AAPi is deeply concerned about the direction of the Psychology Board of Australia’s proposed education and training reforms, particularly the proposed downgrade of the pathway to general registration from an AQF Level 9 qualification to a 5-year undergraduate bachelor's degree with an AQF Level 8. While reform is needed, AAPi believes reform must strengthen, not diminish, the psychology profession. AAPi raised this issue with the Psychology Board prior to the public release of the proposal and met with the Psychology Board this week to again raise our concerns and propose solutions.
The Psychology Board’s proposed model would introduce a single five-year undergraduate pathway to general registration, replacing the current mix of postgraduate and internship-based pathways. The proposal aims to increase workforce supply, reduce costs, and streamline training.
Importantly, one of the stated aims of the reform project was to find solutions to longstanding problems within psychology education and training, including addressing inequities and access barriers for those seeking to attain general registration. The Board has specifically referenced the need to “standardise training pathways to address equity and access challenges” and reduce the burden created by the current fragmented system.
AAPi agrees that reform is needed. There are genuine issues within the current system that must be addressed, including placement bottlenecks, inconsistent access to Commonwealth Supported Places, different funding clusters for courses, delays entering the workforce, rising student debt, and the increasing pressures placed on supervisors and training providers.
However, while the proposed model attempts to simplify the pathway structure, AAPi is concerned that it does not adequately address some of the profession’s most significant structural problems and, in some cases, risks making them worse.
AAPi’s Core Non-Negotiables
Retaining a Postgraduate AQF Level 9 Qualification Through an Integrated Dual Degree Model
AAPi does not support a model where general registration is achieved solely through a five-year undergraduate degree at AQF Level 8.
At the same time, AAPi recognises that the current system creates significant stress, uncertainty, and inequity for students, particularly the major bottlenecks associated with having to competitively apply for separate postgraduate programs after completing undergraduate study.
AAPi believes there is a better solution.
We support an integrated 5-year dual degree model that contains a Master ‘s-level component and preserves a postgraduate qualification (AQF 9) while also addressing many of the inefficiencies and inequities of the current system.
Under this approach:
- Students would enrol from the outset into a combined Bachelor + Masters pathway
- The pathway would remain streamlined and integrated
- Students would not face the current competitive cliff of reapplying for a separate postgraduate degree
- Universities could structure training as a continuous program with embedded practical skills and placements, with graduate skill development and placements.
- Graduates would still leave with an AQF Level 9 qualification leading to general registration
In practical terms, this means students would still experience a simplified “single pathway” model, but without downgrading psychology to an undergraduate-only profession.
OPTION 1:
-
A 4-year Bachelor of Professional Psychology with Honours (AQF 8) degree,
with practical skills embedded from Year 2, and a supervised work integrated
learning (WIL) placement in Year 4 (Honours year).
-
Provisional registration upon commencing a 1-year Master of Professional
Psychology (AQF 9) degree, with WIL placement and General registration on completion.
OPTION 2:
-
A 3-year Bachelor of Psychology (AQF 7) degree, with practical skills
embedded from Year 2.
-
A 2-year Master of Professional Psychology (AQF 9) degree, with a
work-integrated internship with provisional registration, and General
registration on completion.
AAPi believes this approach achieves the core objectives of reform more effectively because it:
- Simplifies student progression
- Reduces bottlenecks and uncertainty
- Maintains professional standards
- Protects future remuneration and workforce recognition
- Preserves the scientist-practitioner model
- Aligns psychology more closely with comparable health professions
Importantly, this model does not recreate the current postgraduate bottleneck system, where students complete an undergraduate degree and then compete for a very limited number of separate master's positions.
Instead, students would enter a clearly defined integrated pathway from the beginning, with progression built into the degree structure itself.
AAPi believes this is a critical distinction that has not been adequately explored within the current proposal.
We strongly reject the notion that retaining AQF 9 necessarily requires maintaining the current fragmented system. Reform can and should modernise the pathway without diminishing the profession.
The Reforms Do Not Resolve the Two-Tier System
AAPi remains deeply concerned that the proposal fails to resolve one of the biggest issues facing psychology: the two-tier system.
For years, psychologists have raised concerns about a system that increasingly divides the profession into “higher” and “lower” valued groups based on endorsement status and rebate access, despite the fact that generally registered psychologists often undertake highly complex work across community mental health, disability, rural practice, schools, trauma services, and private practice.
Rather than addressing this inequity, AAPi is concerned that the proposed reforms may actually entrench and worsen it.
Under the proposed model:
- General registration would be downgraded to an AQF 8 undergraduate qualification
- The gap in perceived professional status may widen further
- Future remuneration differentials may become even more entrenched
Why the AQF Level Matters
Firstly, what is an AQF level, and why should you care? Many of you will have seen the issue of AQF levels raised in recent AAPi communications and in growing discussions across social media, universities, workplaces, and the broader profession.
The Australian Qualifications Framework (AQF) is the national system that classifies the level and complexity of educational qualifications in Australia. AQF levels are not simply academic labels; they influence how professions are recognised. AQF classification influences:
- Public sector pay scales
- Enterprise agreements
- Award classifications
- Funding
- Workforce recognition
- International equivalence
- Career mobility
- Future earnings and superannuation
Under the current system, pathways leading to general registration in psychology sit at AQF Level 9. The Psychology Board’s proposed reforms would downgrade general registration to AQF Level 8. The modelling we have seen suggests that the proposed downgrade amounts to hundreds of thousands of dollars less in wages and superannuation over a psychologist’s career.
