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Department of Education – Department of Immigration and Border

Protection

Stakeholder Details

Organisation name

Australian Institute of Radiography Contact information

David Collier – david.collier@air.asn.au

Streamlining recognition in skilled migration and employment

1. What has been your experience with Australia’s skilled migration programme?

The skilled migration programme has enabled practitioners in the field of medical imaging, radiation therapy and sonongraphy to be assessed to add to the skilled population in Australia.

a) What are your organisation’s main roles and responsibilities and how have these changed over time.

The Australian Institute of Radiography (AIR) is the peak body for those health professionals who work in the disciplines of Diagnostic Radiography/Medical Imaging, Radiation Therapy and Ultrasound. More than 70% of Diagnostic Radiographers, Radiation Therapists and Sonographers working in Australia are involved in some aspect of the Institute, including participation in the AIR's Continuing Professional Development (CPD) program.

The AIR is the leading body for the promotion and advancement of the medical radiation science profession providing leadership on:

• Recognising the professional status of practitioners;

• encouraging professional standards, accreditation and public policy and debate regarding the profession;

• encouraging professional development, education and research;

• engaging practitioners in the future of their profession, while supporting and enhancing their ability to practice today; and

• providing community advice.

The AIR does this through the provision of information in many forms (magazine, e-learning, web based information and seminars and meetings); through funding research and development; through setting academic and professional standards and extensive provision of continuing professional development (CPD), the AIR has national expert panels providing guidance, advice and expertise supporting all of these activities.

As a professional body, our aims are to promote, encourage, cultivate and maintain the highest principles of practice and proficiency in respect of Medical Radiation Science. The AIR facilitates educational activities, discussion and consultation among members and others. We recognise undergraduate courses across Australia, set standards of competency in practice and encourage scholarship and continuing professional development. Prior to the introduction of the Australian Health Practitioner Regulation Agency (AHPRA), the AIR

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was responsible for the accreditation of university programs around Australia and running a training program to assist students in their graduate year to undertake the Professional Development year later known as the National Professional Development Program. The primary role of the AIR has now been usurped through the actions of AHPRA and their interpretations of National Law. This involves registration as well as the fundamental education accreditation for which the professional body (representing the profession) has been totally exempt from having an opinion. Collaboration has been sought by the AIR with AHPRA, however this has not been acknowledged or acted upon to date. The two bodies should be collaborating for the best outcome for all practitioners.

b) How is skilled migration benefiting the occupation(s) you have a role in?

Skilled migration is enabling areas of shortage especially in the field of ultrasound in rural locations to have sonographers service a need in these areas. Currently in medical imaging there are many local students requiring positions, so there has not been a great need for the overseas candidates. The numbers have been fluid in the area of radiation therapy, where there are not many candidates from overseas having these specific skills assessed. This potentially could be as a result of the smaller numbers of graduates exiting university programs, and home countries with shortages in this specific field.

c) What trends are you seeing in skills assessments?

The skills assessments over the period of the last numbers of years have become increasingly sloppy. Information is not complete, or not present, and many candidates are contacted to submit further documentation correctly certified. Candidates are also not reading the information and presenting applications that do not meet the required standards. Applicants are also submitting applications when their qualification does not meet the Australian standard (especially in sonography) and these guidelines are published widely and easily accessible.

d) What are the main policy issues for recognition preventing skilled migration in your occupation(s) where there is scope for improvement in the short – to – medium term?

Some areas of need can be clearly identified. As the assessing authority, it is the belief that we should have the ability to contribute to discussions on employment availability. The current market situation is that there are an overwhelming numbers of local graduates with no jobs immediately available post graduation. This is seen to be more predominant in the field of Medical Imaging. This has resulted from university enrolments that are in excess of available clinical placements and thus contributing to a large strain resource wise on the clinical centres. There are also more market forces appearing on the horizon with a new course opening up with enrolment numbers between 80 – 100 students. There is the issue of rural centre’s that require more support and reliance on other health care professionals to undertake some of our duties.

