June 25, 2015 Council of Physiotherapy Deans Australia & New Zealand Wendy Nickson Health Workforce Consulting Dear Wendy, Re: Accreditation Standard for Entry-Level Physiotherapy in Australia: Draft One, May 2015 The CPDANZ welcomes the opportunity to contribute to the above document being the first draft of the standard that Australian entry-level physiotherapy courses of study must meet for accreditation. The collation of CPDANZ member feedback to the document has been led by Shylie Mackintosh (Physiotherapy Program Director, The University of South Australia). In the following pages, the responses of the CPDANZ membership are itemised according to the questions posed as part of the consultation process. The CPDANZ looks forward to continued engagement with HWC in further refinement of the Accreditation Standard. Regards, A/Prof Liisa Laakso, PhD President, CPDANZ
Domains and Sections 1. Are the Domains and Sections relevant and appropriate? Domains and sections seem appropriate. The CPDANZ welcomes the reduction in duplication and efficiency of elements that now exists. The inclusion of a student domain is well received. However, there were some suggestions as to whether all sections within the domain of students are required. Some of this information is likely to be covered within other University compliance processes and thus the necessity to include it at a physiotherapy program level is questioned. For example, Section 1.1.1, 1.1.2 (systems for admission), 1.3.2, 1.4.1. For some universities, some sections in this domain are not specific to physiotherapy programs. 2. What changes (if any) should be made to the names of the Domains and Sections? Nil comments. 3. Are there any Sections that belong in a different Domain? Section 5.4 Leadership appears to overlap with staffing. Consider moving leadership from Governance to the Resources and Infrastructure 2.3 Staff. The CPDANZ suggests that in its place in Academic Governance there could be a strengthening of ensuring the Physiotherapy program sits in an appropriate organisational structure. 4. Are there any Domains or Sections that should be added? The CPDANZ notes that Research environment and outcomes appear to have been removed. As Research is a primary function of academic units at universities the CPDANZ suggests this element be reinstated to ensure the evidence base and underpinning science of the profession of physiotherapy continues to be led appropriately. 5. Are there any Domains or Sections that could be removed? Nil comments.
Standard Statements 6. Are there any Standard Statements that should be added? (please give reasons) 3.1 Learning outcomes and assessment Given the expanding scope of practice in expanded settings, the CPDANZ suggests consideration of the inclusion of a statement that reflects the preparation of graduates for the future of health care practice. 7. Are there any Standard Statements that could be removed? (please give reasons) Section 3.1.2 The CPDANZ contends that this section is redundant as the matter is extensively covered in the Physiotherapy Practice Thresholds. Provision of this evidence would repeat evidence supplied in 3.1.1. Section 4.3.5 The CPDANZ contends that this section is redundant, as all quality review processes are required to be detailed in sections 4.3.1 to 4.3.4. Standard 5.1.1 This information can be easily located at: http://www.teqsa.gov.au/national-register. This could be a checkpoint for new programs at new institutions, and does not seem necessary beyond this step. Standard 5.1.2. The wording of this section is unclear and could be misinterpreted as it seems to imply that physiotherapy staff works diligently and effectively on university governance functions. If included, this section should relate to the physiotherapy program. 8. Are there any Standard Statements that are ambiguous or unclear? (please suggest alternative wording) 3.1.4 The assessment of Physiotherapy practice competence is undertaken by suitably qualified and experienced physiotherapists. The Physiotherapy Practice Thresholds document states, The context of a physiotherapist s practice may not be limited to (and may not include) direct clinical care. Many of the abilities described in the key competencies are required in direct non-clinical relationships with clients. The abilities are also required when registered physiotherapists work in management, administration, education, research, policy development, advisory contexts, regulatory or other contexts that have an impact on safe, effective delivery of health services in physiotherapy. The implication for practice is that it will not always be feasible for assessment to be conducted by a physiotherapist. Students who are experiencing role emerging placements are unlikely to be directly supervised by a physiotherapist. Other professionals could assess a number of the roles in the Physiotherapy Practice Thresholds document, e.g., professional and ethical practitioner, communicator, reflective practitioner and self-directed learner, collaborative practitioner, educator and manager/leader. Therefore, the CPDANZ suggests that the Accreditation Standard needs to reflect the new Practice Threshold statement.
