Information for employers

UPDATED 22 September 2021 — Information for employers of health practitioners on the pandemic response sub-registers

Responding to COVID-19 remains an important focus for Australian Governments and the community. Registered health practitioners are playing a vital role in supporting the vaccination rollout and in providing healthcare across various settings.

Ahpra and the National Boards are supporting the COVID-19 response by helping provide a surge workforce when the healthcare system is experiencing changing demands due to outbreaks of COVID-19 variants. These practitioners are registered on the 2020 and 2021 temporary pandemic response sub-registers and are included on the national Register of practitioners.

Medical practitioners, nurses, midwives and pharmacists, along with Aboriginal and Torres Strait Islander Health Practitioners, who are registered on the 2020 sub-register until 5 April 2022, are limited to practice for the COVID-19 response.

A second temporary sub-register was established on 22 September 2021 for up to 12 months. Practitioners from across 12 regulated health professions are on the 2021 sub-register. These practitioners had recently stopped practising and can now return to practice if they choose to. They can work to the full scope of their registration (subject to any notations).

Practitioners on the sub-registers are not obliged to practise. They can opt out at any time and don’t need to explain why.

Ahpra and National Boards recognise health service needs may evolve as the COVID-19 pandemic continues and will keep working with state and territory and Commonwealth governments to support the COVID-19 emergency response.

This includes escalating applications for registration to the main Register of practitioners where there is workforce need due to demands created by the pandemic.

More information about the two sub-registers, including an infographic and up-to-date data about how many practitioners are on each, is on the pandemic response sub-registers page.

On the 2020 sub-register are medical practitioners, nurses, midwives, pharmacists and Aboriginal and Torres Strait Islander Health Practitioners. They are registered until 5 April 2022.

These practitioners can work in any area that supports the COVID-19 response, but only if they choose to help and are fit and suitable to do so. As of 8 September 2021, they are no longer limited to roles related only to supporting the COVID-19 vaccination rollout.

This change is reflected on a practitioner’s registration with the notation ‘Registered on pandemic response sub-register. Limited to practice for the COVID-19 response.’

Roles directly supporting the COVID-19 response are those associated with but not limited to:

  • vaccination rollout – administering the vaccine, handling and storage activities, dosing and administering the vaccine and/or helping with this, and/or safety and surveillance monitoring following vaccination
  • clinical and non-clinical roles directly related to the COVID-19 response
  • employment and practice as part of a surge workforce or temporary backfill positions due to outbreak management or quarantining of other health workers.

However, because the National Law1 protects the title of a registered practitioner rather than restricts their scope of practice, current registration may not be a requirement for all of the above role types, such as contact tracing and assessment of exemptions.

Whether a practitioner supporting the COVID-19 response needs to hold current registration, on the 2020 sub-register or the main register, is subject to the role’s responsibilities and the title of the position. For example, a practitioner who has retired and is not currently registered could be employed to assess exemptions or do contract tracing, so long as their job title is not one of the protected titles under the National Law.

A practitioner’s registration on the 2020 sub-register should not be used as a mechanism for employment of an individual in a long-term position.


1 The Health Practitioner Regulation National Law, as in force in each state and territory (the National Law).


On the 2021 sub-register are Aboriginal and Torres Strait Islander Health Practitioners, dental practitioners, diagnostic radiographers, medical practitioners, midwives, nurses, occupational therapists, optometrists, pharmacist, physiotherapists, podiatrists and psychologists. They are registered until 21 September 2022. These practitioners can work to the full scope of their registration (subject to any notations).

If governments alert us to significant changes in need, we may add other practitioners to the 2021 sub-register in the future to help facilitate additional surge health workforce.

The Register of practitioners is available on the Ahpra website. A copy of both the pandemic response sub-registers has been provided to state and territory health departments to help their pandemic workforce planning.

Private employers considering employing practitioners who are on one of the sub-registers can search for registered practitioners by surname on the Register of practitioners to check they hold registration.

On the public Register of practitioners, the practitioner's entry and a notation indicates if they are on the pandemic response sub-register.

Pandemic response sub-register notation

The practitioner’s entry on the Register of practitioners also includes the usual registration information including the practitioner’s qualifications and type of registration. Practitioners on the 2020 sub-register will have registration that ends on 5 April 2021 and practitioners on the 2021 sub-register will have registration that ends on 21 September 2022.

