Advocating Equity in Mental Health Practice for All Similarly Qualified Mental Health Professionals

Introduction

The mental health sector in Australia comprises a diverse range of professionals. Some—including General Practitioners, psychiatrists, psychologists, occupational therapists, and registered nurses—are registered and regulated by the Australian Health Practitioner Regulation Agency (AHPRA) under the Health Practitioner Regulation National Law Act 2009 (as adopted in each state and territory). Others—such as psychology graduates with honours, social workers, counsellors, psychotherapists, behavioural therapists, community mental health workers, and psychoanalysts—are not regulated under this national law. This regulatory distinction significantly impacts access to funding and professional recognition. However, some non-regulated, non-AHPRA-registered professionals from various disciplines, including health and mental health care, do have access to Medicare provider numbers.

Medicare provider numbers are granted to AHPRA-registered practitioners and selected non-AHPRA allied health professionals, including social workers, speech pathologists, and Aboriginal health workers. Yet many non-registered allied mental health professionals, despite qualifications and clinical experience comparable to or exceeding those of Medicare-recognised allied health professionals, face substantial barriers to funding through key national schemes such as Medicare and the National Disability Insurance Scheme (NDIS). These challenges largely arise from a lack of effective representation by peak professional bodies.

The International Association of Accredited Mental Health Professionals (IAAMHP) advocates for equitable recognition and inclusion of all similarly qualified mental health professionals, regardless of registration status. IAAMHP strives to establish transparent accreditation standards and engage with government bodies to secure fair access to professional recognition and funding pathways. These efforts aim to strengthen Australia’s mental health workforce and improve accessibility to essential mental health services nationwide.

Current Landscape in Accessing Medicare Provider Numbers

According to Services Australia, evidence required to obtain a Medicare provider number varies based on the applicant’s registration status. AHPRA-registered practitioners must provide proof of registration, which Medicare verifies directly with AHPRA. Non-AHPRA-registered applicants must submit evidence of registration, certification, or membership from their relevant professional association. Aboriginal health workers must provide certification from a recognised Registered Training Organisation (RTO).

Services Australia recognises various health professionals eligible for Medicare provider numbers, including:

• AHPRA-Registered Allied Health Professionals: Aboriginal and Torres Strait Islander health practitioners, chiropractors, dental practitioners, occupational therapists, optometrists, osteopaths, physiotherapists, podiatrists, psychologists, and others.
• Non-AHPRA Registered Allied Health Professionals: Aboriginal health workers, accredited practising dietitians, audiologists, diabetes educators, exercise physiologists, mental health nurses, social workers, speech pathologists, among others.

Notably, social workers, though not AHPRA-registered, are eligible to provide mental health services under Medicare if they meet accreditation standards set by the Australian Association of Social Workers (AASW). However, many similarly qualified non-registered mental health professionals remain excluded from Medicare and NDIS funding. This exclusion largely results from unsuccessful representation by professional bodies capable of advocating effectively for provider number access.

Barriers to Accessing Medicare and NDIS Funding

A primary obstacle for non-registered mental health professionals in accessing funding is the absence of formal recognition by peak bodies that meet government and Medicare requirements. Services Australia requires applicants to demonstrate registration or certification from recognised professional associations. Similarly, the NDIS Quality and Safeguards Commission requires providers to be registered—a process often inaccessible to professionals lacking unified peak body representation.

The Health Insurance (Allied Health Services) Determination 2014 outlines registration and membership criteria necessary for allied health professionals to access Medicare benefits. Non-registered professionals frequently do not meet these criteria, resulting in exclusion from vital funding schemes.

The Role of IAAMHP in Promoting Recognition and Equity

In response to these challenges, the International Association of Accredited Mental Health Professionals (IAAMHP) seeks to bridge the gap between regulated and non-regulated mental health professionals. IAAMHP aims to establish itself as an independent, inclusive peak body that develops robust, ethical accreditation standards for qualified non-registered professionals. By advocating for their recognition under Medicare and NDIS funding schemes, IAAMHP promotes equitable treatment based on competency and qualifications rather than registration status alone.

Proposed Plan: The Need for a Unified Accreditation Model

The Australian mental health sector currently lacks a single, independent statutory body to regulate and accredit the full spectrum of mental health professionals. While AHPRA oversees professions such as psychologists and occupational therapists, many similarly qualified practitioners remain outside this regulatory framework. This leads to inconsistencies in professional recognition, training standards, and access to funding mechanisms like Medicare and the NDIS.