At a time when psychology is already facing workforce shortages, scope creep from other professions, burnout, increasing complexity of presentations, and recruitment challenges across rural, regional, public, and community sectors, we are deeply concerned about reforms that may weaken the attractiveness, the rigour of the study and training, and perceived value of the profession.
In our meeting with the Psychology Board, they stated that, given their remit, they are not focusing on the very likely consequences of these proposed changes on employment opportunities or remuneration. As your peak body, we have represented the current and real concerns faced by the current and future workforces, and the potential for flow-on effects that can negatively impact our members’ earning capacity.
Retaining Provisional Registration for Postgraduate Training
AAPi also believes provisional registration must remain in place, particularly given the current structural and legislative frameworks that allow provisionals to practice and work in specific settings, such as occupational rehabilitation and under the NDIS. Under the Psychology Board’s proposed model, provisional registration would be replaced by student registration. Students’ registration in the early years is appropriate. We do not believe provisional registration should be removed during the most advanced/postgraduate stages of professional training.
AAPi supports student registration for earlier work-integrated learning placements where appropriate. However, once students move into advanced/postgraduate professional practice and complex placements, provisional registration should remain to ensure appropriate levels of oversight and minimise risk to the public.
This approach better protects:
- Clients
- Students
- Supervisors
- Employers
- The integrity of the profession
Major Workforce Problems Remain Unresolved
AAPi is also concerned that several major workforce issues remain largely unaddressed within the current proposal.
Rural, Regional and Remote Workforce Distribution
The reforms focus heavily on increasing overall graduate numbers, but there is limited evidence that simply increasing graduate supply will resolve the maldistribution of psychologists across rural, regional and remote Australia.
AAPi continues to advocate for:
- Rural placement incentives
- Funded supervision supports
- Sustainable regional workforce pathways
- Better remuneration structures
- Long-term workforce retention strategies
Without these measures, workforce shortages in underserved communities are unlikely to improve meaningfully.
Graduate-Entry and Mature-Age Pathways
AAPi is also concerned about the lack of clarity regarding:
- Graduate-entry pathways
- Mature-age students
- Career changers
- Internationally qualified psychologists
- Recognition of prior learning pathways
Australia’s psychology workforce includes a significant number of mature-age entrants and internationally trained professionals. The current proposal appears heavily oriented toward school-leaver entry models and does not adequately outline how future graduate-entry pathways would operate. AAPi believes preserving and indeed increasing workforce diversity must remain a priority.
Supervision and Placement Sustainability
The proposal also does not adequately address the longstanding lack of funding, recognition, and support for supervisors.
The profession already faces:
- Placement bottlenecks
- Unpaid supervision burdens
- Increasing administrative complexity
AAPi remains concerned that expanding placement requirements without adequate funding and support for supervisors may place even greater strain on an already stretched workforce.
Concerns About Lack of Detail
AAPi is also concerned that major components of the reform proposal remain undefined, including:
- Transition arrangements
- Graduate-entry pathways
- The future structure of AoPE
- Psychology assistant roles
- Supervision models
- Placement governance
- Funding implications
- Impacts on rural and regional workforce supply
- International equivalence and mobility
- Implementation information
Even the Psychology Board has acknowledged that significant elements still require further development. AAPi does not believe reforms of this magnitude should proceed without substantially more clarity and meaningful profession-wide consultation.
AAPi’s Position
AAPi supports thoughtful reform that:
- Reduces unnecessary barriers
- Improves workforce sustainability
- Strengthens placement systems
- Values supervisors
- Expands access to training
- Maintains public safety
- Protects the value of psychology qualifications
- Preserves the scientist-practitioner identity of the profession
However, we cannot support reforms that downgrade general registration.
AAPi will continue advocating strongly for:
- A combined Bachelor and Master’s integrated pathway leading to an AQF 9 qualification for general registration
- Retention of provisional registration during postgraduate professional training
- Meaningful consultation and transparency
- Protection of future workforce remuneration and professional standing
- Sustainable and safe workforce reform
- Genuine solutions to workforce maldistribution and supervision sustainability
We encourage all members to engage with the consultation process and make their voices heard by providing your feedback by Wednesday, 10 June, via the Psychology Board.
The Psychology Board’s proposed reforms would shape the future of psychology in Australia for decades to come. This is one of the most significant structural changes our profession has faced in generations.
Further information
Please see the Psychology Board website consultation page.
There have been detailed concerns raised about the changes from across the profession, including academics, clinicians and training providers. We have included some examples to encourage engagement, reflection and debate.
Dr Beau Gamble has posted a LinkedIn series exploring the student, client, workforce and university impacts of the reforms, while Professor Eric Vanman (University of Queensland) and Benchmark Psychology have published YouTube videos raising concerns about risks, unintended consequences and the need for greater clarity around consultation processes. Professor Linda Byrne from The Cairnmillar Institute has also shared several LinkedIn commentaries on the potential impacts of the changes, alongside an article from Kathryn Nicholson Perry examining the risks.
AEDPA has also published a comprehensive position summary outlining the elements of the reforms it does not support.