Australian Health Practitioner Regulation Agency - Correspondence to Senator Rennick on COVID-19 Vaccinations
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Correspondence to Senator Rennick on COVID-19 Vaccinations

23 Nov 2021

Senator Gerard Rennick recently wrote to us about Ahpra and the National Boards' position on COVID-19 vaccinations. We are sharing our response to Senator Rennick to clarify the facts and our position. 

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8 November 2021

Senator Gerard Rennick
Senator for Queensland 

Via Email:

Dear Senator

COVID-19 Vaccination

Thank you for your letter of 4 November 2021 in which you have asked whether Ahpra has been threatening ‘de-registration’ of medical professionals who raise concerns about the Covid vaccines as a result of adverse events that are presenting to emergency departments. I hope that the following information is of assistance in clarifying the facts and our position. 

National Registration and Accreditation Scheme

By way of background, Ahpra works in partnership with 15 National Boards to regulate registered health practitioners under a National Law passed by each State and Territory parliament. 

Under that National Law, neither Ahpra nor the 15 National Boards have any legal powers to ‘deregister’ a registered health practitioner. In circumstances where this was being proposed by a Board, cancellation of registration could only be a decision of a state tribunal or a Court.

There are circumstances in which we might temporarily suspend the registration of a health practitioner. However, this is an interim measure which is only ever taken to address an immediate risk to public safety, while our investigation occurs. A practitioner can appeal a decision to suspend their registration to a state tribunal.

I would note that, while the standards set by National Boards apply nationally, Ahpra does not directly deal with specific concerns about the conduct, health or performance of registered health practitioners in NSW. Further, in Queensland, we only deal with those matters referred to us by the Office of the Health Ombudsman.

Our expectations of registered health practitioners 

As you would expect, Ahpra and National Boards have received a significant number of questions about practitioner obligations in relation to COVID-19 vaccination. In response, we have published information on vaccines on our webpage. This information is intended to explain how the National Boards’ existing regulatory frameworks apply in the context of COVID-19 vaccination. 

These expectations of registered health practitioners are not new and predate the COVID-19 pandemic. However, as part of our regulatory role, National Boards have issued additional information since the pandemic began to clarify how these expectations apply to various COVID-19 related issues, including vaccination. 

Our vaccine position statement has been discussed with State, Territory and Commonwealth Health Departments and is consistent with the public health approaches being taken in all jurisdictions.

In essence, Ahpra and National Boards expect health practitioners to use their professional judgement and the best available evidence in practice. This includes when providing information to the public about public health issues such as COVID-19 and vaccination. When advocating for community and population health, health practitioners must also use their expertise and influence to protect and advance the health and wellbeing of individuals as well as communities and broader populations.

Any promotion of anti-vaccination statements or health advice which contradicts the best available scientific evidence or seeks to actively undermine the national immunisation campaign (including via social media) is not supported by National Boards. It may be in breach of the codes of conduct and subject to investigation and possible regulatory action. 

We do acknowledge that some health practitioners have a conscientious objection to COVID-19 vaccination and we respect this. The published vaccine position statement includes information for practitioners who conscientiously object to assist them to meet their obligations as a health practitioner.

For ease of reference I have reproduced the appropriate excerpt from the statement:

Conscientious objection 

In the case of a conscientious objection about receiving, authorising, prescribing or administering COVID-19 vaccination, practitioners must inform their employer and/or other relevant colleagues (where necessary) of their objection as soon as reasonably practical. For example, a practitioner’s personal beliefs may form the basis of a conscientious objection to particular treatments. 

In addition to the above, it is important that practitioners inform their patient or client of their conscientious objection where relevant to the patient or client’s treatment or care. In informing their patient or client of a conscientious objection to COVID-19 vaccination, practitioners must be careful not to discourage their patient or client from seeking vaccination. Practitioners authorised to prescribe and/or administer the vaccine but who have a conscientious objection must ensure appropriate referral options are provided for vaccination. 

While some health practitioners may have a conscientious objection to COVID-19 vaccination, all practitioners, including students on placement, must comply with local employer, health service or health department policies, procedures and guidelines relating to COVID-19 vaccination. Any queries about these should be directed towards the individual employer, health service, state or territory health department and/or education provider for registered students. National Boards regulate individual practitioners and not health services or state and territory health departments. Queries about COVID-19 vaccination programs should be directed to the Commonwealth, state and territory governments which are responsible for these programs. 

Exemption certificates

With specific regard to your enquiry about providing exemption certifications for COVID-19 vaccines I can advise that the Medical Board Code of conduct, Good medical practice: a code of conduct for doctors in Australia, requires practitioners to:

  • be honest and not misleading when writing reports or certificates, and only signing documents that they believe to be accurate and
  • taking reasonable steps to verify the content before signing a report or certificate, and not omitting relevant information deliberately

We expect any medical practitioner being asked to supply exemption certificates to use their clinical judgement; know and understand the advice provided by ATAGI, and; any specific State or Territory guidance.  I note that the ATAGI advice addresses the issue of serious adverse events attributed to a previous dose of a COVID-19 vaccine. 

Practitioners can also speak with their professional indemnity provider, who have also published clear advice to practitioners about when, why and how exemptions can be granted (for example see Avant and MIGA).

If concerns about a practitioner are raised with Ahpra and the National Boards, we are required to assess the concern to establish whether there is a risk to the public that needs to be managed by any regulatory action.  When considering notifications about COVID-19 vaccination related issues, we review any public health orders or guidance issued by governments and how they apply to practitioners and the concerns being raised. For example, it the concern is about contraindications and granting exemptions, we would reference the ATAGI advice and relevant state or territory guidance. We also provide an opportunity for the practitioner to respond to any proposed regulatory action before a final decision is made by a Board.

General information about how we manage concerns and assess risk is on the Ahpra website. 

I hope this information has been helpful in addressing your questions. I note that you have published your correspondence with me on social media. I would be very happy for you to publish my response as well.

Thank you for raising this matter with me.

Yours sincerely

Martin Fletcher 
Chief Executive Officer 

CC: Attorney General
      Minister for Health and Aged Care

Page reviewed 23/11/2021