In order to fast track the return of experienced and qualified health practitioners to the workforce, most registration and return to practice requirements have been waived.

Practitioners have been asked to opt-out if they:

  • are unavailable or choose to not be included in the surge health workforce
  • have a health issue which prevents them from practising safely
  • have had a change to their criminal history
  • cannot get professional indemnity insurance arrangements in place as required to practise, or
  • are unavailable or not suitable or safe to practise.

Employers must conduct appropriate pre-employment checks before employing practitioners from the sub-registers.

Before employing a practitioner on the 2020 or 2021 sub-registers, employers need to consider:

  • whether the role the practitioner is being considered for supports the COVID-19 response (practitioners who are on the 2020 sub-register only)
  • conducting your own criminal history checks before employment. (Practitioners have not had to make criminal history declarations or had criminal history checks to be on the sub-registers.)
  • whether adequate professional indemnity insurance arrangements are in place. (Practitioners cannot work without appropriate insurance arrangements that meet their Board’s registration standard.),
  • the health of the practitioner. (Practitioners have not had to make any declarations about their health to be on the sub-registers.)

Employers who wish to employ or engage practitioners on the sub-register have a responsibility to support them to make a safe return to practice and to ensure patient safety. 

Employers should consider:

  • whether the practitioner has maintained recent skills and knowledge to carry out the role. (Practitioners have not been required to make any declarations about their recency of practice before being added to the sub-registers or while on it in the case of practitioners on the 2020 sub-register.)
  • the practitioner’s qualifications, experience, capacity and competence to safely practise autonomously or with direct/indirect supervision 
  • health service capacity to support any required supervision of the practitioner including available skill mix, model of care and staffing levels
  • the practitioner’s understanding of health service policies, procedures and clinical practice guidelines, including any necessary orientation and health service induction 
  • the practitioner’s understanding of their scope of practice, accountability and reporting responsibilities. 

Employers should also have regard to the health and safety of practitioners on the sub-registers, particularly if they are in a high-risk group for COVID-19 for more severe infection.

Practitioners on the 2020 or 2021 sub-registers are expected to complete any training or education that’s required while employed to ensure their knowledge and skills are appropriate for the role. While compliance with the registration standard for continuing professional development is required for continuing registration, there will be no checks for compliance with the standard when the sub-register is closed or if a practitioner on a sub-register chooses to apply for registration on the main register.

The 2020 sub-register closed on 19 April 2021 for diagnostic radiographers, physiotherapists and psychologists.

Medical practitioners, nurses, midwives and pharmacists, along with Aboriginal and Torres Strait Islander Health Practitioners, are on the 2020 sub-register with registration that expires on 5 April 2022.

Aboriginal and Torres Strait Islander Health Practitioners, dental practitioners, diagnostic radiographers, medical practitioners, midwives, nurses, occupational therapists, optometrists, pharmacist, physiotherapists, podiatrists and psychologists are on the 2021 sub-register with registration that expires on 21 September 2022.

As an employer you have an obligation to make sure that the registered health practitioners you have employed are registered. You can look up all registered health practitioners on the Register of practitioners. The public register will show if a practitioner is on the 2020 or 2021 pandemic response sub-register.

Diagnostic radiographers, physiotherapists and psychologists who were on the 2020 sub-register before it closed on 19 April had to apply for and be granted registration on the Register of practitioners to be able to keep working as a registered health practitioner.

Employers should check the registration status of anyone employed from the sub-registers. Diagnostic radiographers, physiotherapists and psychologists who were on the 2020 sub-register and are still practising must be on the Register of practitioners. Their entry will not show them as being on the pandemic response sub-register.

In early 2020, as health services prepared for the expected surge in demand resulting from COVID-19, Health Ministers asked Ahpra and National Boards to enable experienced and qualified health practitioners to quickly return to practice. A pandemic response sub-register enabled those eligible practitioners to be registered if they wish, without having to fill in forms or pay fees.

Changes in health service needs have resulted in temporary registration for specific professions on the 2020 sub-register ending after 12 months and other professions being extended for another 12 months at the request of the Commonwealth Health Minister.

The 2021 sub-register was established on 22 September 2021 at the request of health authorities who identified key professions to be included on it in response to increased health service needs due to the pandemic.

Sub-registers timeline

 
 
 
Page reviewed 22/09/2021