Recognising this gap, IAAMHP advocates for establishing a national, independent statutory accreditation and registration body dedicated to mental health professionals. This body would be modelled on AHPRA’s principles of public safety, transparency, and regulatory independence, providing:

• Statutory Regulation: A central authority responsible for registration, accreditation, and oversight of all mental health practitioners, ensuring consistent standards regardless of professional title.
• Recognition of Diverse but Equivalent Qualifications: Clear acknowledgement of Bachelor’s, Master’s, and higher degrees in counselling, psychotherapy, mental health sciences, behavioural therapy, and related disciplines, establishing equivalence across educational pathways.
• Standardised Accreditation Processes: Uniform criteria for education, supervised clinical internships, and ongoing professional development aligned with frameworks used by AHPRA-registered professions.
• Robust Complaint and Ethical Review Mechanisms: Procedures modelled on national health regulatory standards to protect public safety and uphold professional integrity.
• Equitable Access to Funding: Enabling all accredited professionals to participate fairly in Medicare and NDIS funding schemes.
• Workforce Development and Sustainability: Supporting continuing education, practitioner wellbeing, and collaborative practice to build a resilient and high-quality mental health workforce.

While IAAMHP continues to advocate for the creation of this statutory body, it proactively fills the current representation gap by acting as an independent, inclusive peak body for non-AHPRA-registered mental health professionals. In this capacity, IAAMHP:

• Provides a unified voice for qualified practitioners historically lacking formal recognition and equitable funding access.
• Develops and maintains accreditation standards based on best practice, aligned with professional training and ethics.
• Offers professional development, networking, and support to enhance workforce capacity and practitioner wellbeing.
• Advocates directly with government agencies, policymakers, and funding bodies to promote inclusion and equitable treatment.
• Implements ethical oversight and complaint mechanisms to safeguard clients and uphold high professional standards.

By fulfilling both these roles, IAAMHP supports currently excluded mental health professionals while driving systemic reform toward an inclusive and standardised national accreditation framework. This dual approach aims to enhance public safety, improve service accessibility, and promote fairness across Australia’s mental health sector.

Policy and Advocacy Priorities

To realise this vision, IAAMHP advocates for:

• Raising public and governmental awareness of the qualifications and contributions of currently excluded mental health professionals.
• Engaging policymakers, government departments, and academic institutions to foster inclusive workforce policies.
• Learning from successful accreditation models employed by the AASW, Occupational Therapy Australia, and Speech Pathology Australia.
• Building cross-disciplinary coalitions to advocate for legislative reform and equitable policy development.

Conclusion

The exclusion of many qualified non-AHPRA-registered mental health professionals from Medicare and NDIS funding undermines both workforce capacity and equitable access to mental health services in Australia. Moreover, these professionals face substantial barriers in establishing sustainable careers without Medicare provider numbers. Clients often prefer practitioners who can offer subsidised services through Medicare, making it difficult for non-recognised professionals to attract and retain clients despite having equivalent qualifications and expertise.

The IAAMHP advocates a dual approach: filling the current representation gap as an inclusive peak body and promoting the creation of an independent statutory accreditation and registration body. This model will ensure consistent professional standards, safeguard public safety, enable fair funding access, and support the professional viability of all qualified mental health practitioners.

By advancing these reforms, Australia can build a stronger, more inclusive mental health workforce—one capable of meeting the growing demand for accessible, high-quality mental health care across the country. IAAMHP remains committed to working with government, professional bodies, and practitioners to realise this vision and improve mental health outcomes for all Australians.

References

• Australian Health Practitioner Regulation Agency (AHPRA). (2024). Registration Standards. https://www.ahpra.gov.au
• Services Australia. (2024). Medicare Provider Number Application Guidelines. https://www.servicesaustralia.gov.au/hpmedicarebenefits
• Australian Association of Social Workers (AASW). (2024). Accreditation Standards. https://www.aasw.asn.au
• https://www.servicesaustralia.gov.au/specific-criteria-for-allied-health-professionals?context=20
• Health Insurance (Allied Health Services) Determination 2014:https://www.legislation.gov.au/F2013L02134/latest/text
• https://www.servicesaustralia.gov.au/specific-criteria-for-allied-health-professionals?context=20
• https://classic.austlii.edu.au/au/legis/cth/num_reg_es/hila2022mn4r2022202201518601.html
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