AAPi has commenced legal action in response to the Therapeutic Goods Administration's (TGA) decision to restrict primary psychotherapist roles in psychedelic-assisted therapy (PAT) to psychologists with clinical endorsement while simultaneously expanding psychotherapy eligibility for other professions.
While this decision directly affects psychologists working in the emerging field of psychedelic-assisted therapy, AAPi believes the implications extend far beyond PAT.
Whether or not you are interested in working in PAT, this decision affects how psychology is viewed and represented across the broader health system. The PAT decision is a symptom of a much larger problem: when opportunities for psychologists are restricted to a single area of practice endorsement while other professions are included more readily, it weakens the standing of the entire profession.
It is very important to keep in mind that the National Law does not restrict the scope of practice for psychologists, regardless of whether you have an area of practice endorsement or not. The only practice limitations for psychologists relate to their knowledge and skills and their obligation to practice within the boundaries of their own scope of competence.
For decades, endorsement-based distinctions have been increasingly used to determine access to Medicare rebates, public-sector positions, funded programs, and advanced practice opportunities. AAPi has consistently argued that this approach does not reflect the breadth, diversity, and capability of the psychology workforce.
The PAT decision is one of the clearest examples we have seen of the broader consequences of the two-tier system. For AAPi, this is about much more than psychedelic-assisted therapy. It is about the future of the profession.
AAPi has advocated for broadening PAT to registered psychologists since 2023. Throughout the TGA consultation process in 2025, AAPi consistently argued that eligibility to act as a primary psychotherapist in PAT should be based on demonstrated competence, PAT-specific training and psychotherapy experience.
Importantly, the consultation discussions AAPi participated in supported broadening access. The position supported during the consultation was that psychologists who had completed the necessary PAT-specific training should be eligible to serve as primary psychotherapists regardless of endorsement status.
The final recommendation was therefore not the outcome AAPi expected, as we wrote about last week.
Our concern is with the broader implications of endorsement-based restrictions and what they mean for the future standing of psychology as a profession. Clinical psychologists are highly skilled members of our profession, as are all psychologists.
AAPi is deeply concerned that this recommendation has resulted in the majority of registered psychologists being excluded from primary psychotherapist roles in PAT, while occupational therapists, nurses, midwives, and medical practitioners may participate in those roles.
AAPi believes this approach risks further eroding psychology's standing within the health system and contributes to the ongoing blurring of psychology's role and scope of practice. When opportunities that could be undertaken by appropriately trained psychologists are restricted to a single area of practice endorsement, while other professions are afforded greater flexibility, the entire profession is disadvantaged.
It also creates an environment in which services that should be performed by appropriately trained psychologists are increasingly being opened to other professions under competency-based frameworks, while psychology itself remains constrained by endorsement-based barriers. The PAT decision is one of the clearest examples of this issue we have recently seen.
Following the release of the recommendations, psychologists sought clarification from the TGA regarding why registered psychologists without clinical endorsement were excluded from primary psychotherapist roles. In response, the TGA advised that:
"The Psychology Board of Australia determined that registered psychologists with an area of practice endorsement in clinical psychology to be the appropriate members of the psychology profession to act as primary psychotherapists within the therapy dyad."
The TGA further advised that the outcome was reached following consultation input and "final clarification and agreement with the respective professional boards."
AAPi is reporting information provided directly by the TGA. We are sharing this wording with members today as we are aware that psychologists are sharing the TGA justification quoting the wording across social media, and we wanted to be transparent with the AAPi community on the information we currently have available.
At this stage, AAPi has not had access to the communications, evidence, advice, meeting records, or briefing materials that informed the final recommendation. AAPi is not in a position to draw conclusions about how the final recommendation was reached or the role played by individual stakeholders until we obtain further evidence.
To better understand how the recommendation was reached, AAPi has commenced both advocacy and legal action. Our legal team has lodged Freedom of Information (FOI) requests with the TGA and Ahpra, including requests relating to the Psychology Board of Australia. The purpose of these requests is simple: to obtain the facts.
AAPi believes psychologists deserve transparency regarding decisions that affect the profession and the clients we serve. The information obtained through these requests will help inform both our advocacy strategy and any further legal options available to challenge the recommendations.
AAPi also notes that psychedelic-assisted therapy is not a standard component of any psychology training pathway. Competence in PAT is obtained through post-registration education, supervision, experience, and ongoing professional development. For this reason, AAPi believes that decisions about participation in PAT should be based on demonstrated competence, training, supervision, and experience rather than on assumptions linked to a particular area-of-practice endorsement.
How Members Can Help
AAPi encourages members to respectfully share their concerns directly with the TGA.
Email: [email protected]
When writing, we encourage members to focus on:
- Why competency-based approaches are preferable to endorsement-based restrictions.
- The importance of PAT-specific training and supervision.
- The inconsistency between restrictions placed on psychologists and those applied to other professions.
- The impact on client access and client safety.
Professional, respectful, evidence-based advocacy from psychologists can help ensure decision-makers understand the significance of this issue. Submissions written in your own voice are the most powerful, but please reach out to AAPi if you need assistance with a template email you can modify.
AAPi Will Continue to Fight for All Psychologists
AAPi was founded on the principle that all psychologists deserve fair recognition for their skills, training, experience, and contribution to the community. This issue goes well beyond psychedelic-assisted therapy. It goes to the heart of whether psychology will continue to be divided by endorsement-based barriers that diminish the profession's collective standing and create opportunities for professional substitution by other disciplines.
AAPi intends to utilise every avenue available to us, advocacy, legal action, stakeholder engagement, government relations, public education, and regulatory processes, to challenge this latest example of the two-tier system and to pursue broader systemic reform.
Our goal is not simply to change the PAT requirements. Our goal is to address the underlying structures that perpetuate artificial divisions within psychology and to advocate for a profession recognised on the basis of competence, capability, training, and experience.
The PAT decision has brought into sharp focus many of the flaws that AAPi has long argued exist within endorsement-based approaches. What was intended to be a decision about psychedelic-assisted therapy has instead raised much broader questions about how psychology is represented, valued, and recognised.
This issue may ultimately prove to be a pivotal moment in the ongoing effort to challenge and reform the two-tier system.
AAPi will continue using every appropriate advocacy and legal avenue available to pursue both change to the PAT requirements and broader reform of the systems that continue to create unnecessary divisions within psychology. We will not stop until all psychologists are afforded the recognition, respect, and opportunities they deserve.