The Board's response to this consultation can be located below.

Background
The Psychotherapists Board of Aotearoa New Zealand (the Board) regulates psychotherapists under the Health Practitioners Competence Assurance Act 2003 (HPCAA).

Psychotherapists work in mental health with a range of client groups, including children and adolescents, adults, couples and families. These clients groups are located throughout New Zealand and are culturally diverse. Although the majority of psychotherapists work in private practice, psychotherapists also work in DHB's, NGO's and other organisations. As the majority of psychotherapists work privately there is little or no access to post-entry level education funding.

Comments
The Board would like to make the following comments:

1. The Board supports opening up access to post entry training funding and considers this a constructive change; to fund post-entry level training on the basis of the identified health care needs of the public of Aotearoa/New Zealand.

Providing the opportunity to apply for post-entry training funding may facilitate health professions including psychotherapists to initiate and develop health care services that meet identified needs. This may also mitigate risk to members of the public by facilitating further training in areas of need. The Board understands the any application would need to meet the funding criteria i.e. need, benefits, suitability, cost and savings.

2. The Board agrees with the 'implementation considerations'. The Board agrees that Health Work Force New Zealand (HWNZ) would need to support the formulation and submission of applications as many health practitioners and service providers have no experience of applying for such funding. It is important that smaller professions, especially those without resources, are supported through the application process.

3. The Board understands that individuals can apply for funding, this access is important as the majority of psychotherapists work in private practice.

4. The Board would like to ensure that any outcome assessments are managed in a way that protects privacy. The Privacy Commissioner has recently completed an inquiry into the Ministry of Social Development (MSD) regarding the collection of individual client data in funded services. This report outlines that the privacy of service users must be protected, and suggest methods by which data can be collected to protect the individual client.

5. The Board supports the concept of an Expert Advisory Committee, only if, the allied health professions and smaller health provider groups are represented on this Committee.

6. The Board is concerned that smaller professions may not have access to data and workforce planning information to develop their funding submissions. The Board seeks clarification that HWNZ will fund and provide access to data to support funding submissions.

7. The Board is concerned with the outcome measurement of the health care provided by a service, or by practitioners that receive training funding. The Board seeks clarification about how any received health care will be measured. Any assessment methods will have to be non-intrusive, protective of privacy and carefully designed. The Board refers HWNZ to the Privacy Commissioners recent report.

8. It is unclear how much of the funding will be contestable. The Board seeks clarification on how consistency will be managed if funding is contestable on an annual basis.

Increasing access to a broader range of mental health services; enabling early intervention and better health outcomes for people is a significant focus of the health strategy, recently outlined by the Hon Dr Jonathan Coleman in his speech on Social Investment Approach to Mental Health.

The Board supports initiatives that will open funding to health professions working with and supporting people suffering from diverse mental, social and physical health problems. The Board sees this as an opportunity to create health care services that better match the reality of current health and social concerns.

Thank you for the opportunity to comment, should you have any questions please contact me on 04 9184727.

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:

Occupational Groups
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.

Treatment Providers
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.