a skilled, stable and collaborative primary care workforce through the provision of enhanced curriculum, training/placement and career development capacities for students, supervisors/mentors and primary care health professionals.

The primary care workforce development program will provide support and resources for students, supervisors, mentors and health professionals to develop and maintain their skills in primary care and work to their full scope of practice. This program will ultimately support osteopaths to access education that helps them provide good quality care and develop skills to work as a part of a multidisciplinary team.

Recommendation 4:

Develop principles for interprofessional education and interprofessional capabilities for primary care, collaborative practice and First Nations health care to contribute to contemporary and consistent cross-professional learning and practice.

This recommendation will assist in ensuring that all health professionals have consistency in the skills and capabilities they hold within shared practice areas, helping to improve team trust and collaboration.

Recommendation 5:

Remove unnecessary barriers to supervision in primary care education and training, including those that impede cross-professional supervision.

• 5.1 The Health Ministers’ Meeting (HMM) request National Boards and accreditation authorities enable cross-professional supervision, where appropriate, to support education and training opportunities, including through the review of guidelines and accreditation standards that require (either explicitly or implicitly) supervision to be exclusively profession-specific.
• 5.3 The Australian Government review Medicare Benefits Schedule (MBS) rules and guidelines to ensure that all health professions are reasonably and equitably supported to undertake workplace-based placement supervision in primary care.

The aim of this recommendation is to allow greater flexibility in student supervision and to promote a greater appreciation of other professions while opening up more opportunities for education and development. This recommendation looks to support cross-professional supervision as a complement to profession-specific supervision but not to replace it.

Recommendation 6

Health ministers agree to progress activity-based regulation of scope of practice to complement the status quo protection of title approach. This would apply in instances where a clinical activity that is to be regulated through Australian, state or Territory legislation, excluding the National Law or National Registration and Accreditation Scheme (NRAS):

• Is effectively common or shared across a number of health professions, or has the potential to be
• Is a novel clinical activity not currently performed or undertaken only by a single discipline
• Meets an appropriate risk threshold
• Is in the public interest consistent with the objectives of the National Law, S3 (2) [a-f].

6.1 Health ministers agree to prospectively:

• Limit in future legislation and regulation the use of protected titles as the primary means of regulating and restricting activities in legislation unrelated to the National Law or the direct regulation of health professionals, i.e. shorthand references - and instead ,
• Adopt an approach based on assessment and management of the inherent risk associated with the activity being regulated or restricted.

6.2 The Health Ministers’ Meeting (HMM) request National Boards and the Australian Health Practitioner Regulation Agency (Ahpra) to commence identification of activities falling within an overlapping scope across professions, to inform relevant programs of review and potential harmonisation of existing legislation and regulation (see Recommendation 7), guidelines and standards, and/or education programs.

This recommendation seeks to address the prescriptive nature of regulation that tends to name professions who are authorised to perform particular activities or to be employed in particular settings. This ridged formula has resulted in osteopaths and other practitioners being unable to perform activities that are within their scope of practice. Instead, it has been recommended that an activity-based approach to regulation should be taken.

Recommendation 10:

Introduce a new blended payment to enable access to multidisciplinary health care delivered by health professionals working to their full scope of practice in primary care. This new payment would be supported by a significant growth in investment in primary care and would shift the mix of Australian government payments for primary care from a 90:10 fee-for-service: blended payment to 60:40 (at an aggregate national level).

  A new blended payment model will shift primary care funding away from a high majority fee-for-service system to one incorporating fee-for-service and other funding and incentive payment options. This recommendation hopes to encourage greater flexibility for primary care practices to employ or engage different health professionals to contribute to a multidisciplinary health care team. Osteopathy Australia highlighted within our submissions that the majority of allied health professionals' services are funded outside of Medicare and that this recommendation will require extensive funding to be placed into primary care to ensure appropriate infrastructure is in place such as digital health infrastructure

Recommendation 12:

The Australian Government implement new direct referral pathways for consumer access to specified non-General Practitioner (GP) specialist Medicare Benefits Schedule (MBS) items which meet the following criteria:

A. The direct referral made by the health professional is within their scope of practice.

B. The referral is accompanied by appropriate, timely notification of the consultation to relevant treating team members including the patient’s GP, and registered practice via digital mechanisms as available. In the first instance, these are recommended to include:

Allied health

• Physiotherapist, chiropractor, and osteopath referral to orthopaedic surgeon (e.g. when conversative management is not successful or where the patient presents with an acute or serious injury)

In line with our lobbying work, it has been recommended that osteopaths can refer patients directly to orthopaedic surgeons. Referrals are to be made when conservative management is not successful or when the patient presents with an acute or serious injury. The referral must be accompanied by appropriate, timely notification of the consultation to the relevant treating team members such as the patient’s GP and registered practice. This recommendation marks great progress in recognising the skills that allied health professionals hold and towards the provision of timely and more cost-effective care.

Recommendation 13:

Governments and key stakeholders commit and agree to progress the required reform program and governance structure to drive culture, leadership, implementation support and evaluation across the primary care system.

• 13.1 Australian, State and Territory governments agree to incorporate all relevant recommendations from this Review into the upcoming National Health Reform Agreement (NHRA), specifically into the respective schedules of the agreement which address agreed health system reforms.

This recommendation calls for a shared commitment from all governmental levels to progress and implement the recommendations and reforms put forward by this report. Osteopathy Australia will continue to lobby and advocate for this including in our upcoming pre-budget submission.

Recommendation 15

Governments, working with relevant professional associations, develop and implement communications and training strategies about the intent and substance of reforms to strengthen multidisciplinary primary care teams working to full scope of practice.

• 15.1 Embed a consumer co-design and consultation element in design and implementation phases associated with all recommendations.

This recommendation shows commitment to working with professional associations such as Osteopathy Australia during the communication, educational and implementation stages of these reforms and during implementation.

Recommendation 17:

The Australian Government mandates participation by all primary care providers in an accreditation program under the applicable Australian Commission on Safety and Quality in Health Care (ACSQHC) accreditation schemes, or other relevant accreditation programs, i.e.:

• National Safety and Quality Primary and Community Healthcare Standards
• National General Practice Accreditation
• Quality Care Pharmacy Program (QCPP)

17.1 The Australian Government implements a program of capacity building for clinical governance, risk management and quality assurance across the primary care sector to be supported by Primary Health Networks (PHNs) or other appropriate bodies.

This recommendation aims to ensure consistent clinical governance and practice quality standards across all healthcare facilities. This may result in osteopaths and osteopathic clinics undergoing routine accreditations. Osteopathy Australia will advocate for appropriate resources and funding to be provided to clinics if this recommendation is implemented.