The Board has approached the consultation like this: there have been no changes to the scopes of practice, but previously the Board was wrong in how it applied the scopes, with its ‘historic comments’ resulting in many psychologists exceeding their scope of practice, so the Board is going to rectify matters and ‘legally enable’ the workforce, but in the meantime the status quo remains, i.e., individual practitioners need to take responsibility for determining whether they are competent to undertake specific psychology services. We respectfully believe that the Board’s approach is misleading people as to the nature, breadth, and longevity of the Board’s ‘historic comments’, and perpetuating and exacerbating misrepresentations as to the nature and breadth of the current scopes of practice. Given the way in which the Board has approached and structured the consultation, we believe the Board’s erroneous view of the current scopes of practice means that the entire consultation proposal rests on an incorrect foundation.
In its December 2023 consultation paper, the Board says that, historically, the Board made comments about scopes of practice that risked being construed as contradicting the fundamental principle that health practitioners must not practise outside their scope of practice. It says that (a previously composed) Board stated on its website that scopes of practice protect title but do not limit tasks, provided the individual psychologist is competent to perform those tasks”. This is not what the Board said on its website. Both this re-worded version of what previous Boards said, and similar variants communicated by the Board or its Secretariat in 2023, are misleading. They misquote what previously composed Boards said, they are taken out of context, and they either overlook or misunderstand how the scopes were lawfully developed and applied from 2004-2021.