We, the undersigned members and supporters of Australia’s diverse counselling and mental health workforce, call on the Department of Health and Aged Care (DoHA) and the Mental Health Working Party to urgently revise the current Draft National Standards for Counsellors and Psychotherapists (November 2024) to ensure a fair, inclusive, and evidence informed framework that properly reflects the full breadth of professional pathways particularly those trained through Australia’s accredited vocational education and training (VET) sector...

Subject: Urgent Call for Inclusive Revision of the Draft National Standards for Counsellors and Psychotherapists

We, the undersigned members and supporters of Australia’s diverse counselling and mental health workforce, call on the Department of Health and Aged Care (DoHA) and the Mental Health Working Party to urgently revise the current Draft National Standards for Counsellors and Psychotherapists (November 2024) to ensure a fair, inclusive, and evidence informed framework that properly reflects the full breadth of professional pathways particularly those trained through Australia’s accredited vocational education and training (VET) sector.

Why We Are Deeply Concerned:

The draft standards, as they currently stand, risk marginalising Diploma qualified counsellors many of whom have decades of experience and are often the primary providers of frontline counselling in regional, rural, and lower income urban communities. Key areas of concern include:

1. Loss of Private Practice Eligibility (Section 1.3.1)

The draft currently designates “Foundational Counsellors” commonly understood to include those with a Diploma of Counselling (AQF Level 5) as having “no ability to work in private practice.” This blanket disqualification fails to recognise the capability and established practice of thousands of vocationally trained counsellors operating ethically and effectively across Australia.

2. Unclear and Unworkable Licensing Pathways (Sections 1.3.2 and 1.1.1)

The draft permits private practice only after:

Completion of 450 to 750 client contact hours; and
Licensing and endorsement by an unspecified “peak body.”
However, it fails to address critical questions such as:

• Who is authorised to provide these contact hours?
• Which peak bodies are recognised to endorse licensing?
• Will the minimum requirement be 450 or 750 hours?
• What is the cost, structure, and legal foundation of the proposed licensing process?

This ambiguity creates significant barriers to entry and advancement especially for students and early career professionals from disadvantaged backgrounds.

3. Disqualification from Supervision Roles (Section 1.2.3)

The draft prohibits both Foundational and “Qualified” (Diploma level) counsellors from providing clinical supervision. This is not only inconsistent with current practice but also unjustly disregards the role of many vocationally trained supervisors who are supporting and mentoring the next generation of counsellors within both clinical and educational settings.

What We Are Respectfully Requesting:

1. Formal Recognition of the Vocational Pathway

We seek explicit acknowledgment of the vital role played by Diploma and Advanced Diploma qualified counsellors (AQF Levels 5–6). These professionals must be recognised as legitimate and valued contributors to Australia’s mental health ecosystem distinct from but complementary to university trained professionals (AQF Levels 7–9).

2. Revision of Restrictive and Discriminatory Language

We request the immediate amendment or removal of clauses that arbitrarily restrict private practice, supervision roles, or other career pathways based solely on qualification level, without regard to demonstrated competency or real world performance.

3. Transparent and Equitable Licensing Framework

We call for the development of a clear, accessible, and cost transparent licensing framework that includes:

• Definition of what constitutes a “licence”
• Specification of recognised peak bodies and their criteria
• Consistent application of client hour thresholds
• Fair transitional arrangements for existing practitioners

4. Inclusive and Sector Wide Consultation

We urge DoHA and the Working Party to broaden engagement across the sector specifically including vocationally trained counsellors, RTO educators, employers, professional associations, and community based services before the draft is finalised.

Why This Matters for Australia’s Mental Health System

Vocationally trained counsellors are indispensable. They:

1. Provide high quality, client centred care to vulnerable populations
   Operate effectively in communities with limited access to university trained clinicians
2. Reduce pressure on overburdened public systems by offering flexible, community based services
   Strengthen the diversity, reach, and resilience of the mental health workforce
3. To exclude or diminish their contribution through overly prescriptive standards not only creates inequity it undermines service access, particularly in communities already suffering from significant mental health workforce shortages.

Our Position:

We believe in competency, not qualification alone, as the proper foundation of regulation. The final National Standards must reflect this by valuing all qualified counsellors vocational and tertiary alike based on their skills, ethics, and contribution to the mental health and wellbeing of the Australian community.

We therefore urge the Department of Health and Aged Care and the Mental Health Working Party to pause the implementation of the current draft, and to reengage in a genuine and inclusive co design process.

Please add your name and voice in support of this urgent call for equity, clarity, and respect for all qualified counsellors.

Read the VMHPAA full response to the National Standards Draft HERE

Keep checking our dedicated page to the National Standards HERE