The Australian Health Practitioner Regulation Agency (Ahpra) and the National Boards have published the second in a series of reform documents aimed at overhauling key aspects of the country’s health practitioner regulation system, with a strong emphasis on cultural safety, complaints handling, and governance.
Consultation Paper 2: Consultation Outcomes and Reform Directions builds on previous engagement with practitioners, community members, and organisations, and sets out proposals aligned with recommendations from the independent review of the National Registration and Accreditation Scheme (NRAS) conducted by Kim Cary Dawson, a regulatory lawyer appointed by the Health Council to lead the independent review.
Some changes can be introduced through administrative and policy updates, but others, particularly those involving National Law amendments, will require agreement from Health Ministers across jurisdictions.
Addressing systemic concerns
Feedback collected across multiple engagement channels during the Dawson Review identified dissatisfaction with aspects of the current regulatory model. These included the handling of complaints (or “notifications”), the cultural safety of regulatory processes, and transparency around decision-making.
To address these matters, Consultation Paper 2 outlines proposals to:
- Pilot a new early resolution process for low-risk notifications.
- Improve written communication with both notifiers and practitioners.
- Strengthen guidance and support available during the notification process.
- Enhance cultural safety governance through a new proposed body.
- Clarify and strengthen governance structures within Ahpra and the Boards.
The proposed notification reforms aim to make the experience less distressing for notifiers and practitioners, particularly in low-risk matters where early clarification could prevent prolonged and unnecessary escalation.
Proposed Cultural Safety Council
One proposal central to the paper is the establishment of an Aboriginal and Torres Strait Islander Cultural Safety Council. This independent body would advise on how cultural safety principles should be embedded into regulatory governance and operational decision-making. While still in development, the council would likely play a role in shaping training, assessment tools, and accountability mechanisms across the scheme.
The new proposal builds on Ahpra’s existing 2020–2025 Aboriginal and Torres Strait Islander Health and Cultural Safety Strategy and the 2023 Anti-Racism Position Statement, both of which emphasise the need for structural reform, anti-racist practice, and sustained accountability in regulatory systems.
Strengthening governance and transparency
The paper also flags the development of a new principles-based Code of Governance to clarify the role of the National Boards, improve transparency, and guide consistent public reporting across the scheme.
In addition to clearer separation of functions between operational and decision-making arms of the scheme, Ahpra is exploring options to publish more regulatory decision summaries and increase stakeholder input into key processes.
Ahpra CEO Justin Untersteiner described the reform process as an inflection point for the scheme.
“The National Scheme is facing challenges it has not previously encountered,” he said in Ahpra’s response to the Dawson Review. “The time is right to take the National Scheme forward to meet the evolving needs of contemporary regulation. I look forward to working with stakeholders to bring the recommendations of the review to life.”
Next steps and legislative reform
While Ahpra has committed to acting on changes that fall within its existing remit, a number of proposals, particularly those requiring new governance bodies or structural role changes, will require legislative support.
As the consultation paper notes, any National Law changes must be agreed through the Ministerial Council process, and the timeline for reform will depend on cross-jurisdictional alignment. Under the current framework, National Law amendments require unanimous agreement from all Australian state and territory Health Ministers. This intergovernmental process means that even broadly supported reforms can face delays if consensus isn’t reached across jurisdictions.
Targeted consultations will take place between May and June 2025, focused on testing specific models for implementation. Broader public consultation is not currently planned at this stage of the process, marking a shift from the approach taken with Consultation Paper 1.
