OTA submission to the national Scope of Practice Review

OTA is preparing a submission to the scope of practice review which was announced in the 2023 federal Budget by Minister for Heath Mark Butler. The Review is led by Professor Mark Cormack and seeks to identify opportunities to remove the barriers stopping health professionals working to their full scope of practice in primary care. It will also look for examples of multi-disciplinary teams working together at the top of their scope of practice to deliver best practice primary care.   

OTA plans to make an initial submission to the review, which is due on 16 October 2023. We understand that there will be further opportunities to engage with the review in the coming months as they release issues papers and an interim report.   

Read more about the review here.

Have your say 

OTA is seeking your insights and feedback to help us understand where both barriers and enablers/opportunities to allow OTs to practice to their full scope, where safe and appropriate, to fill an identified service gap or unmet community need, in the primary health system.  

We have posed some topics and questions below, but would also welcome any other thoughts or insights you feel might be valuable to assist us to respond on behalf of the profession.   

We are seeking feedback by Friday 29 September to policy@otaus.com.au.  

The review is primary focusing on public health system however this has not been defined specifically, so OTA is interpreting this as being services accessible via state and territory public health systems, primary health networks, hospitals and Medicare.   

Legislation and Regulation  

Have you encountered any barriers or enablers in legislation or regulation that OTs are subject to? These include:  

  • National Registration Act (Health Practitioner Regulation National Law Act, 2009, 2010);   

  • Australian Minimum Competency Standards for New Graduate Occupational Therapists (OTA 2018)   

  • Code of Conduct (Occupational Therapy Board of Australia (OTBA), 2022)  

  • Code of Ethics (OTA, 2014)  

  • Legislation relating to NDIA, DVA, compensation schemes  

Education, training and supervision  

  • Any barriers or enablers that exist in the ability to access education, training and supervision, including interprofessional learning and collaboration and supervision?  

Employer practices and work context  

  • Any barriers or enablers that you have seen in the employer space, including employer credentialing practices, employer policies, organisational practices (e.g. role design), insurance and other practice requirements, models of care, or geographic factors?   

Leadership and culture   

  • Any barriers or enablers in leadership and culture including cultural practices that systematically support or inhibit working to full scope of practice, professional leadership requirements, the ways OTs understand/learn about their scope of practice?  

Funding mechanisms  

  • Do specific funding mechanisms create barriers or opportunities to promote full scope of practice? Weare thinking here of funding via Medicare, or other commissioned arrangements e.g. those via Primary Health Networks?  

  • What ways could OTs be operating within the primary health system to work at full scope, including in the preventative health space?    

  • What barriers exist in the current service delivery available under Medicare? Occupational therapists are eligible to provide a range of services funded by Medicare:  

  • M3 – Allied Health Services for Chronic Disease Management   

  • M7 – Focused Psychological Strategies Services by Allied Health Providers (commonly referred to as the Better Access to Mental Health Program)   

  • M10 – Complex Neurodevelopmental Disorder (such as Autism Spectrum Disorder) and Eligible Disability Services (formerly known as Autism, Pervasive Developmental Disorder or Disability Services and the Better Start and Helping Children with Autism programs)   

  • M16 – Eating Disorders Services  

  • Is there scope for OTs to deliver even more services under Medicare? For example, Medicare enabling OTs to provide a full suite of assessment and intervention aligned to OT capabilities, and  greater opportunity to work collaboratively with other health professions, offer capacity building interventions under Better Access, or social prescribing? We’d welcome your thoughts.   

Multidisciplinary team (MDT) practice  

  • What barriers current exist that prevent best practice MDT approaches?  

  • Do you have any examples where MDT enables full scope of practice and works particularly well?  

Call for Case studies/examples  

  • We would welcome any Case studies/examples of OT professionals working to full scope and upskilling to work at an expanded scope of practice to fill an identified service gap or unmet community need.  

  • Did you observe any changes during COVID-19 that you think were positive in terms of enabling fuller scope of practice?  


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