We, the undersigned psychologists of Australia, call on the Psychology Board of Australia to pause the proposed changes to the Psychology Recency of Practice Registration Standard and undertake further consultation with the profession before implementing changes that may significantly affect Australia's psychology workforce and community access to psychological care.

As psychologists, we understand the importance of regulation in protecting the public. We support maintaining professional competence throughout our careers, and we support evidence-based regulation that reflects both the science of competence and the realities of contemporary psychological practice.

It is because we value these principles that we are deeply concerned by the proposal to increase psychology's recency of practice requirements from 250 hours over five years to 450 hours over three years, or 150 hours in the previous 12 months.

Before implementing changes of this magnitude, we believe the Psychology Board should clearly demonstrate why these specific thresholds have been chosen, what evidence supports them, and how they are expected to improve public safety.

Our concerns

We believe the proposed changes raise five significant concerns:

• The case for change has not been clearly established.

The consultation paper acknowledges there is limited evidence identifying an optimal recency of practice threshold, yet proposes a substantial increase in requirements. It also does not clearly demonstrate that the current Recency of Practice Standard is resulting in harm to the public. Before implementing changes of this magnitude, we believe the Psychology Board should clearly demonstrate why the current standard is no longer sufficient, what evidence supports the proposed increase, and how it is expected to improve public safety.

• The proposal may disproportionately affect psychologists who require flexibility in their workforce participation.

The proposed standard states that there will be no exemptions, on the basis that the minimum requirements themselves provide sufficient flexibility. We do not believe this adequately reflects the realities of psychologists' working lives. Does this mean a psychologist taking extended parental leave following the birth or adoption of a child would be expected to continue working in order to maintain their registration? If not, how will psychologists who choose to step away from work during one of life's most significant transitions continue to meet the proposed requirements?

The same questions apply to psychologists living with chronic illness or disability, recovering from serious illness or injury, undertaking caring responsibilities, or navigating other major life circumstances. Approximately 80% of Australia's psychology workforce is female. Many psychologists intentionally adjust their participation in the workforce at different stages of life while balancing parenting, caring responsibilities, chronic illness, disability, neurodivergence and other significant life circumstances.

We are concerned that increasing recency of practice requirements, without reducing regulatory demands elsewhere, will make it harder for psychologists to make these professionally responsible decisions. Choosing to temporarily reduce clinical hours, work casually, or step away from practice for a period can be an important way of protecting wellbeing, preventing burnout and ensuring the delivery of safe, sustainable care. These decisions should not place psychologists at greater risk of losing their registration.

• The proposal appears inconsistent with the Psychology Board's own Professional Competencies.

The Board's recently updated Professional Competencies place a strong emphasis on self-care, sustainable professional functioning, reflective practice, neuroaffirming practice and recognising the diverse circumstances in which psychologists live and work. We are concerned that the proposed Recency of Practice changes move in the opposite direction by making it harder for the psychologists most affected by these circumstances to make the very decisions that protect their wellbeing and support safe, sustainable practice over the long term. Rather than enabling psychologists to practise in ways that are responsive to parenting, caring responsibilities, chronic illness, disability or neurodivergence, the proposal may unintentionally discourage the flexibility that the Board's own competencies recognise as essential to sustainable professional practice.

• Psychology deserves psychology-specific regulation.

The proposal places significant weight on achieving consistency across health professions without adequately demonstrating why this particular increase is necessary for psychology. Health professions are not a monolith. They differ in the competencies they require, the risks they manage and the ways practitioners maintain competence over time. We believe psychology deserves regulation that is informed by psychology-specific evidence, rather than consistency for its own sake.

• The proposal may reduce workforce participation and community access to psychological care.

Taken together, these changes risk reducing workforce participation at a time when Australia is already experiencing significant workforce shortages and increasing demand for psychological care. We are concerned that some psychologists may reduce their clinical hours, delay returning from parental leave or illness, move to non-practising registration, or leave the profession altogether because the increased requirements are no longer compatible with their life circumstances. Any reduction in workforce participation is likely to be felt most acutely in rural and regional communities, where access to psychologists is already limited.

We call on the Psychology Board of Australia to:

• Pause implementation of the proposed Recency of Practice changes.
• Publish the evidence supporting the proposed increase in recency requirements.
• Clearly explain why the current Recency of Practice Standard is no longer considered sufficient to protect the public.
• Undertake and publish an assessment of the likely impact on workforce participation, particularly for psychologists returning from parental leave, carers, psychologists living with disability or chronic illness, neurodivergent psychologists, rural and remote practitioners.
• Demonstrate how the proposed changes are expected to improve both public safety and access to psychological care.
• Continue meaningful consultation with the psychology profession before implementing any revised Recency of Practice Standard.

As psychologists, we believe regulation should be evidence-based, proportionate and designed to protect both the public and the long-term sustainability of the psychology workforce. We respectfully ask the Psychology Board of Australia to reconsider this proposal in partnership with the profession it regulates.

For psychologists wanting to also voice their concern about these proposed changes, we ask that you support by signing this petition and; 

• Include a comment about why you are signing this petition. Tell us how these proposed changes would affect your work, your family, your wellbeing, or the communities you serve. Your experiences will help demonstrate the real-world impact of this proposal when the petition is presented to decision-makers. For example:
  • Are you pregnant or planning to be pregnant and planning for maternity leave?
  • Are you returning from parental leave?
  • Do you live with a chronic health condition or disability?
  • Are you neurodivergent?
  • Do you work part-time to care for family members?
  • Do you work rurally or remotely?
  • Would these changes affect your decision to remain in the workforce?
     
• Consider also completing a personal submission to AHPRA via their online survey here: https://ahpra.au1.qualtrics.com/jfe/form/SV_7UP3v3qiorC9FSC

• Share the link to this petition and the link for personal AHPRA submission within your networks.

Thank you.