Australian Health Practitioner Regulation Agency - Managing and directing
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Managing and directing

2018/19 Annual Report - Our National Scheme: For safer healthcare

Key initiatives

  • Created a new online portal, enabling paramedics to register online
  • Implemented a new national model for registration and legal services and finalised a national compliance model
  • Developed a new scheme-wide approach for managing National Boards' equity
  • Delivered a cross-organisation program to ensure compliance with new requirements for the Information Publication Scheme under the Freedom of Information Act 1982

Agency Management Committee

The Agency Management Committee is appointed by the Ministerial Council. It ensures that AHPRA performs its functions in a proper, effective and efficient way. It is responsible for determining and agreeing AHPRA policies and setting the strategic direction for the National Scheme.

Organisational structure and resources

Four directorates govern AHPRA’s corporate activities with a total of 992 full-time equivalent staff: Regulatory Operations 668, Strategy and Policy 105; Business Services (including CEO office) 196; and People and Culture 23.

Regulatory Operations is responsible for the efficient and effective delivery of core regulatory functions – registration, notifications, compliance and legal services – under the National Law. It provides leadership and strategic direction in developing and providing operational policy and procedures that support decision-making across these functions. Offices in each state and territory deal directly with local stakeholders and support the decision-making of local boards and committees.

This directorate is accountable for operational performance across the regulatory functions. It is committed to continuous improvement and quality assurance of our regulatory processes, through the continued refinement of our service model.

In 2018/19 we continued moving towards a national function-based operating model to carry out all our regulatory functions. The national models for legal, registration and parts of our notification functions have been confirmed and implemented, and we finalised a national model for compliance to be implemented next year.

Arranging our regulatory teams along national reporting lines will enable national consistency in how we work, and how we make our work visible, and will allow us to mobilise the skills and expertise of all our staff. The national model includes having clear points of contact for our stakeholders at each of our state and territory offices, including the state and territory managers.

Strategy and Policy undertakes whole of National Scheme strategy, policy, engagement and regulatory governance functions that are effective and responsive. It provides high-quality services that are national and run across the professions we regulate. It works in partnership with National Boards and collaboratively with accreditation authorities and key partners.

Business Services delivers corporate support, providing effective and efficient business systems and processes to reach our strategic objectives. Its main functions include providing information technology, cyber security and architecture, facilities management, finance and procurement, scheme-wide insurance portfolio, and organisation-wide risk management to ensure that we manage risk well.

People and Culture provides services to meet the needs of our people from employee engagement through the whole of their AHPRA career. This includes services such as learning and organisational development, health and wellbeing, recruitment, payroll and remuneration, leave and benefits, staff movements, and starting with and leaving AHPRA.

National Executive

The National Executive is AHPRA's national leadership group. In 2018/19 its members were:

  • Mr Martin Fletcher, Chief Executive Officer
  • Ms Kym Ayscough, Executive Director
    Regulatory Operations
  • Ms Judith Pettitt, Executive Director
    People and Culture (interim to 3 August 2018)
  • Mr Mark Edwards, Executive Director
    People and Culture (from 3 September 2018)
  • Ms Sarndrah Horsfall, Executive Director
    Business Services
  • Mr Chris Robertson, Executive Director
    Strategy and Policy

State and territory managers

Our state and territory managers are our senior leaders in each jurisdiction, and are based at each of our offices:

  • Australian Capital Territory
    Mr Anthony McEachran
  • New South Wales
    Ms Jane Eldridge
  • Northern Territory
    Ms Eliza Collier
    Ms Inta Tumuls (acting, 24 Dec to 15 March)
  • Queensland
    Mr Howard Spry (acting, from 4 March)
    Ms Rose Kent (to 1 March)
  • South Australia
    Ms Sheryle Pike
  • Tasmania
    Mr David Clements (from 3 June)
    Ms Lisa McIntosh (to 31 May)
  • Victoria
    Dr Clarissa Martin PhD (from 3 June)
    Mr Murray Smith (to 12 June)
  • Western Australia
    Mrs Karen Banks (from 24 June)
    Ms Eliza Collier (acting, to 21 June)
    Ms Robyn Collins (to 21 Dec)

Financial management

We work to ensure the long-term sustainability of the scheme. We do this through strategic financial management with a long-term view considering the strategic goals and objectives of the scheme. We plan, organise, direct and control the financial resources, ensure compliance with legislation and provide guidance to the National Boards.

The Finance, Audit and Risk Management Committee (FARMC) is the principal committee of the Agency Management Committee that oversees finance, audit and risk. This committee reviewed the annual financial reports and projections with management, focusing on the integrity and clarity of disclosure, compliance with relevant legal and financial reporting standards, and the application of accounting policies and judgements.

