Australia has a National Regulation and Accreditation Scheme (NRAS) which was set up in 2010 to ensure that the title of specified health professions would be protected – meaning that individuals who do not meet the training and practice standards of a profession could not use the title of that profession.
The NRAS is administered by the Australian Health Practitioner Regulation Authority (AHPRA), and it is under this Authority that each profession has a regulatory Board to oversee and implement the education and practice standards for their profession. There are currently 16 health professions included in the NRAS and each profession has core standards (such as minimum education requirements) that have been defined by the profession as necessary to their practice. Without meeting these professional and educational requirements, an individual cannot claim to be a member of that profession. For example, an individual must meet the expected training and practice standards set by the Medical Board of Australia before they can claim to be a ‘medical doctor’.
This same protection is not available to naturopaths and Western herbalists, as they are currently not included in the NRAS. In fact, anyone can call themselves a ‘naturopath’ or a ‘Western herbalist’ with no training at all.
The importance of regulation for naturopathy has been recognised around the world. Statutory regulation of the naturopathic profession currently exists in countries across most world regions including Europe, North America, Asia, and Latin America. The World Naturopathic Federation (WNF) is an organisation for the promotion of the naturopathic profession on a world scale and is building a relationship with the World Health Organisation (WHO) to improve global access to naturopathy. In line with the WHO’s Traditional Medicine Strategy, the WNF supports regulation and accreditation of the naturopathic profession around the globe and aims to promote the highest quality in standards of education and practice for naturopaths.
In Australia, a report was commissioned by the Victorian State Government in 2005 to investigate the need for statutory registration of naturopaths and Western herbal medicine (WHM) practitioners. The report, entitled The Practice and Regulatory Requirements for Naturopathy and Western Herbal Medicine recommended that registration of naturopaths and Western herbal medicine (WHM) practitioners is needed. In 2008, this report was tabled at the Council of Australian Governments but was not actioned because the NRAS was only just being developed and the government prioritised inclusion of professions that were already registered in some form at a national or state level. We have been waiting since this time for the government to release the criteria upon which it will consider the inclusion of new professions into the NRAS.
In lieu of statutory registration for naturopaths and WHM practitioners in Australia, an independent self-regulatory body was established by the profession in 2010 which mirrors the standards upheld by currently registered professions – the Australian Register of Naturopaths and Herbalists (ARONAH). ARONAH was created to prepare the professions of naturopathy and WHM for statutory registration and is active in petitioning the federal and state governments of Australia to include naturopathy and WHM as AHPRA-registered professions. ARONAH also handles complaints from members of the public regarding the standards of treatment received by individuals who use the title of ‘naturopath’ or ‘WHM practitioner’. ARONAH membership is determined based on an individual’s ability to meet set minimum practice and education standards. Membership of ARONAH has been open since 2013.
At present, due to the absence of statutory registration of naturopathy and WHM in Australia, naturopaths and WHM practitioners are accountable to the Health commissioner (or similar) in the state or territory where they practice. These commissioners are responsible for enforcing negative licensure legislation which can be defined as “a statutory scheme that allows a person or business to practise an occupation unless they breach statutory-based requirements”. While ARONAH has an established complaints process, this only applies to ARONAH members and complaints about non-members are referred to the state Health commissioner. Since ARONAH’s inception, none of the complaints they have received from the public have related to ARONAH members.
This means that while there is legislation to capture serious risks or damage to individuals after they have occurred, there are no government-enforceable barriers to unqualified practitioners claiming to be a naturopath or WHM practitioner. Therefore, no protection of the public by unqualified individuals practising. If a complaint is raised against a practitioner, then the Health commissioner will step in to investigate the case based on the negative licensure legislation and decide the outcome. However, the legislation is generic across all unregistered health professions, with no specific input or consideration of the unique practices of naturopaths and WHM practitioners. Unlike the NRAS, there is no board of peers, and no profession-specific guidelines which determine or help to shape the outcome.
In March 2019 the Australian Federal Government removed the ability for naturopaths and WHM practitioners to obtain private health insurance (PHI) rebates for their patients. This has removed a proxy regulatory mechanism from the profession. PHI companies required practitioners to meet certain professional and educational standards. This meant members of the public could have some confidence that if their practitioner could obtain these rebates, that they met some minimum requirements. PHI rebates required professional association membership, and many PHI providers required educational qualifications above and beyond the minimal standards imposed by some professional associations. As it stands, naturopathy and WHM are now the only health professions trained to a government-accredited degree level that are excluded from the PHI sector. There is a concern that in this unregulated environment potential practitioners may also not train in accredited educational programs, and regress naturopathic standards.
Statutory registration has a primary focus of protecting the public by upholding minimum standards for the profession. And until this is achieved in Australia for naturopaths and WHM practitioners, the public will continue to be put at risk. The criteria we have been waiting for the government to release since 2008 – and that new professions must meet to be considered for inclusion in the NRAS – is finally available. Now is the time for us to act. If you would like to help ANC in this endeavour, please donate to the Go Fund Me campaign here, or join ARONAH as a full or associate member by 31st of July. 100% of new membership fees will be donated to the campaign. If you are in the naturopathic or WHM profession, then memberships are tax deductible.