Many overseas applicants want to get work here with qualifications that do not meet our detailed professional standards and some are accepted by the registration body AHPRA with what appears to be a limited review of the undergraduate programs and respective work experience. Based on a

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review of outcomes to date, AHPRA have not been able to collaborate in any round table discussions with the AIR to produce a successful process of ensuring a smooth transition for candidates undergoing both a skills migration process and a registration process. We recommend consistency and consultation to improve this particular challenge.

2. What are your skills assessment criteria based on? How do you review your criteria and assessment methodology? Who do you consult with?

Criteria underpinning the skills assessment criteria revolve around the key registration standards. These include undergraduate qualifications, english language, recency of practice and relevancy of practice and demonstration of continuing professional education.

3. What interaction do you have with Australian Education providers?

Prior to July 2012 before AHPRA was introduced into the profession, the AIR was responsible for the accreditation of all University programs in Australia. There was a continuous flow of communication between the universities and the Professional Education and Accreditation Board (PAEB). Whilst the transition from the AIR is occurring to AHPRA’s Supervised Practice Program, the universities are no longer required to provide lists of successful graduates to the AIR. The AIR does not have a large role with respect to university courses. Currently the AIR has no involvement in course accreditation. There is no facility or mechanisms in which to have input into determining the core basic skills required or the numbers of graduates that are being accepted into the courses with the resultant large cohorts of graduates exiting the program and no jobs available for these graduates.

a) What benefit does the accreditation of courses have on your skills assessments?

See (b)

b) Are there any issue with course accreditation relating to skills assessment or employment, and are they being effectively managed?

As the accreditation unit has just commenced their accreditation of the university programs, we are waiting to have these confirmed to establish the professional standard. This will have an effect on the skills assessment being undertaken, as the current skills are measured against the Professional Practice Standards of the AIR. http://www.air.asn.au/cms_files/10_Publications/policies_guidelines/pps_air_dec2013.pdf

4. What has been your experience with skills assessment of Australian graduates?

There have been no significant issues with skills assessments of Australian Graduates. This however is being eroded away through the interference and undertakings of AHPRA.

There will be implications when the course accreditation unit completes their accreditations of

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university programs.

a) Can you describe the circumstances where an Australian qualification would not meet the criteria for a positive skills assessment?

When a graduate completes their undergraduate program and does not undertake the Supervised Practice (SPP) year and they return to their international hometown and undertake practice. As they have not completed their program in Australia under the SPP guidelines, they would not meet the requirements for a skills assessment. In the case of ultrasound, candidates can enter an accredited ultrasound program on a student visa. When they undertake the Diploma of Medical Ultrasound ( DMU), they may experience circumstances which prevent completion of the program in a timely manner. This may exceed the timeframe for which they have a visa, and if they have not completed their program at this point in time, they will be unable to obtain successful skills assessment.

5. In relation to employment:

a) What are the main issues preventing workforce participation in your occupation(s)

The AIR has been gazetted by the Department of Immigration to undertake skills assessments for graduates from overseas. This is an assessment to ensure that the practitioner has the appropriate skills and qualifications which meet the requirements of skilled migration. AHPRA undertake their assessment of overseas practitioners for the purposes of meeting basic standards for registration. There are many practitioners worldwide who wish to work here with qualifications that are nowhere near our standards and some are accepted by AHPRA with obviously no thought given to their courses or work experience. AHPRA seems to be afraid of allowing or acknowledging that a “body” other than themselves has the ability, skill and knowledge to critique and assess on the credentials (both academic and clinical) of overseas candidates. There needs to be acknowledgement and professional courtesy for professional bodies such as the AIR. There is a large conflict between the two organizations with respect to these assessments. Ultimately, practitioners can be registered to practice in this country, however if the practitioner does not meet the professional standard for a skills assessment, they will not be issued with a positive skills assessment, and therefore unable to enter Australia to practice their profession. See Appendix 1 for recent issues of overseas graduates and skills assessment. The AIR does not see any advantages, only disadvantages. The AIR have effectively become redundant where the professional body should be seen as setting the standard and the registration body should be collaborating with the professional body to ensure that these practice standards are maintained.

b) For an occupation(s) that has another body controlling access to employment, what are the advantages and disadvantages of this separate structural arrangement?

