OTA conducts audits to verify ongoing eligibility to be endorsed under its own program and Medicare conducts compliance audits to ensure that practitioners are adhering to funding program guidelines. Importantly, other funders may also conduct audits associated with their own compliance programs.

Our aim is to align the mental health endorsement audit with Ahpra and Medicare guidelines to streamline the process. Consequently, documentation for audit purposes align closely with other compliance programs.

As an endorsed mental health occupational therapist, you are required to undertake activities to develop and maintain your mental health expertise. OTA is required to ensure that all endorsed practitioners adhere to these requirements through regular checks. Endorsed occupational therapists who do not meet the audit criteria will have their endorsement rescinded and be unable to continue to use their Medicare provider number for BAMH rebates.

Endorsed practitioners must

• undertake 10 hours of mental health specific CPD each year, and, if practicing under Medicare, this must be focused on the therapeutic interventions defined by Medicare as Focused Psychological Strategies (FPS). These CPD activities can contribute to the 20 hours of total CPD each year all occupational therapists are required to complete by the Occupational Therapy Board to maintain registration.
• maintain formal professional supervision arrangements, to keep professional supervision records, and to be able to provide details of their supervisor. Supervision should generally occur every four to six weeks, though practitioners may benefit from more frequent supervision at early career stages or when developing capability with new client cohorts, mental disorders, or therapeutic interventions. Supervision may include peer supervision.
• Retain OTA membership and registration with Ahpra.

Practitioners can claim supervision as a component of the 10 hours of FPS CPD, alongside other CPD activities such as formal postgraduate education, workshops, seminars, lectures, journal reading, writing papers, and online training. OTA expects endorsed practitioners to maintain a balance of supervision and formal learning components of their continuing professional development requirements and supervision should not generally comprise more than half of total FPS CPD.

When do audits take place?

The audit cycle has been aligned to coincide with the registration requirements under the Occupational Therapy Board of Australia (OTBA) related to the Australian Health Practitioners Regulation Agency (Ahpra) (i.e. 1 December-30 November).

The obligation of occupational therapists who are endorsed during the course of the CPD year to undertake CPD will be on a pro-rata basis. The amount of units will be calculated from the 1st of the month immediately succeeding the month they obtained initial endorsement. The obligation will be one-twelfth of the yearly requirement for each month.

Part-time allied mental health professionals are required to have 10 hours of mental health related CPD, the same as full-time allied mental health professionals.

The audit process will:

• Randomly choose endorsed occupational therapists, to a level of 10%, from the Occupational Therapy Australia database.
• Chosen occupational therapists are requested to provide evidence of participation in relevant CPD to the required level and details of engagement in supervision.
• Occupational therapists will be informed of the outcome of the audit. If the occupational therapist does not meet the audit criteria, endorsement will be rescinded and, if applicable, Medicare will be notified accordingly.
• A reconsideration mechanism will allow for endorsees to request either a further 28 days to complete the 10 hours of CPD or apply for internal review of a decision that the endorsee has not achieved the required CPD.
• Occupational therapists who are removed from the endorsed/approved provider list can be placed back on the list once they meet the CPD requirements for the previous cycle (total of 10 hours) and will be required to meet the requirements for the new cycle in full.

Records should include:

• Evidence of participation and reflection of activities relevant to mental health practice/delivering FPS Medicare items. This evidence must be clear and verifiable, i.e. certificates of attendance, reflections and readings for self-study to include references for journal or book publications plus a copy of the title page. All signed records of peer consultations, mentoring or supervision should also be presented.
• CPD activities must be relevant to mental health practice/delivering FPS services. Acceptable CPD activities can include formal postgraduate education, workshops, e-learning, seminars, lectures, journal reading and self-study activities, writing papers, receipt of supervision and peer consultation, supervision and online training programs.
• Records must be kept for two years.

Focussed Psychological Strategies approved for use by allied mental health professionals utilising the FPS Medicare items are:

1: Psychoeducation (including motivational interviewing)

2: Cognitive behavioural therapy including:

• Behavioural interventions
• Behaviour modification
• Exposure techniques
• Activity scheduling
• Cognitive interventions
• Cognitive therapy

3: Relaxation strategies

• Progressive muscle relaxation
• Controlled breathing

4: Skills training

• Problem-solving skills and training
• Anger management
• Social skills training
• Communication training
• Stress management
• Parent management training

5: Interpersonal therapy (especially for depression)

6: Eye-Movement Desensitisation Reprocessing (EMDR)

7: Narrative therapy (for Aboriginal and Torres Strait Islander people)