3.2.2 "A contemporary educational framework is utilised in the design and delivery of the Physiotherapy course of study" Some suggestions were noted that the use of the word contemporary requires further thought. That is, contemporary in the year 2015 may not be acceptable nor necessarily of a higher quality than an alternate framework in the year 2020. Moreover, there is little evidence to support one educational framework over another. 3.2.3 e. The CPDANZ suggests a change to knowledge and skills for working effectively and collaboratively in the public and the private sectors 3.3.1 "Students of the Physiotherapy course of study develop the knowledge and skills necessary for evidence-based practice" The CPDANZ suggests adding 'develop the knowledge, skills and research literacy necessary for evidence based practice' 4.3.3 The CPDANZ suggests changing this section to Clinical placements of sufficient type and quality are obtained for the number of currently enrolled and/or planned students in the Physiotherapy course of study. The use of the term Assured is problematic as there are so many external factors that impact the provision of clinical placements. Some states in Australia have witnessed an unprecedented increase in physiotherapy programs, which is now placing an increasingly significant burden on clinical placement sites. The CPDANZ would seek the following: - a process for determining the capacity of new programs to have assured access to quality clinical education placements without undermining or restricting access to such placements from currently accredited programs; and - procedures that would identify the need to the profession for a new program in a particular state or location For the review of the Accreditation Standard, the CPDANZ contends that "Assured" may not be the most appropriate term as it means placements will be "guaranteed; sure; certain; secure" for a time some distance in to the future. "Obtained" is a more appropriate word for this context and means "to come into possession of; get, acquire, or procure, as through an effort or by a request". 1 The proof for obtaining sufficient and suitable placements may require another form of standard. 4.3.4 "The results of regular interim monitoring, comprehensive reviews, external referencing and student feedback are used to mitigate future risks to the quality of the education provided, including the use of data on student progress and success to inform admission criteria and approaches to course design, teaching, supervision, learning and academic support." The CPDANZ suggests the addition to last part '...approaches to course design, course content, teaching, supervision...' 1 Ref: Dictionary.com
9. Is there any duplication in the Standard Statements? (please suggest changes) See question 7 Are there any standards that can be removed? for details of these standard statements 3.1.2 3.3.2 overlaps with 2.3 Staff and can probably be removed 4.3.5 5.3.1 10. Are there any Standard Statements that could be more specific? (please say how) 1.1.2 There was a suggestion by a few CPDANZ members that an IELTS 7 (in all four sections) should be included thus using the same criteria as required by AHPRA for registration as a physiotherapist in Australia. We recognise this may not be feasible however, in some universities. 3.2.1b There is no reference to a graduate-entry Doctor of Physiotherapy program The CPDANZ suggests inclusion of this type of program in this section. 3.2.3a Suggest the addition of words as follows: anatomy, physiology, pathology, biomechanics, pharmacology and other biomedical sciences relevant to human health and function or the treatment of same, and 5.2.2 "The financial position, financial performance and cash flows of the Physiotherapy organisational unit is monitored regularly and understood". Some further clarity in the wording is suggested herein: Who is meant to understand? (the Head of Physiotherapy / Discipline Lead? University finance personnel? accreditation panellist?) 11. Are there any Standard Statements that could be less specific? (please say how) Nil comment Clinical Education 12. Standard Statements relating to clinical education are currently in Section 3.2 Course Design (see 3.2.4-3.2.9). Would these Standard Statements relating to the clinical part of the course of study be better presented in a stand- alone Section under the same Domain? There appears to be some risk for duplication in the clinical education sections of the standard. On the whole however, the CPDANZ suggests that the clinical education section remains under 'course design', particularly if simulation-based learning is to increase, thus blurring the line between traditional 'campus' based content and 'clinical' based content.
Research and Research- Related Activities 13. Standard Statements relating to research and research- related activities in a course of study are currently in a stand- alone section (3.3). Would these be better located in Section 3.2 Course Design? As it appears that the 'research' section would only refer to student skills/development, the CPDANZ agrees that such matters may be best incorporated in the 'course design' section. Other comments and suggestions 14. Do you have any other comments or suggestions? - Overall, there appear to be a smaller number of requirements (with some consistency with the SHE standards and accreditation requirements for other professions) which should assist with documentation and with review. - It is good to see the focus on sufficient clinical experience to achieve learning outcomes rather than being overly prescriptive in terms of hours or type of placement (however evidence statements are not reflective). - It is important that supervision assessment on some clinical placements needs to be broadened so it can be undertaken by other health professionals (particularly given the importance of interprofessional practice and teamwork in healthcare). - Re: 3.2.3a anatomy, physiology, pathology, biomechanics, pharmacology and other biomedical sciences relevant to human health. It is interesting to note that there is willingness to prescribe the above areas / fields as requirements for inclusion for, or as prerequisites to physiotherapy studies. Perhaps consideration should also be given to prescribing core elements for inclusion in physiotherapy curricula in order to ensure that graduates are adequately prepared for safe and effective contemporary and future practice; the profession s knowledge base does not excessively diverge or become diluted at entry-level; and there is a strong base upon which graduates can build further knowledge. This may be something the HWC seeks further information on in the next round of consultations.