Community Services & Health Industry Skills Council COMPLEMENTARY & ALTERNATIVE HEALTH Alignment of Qualifications to the Australian Qualifications Framework Discussion Paper: October 2013 The Australian Naturopathic Practitioners Association Excellence, Leadership and Integrity in Naturopathic Health Care Suite 36/123 Camberwell Rd www.anpa.asn.au East Hawthorn admin@anpa.asn.au VIC 3121 1 800 422 885
Contents Executive Summary... 3 Introduction... 3 Question 1.. 3 Question 2 5 Primary Care Practitioners 5 Critical Thinking Skills..5 International Standards 5 The Australian Bureau of Statistics - ANZSCO skill level 1.. 6 National Standards in Naturopathy Education.6 Australian Register of Naturopaths and Herbalists (ARONAH). 6 Statutory Registration.. 6 ANPA Recommendations.6 References. 7
Executive Summary Millions of Australians consult naturopaths because they achieve good outcomes a variety of health conditions. At present the Australian government endorses the education of Naturopaths in both the VET and higher education sectors. This two-tier approach is counterproductive to the full recognition of the naturopathy profession by other health professionals, government agencies, the media as well as the public. There are potential risks for the public when seeking health support from some naturopaths who have insufficient training. By offering a Bachelors level degree to all prospective naturopaths the profession will avoid the following problems: discrimination in accessing rebates from private health insurance providers because of differing education standards, standardising supervised clinical education on campus for students and importantly including critical reasoning as integral to the training of naturopaths. The negative consequences of not adopting a Bachelor degree as a minimum standard is the continued discrimination against practitioners by health insurers, maintaining poor perceptions of the naturopathy profession and the potential risk of harm to the public. Presently, some students are accessing clinical supervision in private clinics with no recognised standard or quality assurance of the supervisor. Naturopaths are primary health care providers. As such, they deserve to be recognised as part of the professional health spectrum. The focus of this submission is to provide rationales for the transition to a Bachelors degree for all naturopaths in Australia. Introduction The Australian Naturopathic Practitioners Association (ANPA) thanks the Community Services & Health Industry Skills Council (CSHISC) for the opportunity to lodge this submission. The ANPA was founded in 1975 and is a national association representing naturopaths. All members at present must have a minimum of an Advanced Diploma of Naturopathy, although many have much higher qualifications. Our members abide by a code of ethics as well as other policies that guide clinical practice. The ANPA represents naturopaths in the following ways: - Advocacy to government at State and Federal levels. - Support statutory registration for naturopaths. - Advocacy to private health insurers. - Participation in the review of the Health Training Package (VET Sector). - Foundation member and continued support for the Australian Register of Naturopaths and Herbalists (ARONAH). - Significant focus on support for students and new graduates as they enter the profession. - Ongoing educational and professionalization support for naturopaths. - Collaboration with other health professionals creating by bridges of understanding to improve health outcomes for the public. - Communication with education providers across Australia and overseas that are offering naturopathy training.
- Regular contributions to the media raising the profile of naturopathy and awareness for the profession amongst other health professionals, the public and the media. QUESTION 1 What are your general views on the mapping represented in Table 1, which suggests CAH Advanced Diploma qualifications could be aligned to Bachelor Degree level? The limitations of an Advanced Diploma qualification are clearly identified in Table 1. All areas show deficiencies: purpose, knowledge, skills, application of knowledge and skills and volume of learning. All of these impact the day to day clinical practice requirements for a primary care naturopath. The problem of not knowing what you don t know because information and critical skills have been left out of the curriculum is a serious issue. The comparison table fails to include a discussion on the different criteria used for assessing an Advanced Diploma (competency based) level versus the Bachelors Level. There is a vast difference between VET sector assessment methods and Higher Education assessments. The VET sector is restricted to Competency Based assessment, which methodologically is basic and incapable of assessing higher processing skills such as high level decision-making and critical thinking. This is a major reason to move Naturopathy out of the VET sector and into Higher Education. This is not possible within the VET sector due to VET sector teaching methodologies and VET sector assessment methods. The critical skills that are taught to naturopaths ought to be assessed at a level equivalent to other primary health care practitioners. General practitioners are trained at a post graduate level, osteopaths and chiropractors are trained to a Masters level. When Naturopaths in the workplace are required to analyse information from a detailed case history, medical reports, in-depth client interviews, diagnose conditions, make independent judgements, and communicate complex information about conditions and treatments to clients and these skills are not part of their study program, the public are being put at risk. The HCCC report Potential Risks of Unregistered Healthcare Practice, (Report No 13/53, September 2006,) included two categories of risk that may well impact practitioners who are not sufficiently trained to provide primary care health care: Risks of Commission: Removal of appropriate medical treatment, Incorrect prescribing Risks of Omission: Misdiagnosis, Failure to refer, Failure to explain precautions, Failure to identify limits of practice, Lack of skills/experience in delivery of specific health services, The public deserves the protection and assurances inherent in a higher level bachelors level education thus minimising the potential for both these serious types of risk.
