The Board's response to this consultation can be located below.
Thank you for the opportunity to respond to the Consultation on 'New Practitioners for Registered Health Professional and Treatment Provider Definitions'.
The Psychotherapists Board of Aotearoa New Zealand (the Board) would like to make the following comments:
1. It is important that new 'Occupational Groups' are named by title e.g. 'psychotherapist' rather than by profession e.g. 'psychotherapy'. This distinction is important as both regulated and non-regulated professions can practise 'psychotherapy' but only registered psychotherapists can claim the title psychotherapist.
Burden of Proof
1. The Board is concerned that the minimum threshold (the burden of proof) may be increased for service users who are required to provide evidence of a treatment injury (rather than current personal injury); any increase will exact a detrimental toll on both claimant and practitioner.
Definition of Treatment Injuries
1. It may be complicated to assess what exactly caused a treatment injury i.e. causality. Unless the injury resulting from the treatment of a psychotherapist is clear, such as, a complaint that has been upheld. The Board notes that a claimant may experience psychotherapy, particularly in early stages, as increasing their symptoms. In addition, the effects of psychotherapy and psychotherapy methods may be interpreted differently by a claimant and/or assessor.
2. Treatment injury's unless directly evident (as in the case of a complaint upheld against a psychotherapist), may be difficult to define. Definition of a treatment injury may become problematic and will require skilled assessment. Any assessment of a treatment injury would need to be based on the Board's Standards of Core Clinical Competence and Scopes of Practice.
3. It is important that the expert opinion or perspective of a psychotherapist is engaged when assessing any claim for mental injury, resulting from the practice of a psychotherapist. A psychotherapists practice and methods may not be understood by assessors with different professional practice knowledge.
1. If the category 'Registered Health Professional' is being aligned with the Health Practitioners Competence Assurance Act 2003 (HPCAA), it would be reasonable to also align the 'Treatment Providers' with the HPCAA.
2. Currently the title 'counsellor' is used for psychotherapists. The Board suggests that 'psychotherapist' be added to the Treatment Provider list to ensure that information collected is correct and relevant.
In support of the Board's submission I have hyper linked access to the Board's Core Clinical Competencies and an article by Jonathan Schedler outlining the practice of psychotherapy.
Thank you for the opportunity to comment, should you have any questions please contact me on 04 9184727.