N/A

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6. What would be the consequences if meeting the criteria for registration / licensing / membership for employment in an occupation is deemed as meeting the criteria for a positive skills assessment in that occupation?

This effectively will make the professional body who upholds Professional standards redundant in medical imaging and radiation therapy. The AIR currently undertakes the assessments on behalf of the Australian Sonographer Accreditation Registry (ASAR). The resultant successful assessment results in registration of the practitioner with ASAR. This process has not been earmarked for change as yet.

7. What opportunities are there to better streamline policies, eliminate inequitable recognition barriers and reduce unnecessary regulatory tape across study, migration and employment pathways?

The AIR has a system and process in place for overseas candidate seeking skills assessment. Currently the overseas candidates are confused and complicated by these processes. For the candidate to undergo the AIR’s process and then have to submit the same documentation twice under a set of different rules and conditions for the registration body is impractical and a huge burden and stressor for candidates.

8. How can the Department of Education better support your role in skilled migration?

Our strong recommendation is that the skills assessment process is undertaken by the AIR, as this professional body is the best positioned to demonstrate and understand the needs and requirements of the profession. The universities need to be cognizant of the immediate harm being created by the significant increase of student numbers into the Medical Radiation Science field. These students may not all obtain their required supervised practice positions at the conclusion of their academic qualifications and therefore not be able to become qualified practitioners that then contribute to the wider community. These graduates that are unable to find positions will then return to the workforce in a capacity which does not utilize the skills that they have spent the last 3-4 years studying and this would become a significant problem in the long term. The Department of Education may consider reviewing the numbers of graduate being accepted into programs, look at the number of new programs commencing at the various universities, and also undertaking a study which will analyze the impact of graduates exiting the program and not being able to work in the profession of their choice. Clinical placements are at a premium, and not all graduates will be able to find a position in this current climate. Although the university may be able to change their programs to fit in clinical placements for the increasing cohorts of students, this reduces the “hands on” time required for successful learning. The Department of Education may also consider wish to re consider the projections for health care

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for the ageing and rural workforce using realistic numbers. The Department of Education could also assist the AIR in conducting a survey of the employers of applicants granted skill recognition to determine if their knowledge, skills and scope of practice were consistent with expectations of Australian graduates. This would give us more data to demonstrate the assessment standard.

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Appendix 1

Candidates accepted by OQAP and rejected by AHPRA

2012 candidate. OQAP offered a CBA. AHPRA offered 48 weeks SPP.

Candidate accepted by AIR. AHPRA placed conditions on registration for 12 months

Candidate from an educational institution not listed on MRPBA Equivalent list of program study.

Candidate met all requirements for UG and clinical experience in DI. Has three years PG clinical experience.

Candidate from an educational institution not listed on MRPBA Equivalent list of program study.

Candidate met all requirements for UG and clinical experience in DI. HPC registered. Has four years PG clinical experience.

AHPRA letter "Bachelor Degree in Radiology has content that is more consistent with diploma qualification and there is an unacceptably low level of clinical training,

and the technique subjects appear to provide only a cursory overview of core professional practice requirements, when compared to an Australian qualification."

Candidates accepted by AHPRA and rejected by AIR

Candidate accepted by AHPRA (on equivalent list of program study) and rejected by AIR. Candidate did not meet recency of Practice for AIR.

Candidate only worked part time and did not match full time hours.

UG program short of Australian Standard. Already had MRTBQ registration at time of AHPRA coming into force.

MRI candidate. No recency of practice in radiography for over 3 years. MRPBA registered candidate although there is no legislation to register MRI technologists.

Abbreviations AIR – Australian Institute of Radiography AHPRA – Australian Health Practitioner Regulation Agency MRPBA - Medical Radiation Practice Board of Australia MRTBQ – Medical Radiation Technologist Board of Queensland UG – Undergraduate PG – Postgraduate DI - Diagnostic Imaging CBA – Competency Based Assessment HPC – Health Professionals Council (United Kingdom) MRI – Magnetic Resonance Imaging