QUESTION 2 If you believe that qualifications in Aromatic Medicine, Homeopathy, Naturopathy, Nutritional Medicine and Western Herbal Medicine should become Bachelor Degree qualifications, what is your rationale based on the AQF descriptors? Please specify which modality your feedback relates to. The ANPA recognises that significant numbers of patients presenting at naturopaths offices today have complex chronic conditions with multiple diagnoses. Often these patients are taking numerous pharmaceutical medications as well as self-selected natural medicines. This level of complexity has the potential risk of causing harm if the practitioner is insufficiently trained. The naturopathy practitioner of today must be educated and professionalised with the extensive skills required of a primary care practitioner. This level of responsibility and potential risk of harm to the patient clearly demands the minimum level of a Bachelors Degree. Primary Care Practitioners Naturopaths are primary care health practitioners and offer the Australian public approximately 4.9 million consultations per year¹. Naturopaths are the largest group of complementary and alternative medicine practitioners in Australia². Determining accurate numbers of naturopaths continues to be a problem because there is no formal register. There could be as many as 10, 000 naturopaths in Australia. This is substantially more than 4000 - the total number of Chinese medicine practitioners registered in 2012³. Chinese medicine practitioners are all trained with a minimum of a Bachelors level in Australia. Nearly 10% of Australian women consult naturopaths⁴ and this number rises to 16% in conditions such as cancer⁵. The public are turning to naturopaths for many reasons: they prefer natural medicine approaches, they have experienced adverse side effects from pharmaceuticals and conventional medical approaches, want to try other options and want a more holistic approach⁶. Critical Thinking Skills Naturopaths offering primary health care services MUST be trained in critical thinking. They must be able to read information and have the ability to critically evaluate it in relation to their clinical practice. Critical thinking must form the core of training for naturopaths. It is absent from the Advanced Diploma training. Naturopaths require the critical thinking skill to enable them to read media and evaluate it, to know whether the information they found on a blog or a website is useful, biased or simply fabricated. In an environment based on evidence-based medicine, naturopaths must be able to read a research paper and determine how to look for the holes in the research and establish if there is bias. This is a core skill taught at a Bachelors level, but missing from the Advanced Diploma. International Standards International standards of education for naturopaths support the transition to a Bachelors level for Australia. The US training of Naturopathic Physicians requires an undergraduate degree as well as a post-graduate training of 4 years. Indian training of medical practitioners
as well as practitioners of the five traditional medicines including yoga and naturopathy all require the minimum of 4 years at a Bachelors level plus 1 year clinical training. Australia will be at a basic threshold when a Bachelors level is the approved minimum standard. The Australian Bureau of Statistics - Australian and New Zealand Standard Classification of Occupations, First Edition, 2006: 252213 Naturopath Skill Level 1 Skill Level 1 Occupations in this unit group have a level of skill commensurate with a bachelor degree or higher qualification. Online at: http://www.abs.gov.au/ausstats/abs@nsf/product+lookup/1220. National Standards in Naturopathy Education Two long term providers of naturopathy education in Australia have already moved to only offer a Bachelor level training. Endeavour College, the largest natural therapy school in the Southern Hemisphere graduates the most naturopathy students each year. They are now all at a Bachelor level. Southern School of Natural Therapies in Melbourne and Paramount College in Perth only offer a Bachelor level for Naturopathy. There may be other schools that are moving to only offer the Bachelor level as well. The shift towards a bachelor degree is already apparent and consistent with the naturopathy education marketplace. Australian Register of Naturopaths and Herbalists (ARONAH) In line with other primary care professions the Australian Register of Naturopaths and Herbalists is now formally taking applications for practitioners to sign up to the register. The ARONAH register has been based on the NRAS used by AHPRA. They have grandparenting provisions at present but are advocating for a minimum education of a bachelors degree by 2016. Statutory Registration The ANPA supports statutory registration for the naturopathy profession. Statutory registration will offer a minimum education standard, independent complaints mechanism and the protection of title for the profession. At present there are no barriers to entry and anyone can use the title naturopath without formal training. ANPA Recommendations 1. That the CS&HISC adopts the transition to a Bachelor level minimum education standard for Naturopaths consistent with the AQF 7 framework. 2. That potential harm to the public is a major consideration in upgrading naturopathy education to the AQF7 level Bachelor degree. 3. That the transition to the Bachelor level for naturopaths includes ample time for education providers to review their delivery of naturopathy education to naturopaths and make the necessary changes to offer a Bachelor degree. 4. That students enrolled in Advanced Diploma programs be given ample time and options to upgrade to the Bachelors degree without penalty. 5. That the CS&HISC supports the further strengthening of the naturopathy profession by advocating the inclusion of naturopaths under AHPRA as a registered profession. 6. That the education levels meet the ANZSCO classification for naturopathy requiring a Bachelor education level or higher.
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