AMHSW CPD Audit of 2017-18

 

AMHSW CPD Audit of 2017-18

The AMHSW CPD for 2017-18 has now been conducted. You can read a little about the outcome, and also read some information to keep in mind for the future, below.

Why an Audit was important

AASW has standards for the CPD that AMHSW members should attain each Audit year, which is from July 1 to June 30 each year.

In addition, and consistent with these AASW standards, members who are Medicare providers of FPS standards need to be able to demonstrate that they meet certain CPD requirements for FPS.

The National Alliance of Self-Regulating Health Professions (NASRHP) provides a recommendation that 5% of accredited members should be audited for compliance with CPD requirements or standards. The audit has been conducted as a randomly selected sample of AMHSW members, then with further sub-selection so that the threshold of 5% coverage is met.

The total number of AMHSW members was 2204 as at 30 June 2018 (the last day of the CPD year under consideration). A random selection process was followed, to identify 10% of members for a selection pool. These members were notified that their records may be accessed or requested. They were given time to check and make sure their records were ready. Then, records and information for members in the selection pool were accessed for the audit purposes, to achieve 5% total coverage. The vast majority of records that were able to be checked were satisfactory. Some members were asked to provide further information, including some members who did not use the AASW CPD log for their CPD activity record keeping.

What happens next?

The information gathering has now concluded. Unless members have already been asked for further information, no further information will be sought for this year’s CPD Audit.

For those who participated, thank you for your part in the maintenance of standards.

For those who were not selected this time, thank you also for your part in the maintenance of standards, by being ready to demonstrate your compliance with CPD requirements.

The AASW CPD team will continue working with a few members to ensure their CPD activities and record keeping of them are consistent with the requirements.

Also keep in mind you could be asked to demonstrate compliance by relevant authorities

For your information and interest, please keep in mind the following powers in relation to FPS CPD for all AMHSW members who have relied on their AMHSW status to apply for a Medicare provider number to provide certain FPS item number services. The Minister holds the discretion to review evidence of your recent or current CPD in any given year that you hold yourself out as a Medicare provider of FPS services. 10 hours of FPS CPD is a common requirement of all FPS providers.

Under the relevant regulation: Health Insurance (Allied Health Services) Determination 2014 (Cth) (which is made under subsection 3C(1) of the Health Insurance Act 1973 (Cth):

If a provider is potentially not meeting the required 10 hours of FPS CPD activity, then there is a set process for the consideration of this departure from acceptable standards within the Department.

The ultimate decision maker is the Minister. The Chief Executive Medicare has the power to remove someone from the register of Medicare providers.

The full text of the Determination is available through the Federal Register of Legislation;

https://www.legislation.gov.au/Details/F2013L02134

A portion of Section 10 from the Health Insurance (Allied Health Services) Determination 2014 is quoted below.

10  Focussed Psychological Strategies health services

  1. To comply with this section a person must complete focussed psychological strategies continuing professional development each CPD year.
  2. A person referred to in subsection (1) is required to keep written records of completion of focussed psychological strategies continuing professional development for a period of two years from the end of the CPD year to which the focussed psychological strategies continuing professional development relates.
  3. For the period referred to in paragraph (a) of the meaning of CPD year in section 4(1), a person who is an allied health professional in relation to the provision of a focussed psychological strategies health service, as at the date of commencement of this Determination, may count for completion of focussed psychological strategies continuing professional development any of the units referred to within the meaning of that term in section 4(1) completed from 1 July 2009 to 30 June 2011.
  4. Other than where subsection (7) applies, where a person seeks to become an allied health professional in relation to the provision of a focussed psychological strategies health service during a CPD year and meets the requirements set out in Schedule 1 for the provision of a focussed psychological strategies health service:
    1. that person’s name will be entered on the register, kept by the Chief Executive Medicare, of allied health professionals who are qualified to provide a service of that kind until the end of that CPD year; and
    2. that person will have until the end of that CPD year to meet the focussed psychological strategies continuing professional development on a pro‑rata basis, with units being calculated from the first day of the month immediately succeeding the date of registration.
  5. If the Minister is satisfied that an allied health professional in relation to the provision of a focussed psychological strategies health service has not completed their focussed psychological strategies continuing professional development, the Minister:
    1.  may decide to remove the name of that allied health professional from the register kept by the Chief Executive Medicare; and then
    2. notify the Chief Executive Medicare to remove the name from the register.
  6. Before the Minister provides notification under subsection (5)(b), the Minister must notify that allied health professional in writing of the decision setting out:
    1. the decision;
    2. the reasons for the decision; and
    3. a statement of the allied health professional’s reconsideration rights under section 11.

Section 11 is about the process of reconsideration of such a decision and documentation of that process.

What this means for AASW’s role

AASW therefore has mainly an educative role, but would likely have an obligation to draw attention to significant and serious potential departures that it had become aware of.

This is because AASW is an Accrediting Authority recognised by the Federal Government.

It has a positive obligation to maintain vigilance over standards, and assure itself that appropriate standards are being promoted.

While not having as full inquiry powers as the Minister, auditing of CPD records is in keeping with a general responsibility to satisfy reassurance of a good level of awareness of the required standards.

AASW would arguably also have a positive obligation to bring to the attention of the Department / CEO Medicare if there was a significant and serious departure from required standards, such that an accredited provider’s eligibility to be a Medicare provider may be in doubt.

Thank you once again for your part in being ready for the Audit, and in continuing to be ready to be selected for future Audits.

All AMHSW members play a vital part in upholding the high standards for mental health social work services which are made available to the community.

The Audit has been a joint exercise of the AASW Professional Standards, Mental Health, CPD and Membership teams, on behalf of the AMHSW members, and in AASW’s role as an Accrediting Authority recognised by the Federal Government.