From mid to late 2021, the Board changed its website statements on scopes of practice to be more prescriptive sounding. By the time we get to 2023, the Board had changed its website statements to say that the “Board has identified individual scopes that can be practised in New Zealand”, and that “each scope of practice for psychologists has a unique focus and requires specific qualifications and experience”, followed by a reference to section 8 of the Health Practitioners Competence Assurance Act under which “health practitioners are not allowed to practise outside their scope of practice”. This wording appears to portray a siloed and non-overlapping approach to the psychology scopes of practice that is not consistent with how the Board developed and applied the scopes from 2004-2021.

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Mid to late 2021 to November 2022

By 22 September 2021, the Board had changed its messaging on scopes:

Scopes of practice

Psychologists are ethically bound to practise within their scope of practice and in accordance with their area(s) and level of expertise

A psychologist may work within a scope of practice only if:

    • they are registered in that particular scope of practice, AND
    • they are demonstrably competent to do so, OR
    • are doing so under appropriate supervision.

Within each scope of practice, a range of professional activities is encompassed. A practitioner is not permitted to practise in an area if they have not undertaken training and gained supervised experience to ensure that their practise is competent.

This statement remained on the website until at least November 2022.

In December 2022, the Board’s website appears to have been hacked, and the site was down for a period.

2023

Some time in 2023, the Board updated what it says about scopes, as follows:

Scopes of Practice

Psychologists have a legal and ethical responsibility to practise only in areas in which they are suitably qualified and experienced. The Board has identified individual scopes that can be practised in New Zealand.

Each scope of practice for psychologists has a unique focus and requires specific qualifications and experience.

Please note: Section 8 of the Health Practitioners Competence Assurance Act 2003 states that health practitioners are not allowed to practise outside their scope of practice.

The wording changes shown above effected subtle but significant changes that most busy psychologists are unlikely to have noticed. On their own, they may not have raised alarm bells. However, given what that the Board has been saying in the latter half of 2023, including in the consultation paper, they can now be seen as attempts to depart from the previous position so clearly held and communicated by the Board from 2004 to 2021.

The reference to section 8 of the Act in conjunction with the prior sentences implies that a psychologist should be careful not to work outside their ‘individual scope’ with its ‘unique focus’ or they will be breaching the Act. That sort of phraseology creates unnecessary alarm. Why? Because it is premised on a siloed approach to scopes. We need to appreciate that the general scope (which all fully registered psychologists have or are deemed to have) was designed to be all-encompassing, and that the vocational scopes cover areas of work that are subsets of the general whole but whose titles can only be used by those registered in them. When we appreciate these things, we realise that the real issue is not whether a psychologist who is providing psychological services is acting ‘outside of scope’. The real question is whether they are acting within or outside their level of competence.

The statement that each scope ‘has a unique scope and requires specific qualifications’ is, at the least, misleading. If it were correct, a psychologist with the ‘Clinical Psychologist’ scope, for example, would not be able to undertake any work covered by the ‘Neuropsychologist scope’. Similarly, a Clinical Psychologist ought not to be undertaking work covered by the Educational Psychologist scope. It is very clear that that is not how the scopes were intended to apply.