AHPRA’s income for the full financial year to 30 June 2019 was $203.22 million. Our income for the full year includes the components shown in Income type table.

Income type 2018/19

Income type Full year $'000
Registration income 177,022
Application income 15,723
Interest income 5,084
Legal fee recoveries 1,749
Exam fees 1,086
Late fees and fast-track fees 754
Certificate of registration status 337
Accreditation income 242
Application for registrar program 221
Other income 1,000
Total 203,218

AHPRA and the National Boards work in partnership to ensure long-term financial sustainability. We recorded a net deficit of $6.132 million in 2018/19.

Fees set for each National Board aim to meet the full costs of regulation for each profession. The Registration fees for each profession table provides an overview of registration fees by profession since the start of the National Scheme.

Registration fees for each profession

Profession Fee ($) 2010/11 Fee ($) 2011/12 Fee ($) 2012/13 Fee ($) 2013/14 Fee ($) 2014/15 Fee ($) 2015/16 Fee ($) 2016/17 Fee ($) 2017/18 Fee ($) 2018/19
Aboriginal and Torres Strait Islander Health Practice     100 100 100 100 120 150 150
Chinese medicine     550 563 579 579 579 579 579
Chiropractic 495 510 518 530 545 552 566 566 566
Dentists and specialists 545 563 572 586 603 610 628 647 663
Dental prosthetists 485 501 509 521 536 542 558 575 589
Dental hygienists and therapists 270 279 283 290 298 301 310 319 327
Medical 650 670 680 695 715 724 724 742 764
Medical radiation practice     325 295 250 180 180 180 185
Nursing and midwifery 115 160 160 160 150 150 150 155 170
Occupational therapy     280 230 160 130 110 110 110
Optometry 395 408 415 395 365 325 300 300 300
Osteopathy 480 496 504 516 416 386 376 376 376
Paramedicine1                 275
Pharmacy 295 305 310 317 317 320 328 336 396
Physiotherapy 190 196 199 179 159 120 110 110 140
Podiatry 350 362 368 377 388 378 378 378 378
Psychology 390 403 409 419 431 436 449 462 474

Corporate legal compliance

AHPRA is subject to a wide range of Commonwealth, state and territory legislation and subordinate rules made under that legislation, such as regulations and obligations under the general law. We are committed to constantly reviewing and improving both AHPRA and National Board procedures and activities to comply with these laws and to promote a culture of compliance. We have carried out a range of activities, described below, to instil the principles set out in Australian Standard 3806–2006: Compliance programs into our everyday activities.

When compliance concerns have been identified through monitoring, or applicable legislation is amended, relevant staff have been allocated responsibility to take practical steps to ensure compliance. Responsible officers regularly report to AHPRA’s senior executives and the FARMC on the compliance steps they propose to take or have taken. This occurred in 2018 when amendments were made to the Health Practitioner Regulation National Law, which changed the way the Privacy Act 1988 (Cth) and Freedom of Information Act 1982 apply to AHPRA and the National Boards.

AHPRA engages third party providers such as contractors and consultants to help administer the National Law. To ensure compliance with the National Law and the wider regulatory framework, AHPRA’s standard contract terms require contractors to comply with applicable legislation and policies, including confidentiality, privacy, freedom of information (FOI), information security, record management, employment, and workplace health and safety. Where appropriate, AHPRA requires contractors to permit audits to demonstrate compliance.

Within the past 12 months, AHPRA introduced a new procurement policy and intranet site to enhance organisational compliance with financial management duties under Part 9 of the National Law. AHPRA also maintains a central repository for contracts and tenders, designed to monitor contractor performance and achieve expense resource planning.

Practitioner Information Exchange program

Practitioner Information Exchange (PIE) is a secure web-based system providing information to employers about the registration of the health practitioners they employ, including any restrictions that a Board might have placed on their registration. It helps employers connect human resources, clinical management, risk management, IT security and customer management systems into an effective health practitioner registration data source.

This year, there were 94 subscribers to the PIE service from government departments, public and private hospitals, and the educational and research sectors.

Administrative complaints

This year has seen a significant change in the way that AHPRA manages and responds to administrative complaints. AHPRA has revised its administrative complaints handling policy and procedure and created a new National Administrative Complaints team led by a National Complaints Manager, to ensure national consistency and oversight of our complaints management framework.

The purpose of the new policy is to listen to the concerns that people have raised, and respond to complaints promptly, empathetically and fairly. We are committed to excellent customer service and continuous improvement. Feedback is always welcome and helps us improve our services and this is why it was important to us to improve our management of administrative complaints.

The new policy makes it easier for people to make a complaint, to understand how we will manage their complaint once we receive it and what people can do if they remain concerned after they receive our response.

We have also significantly reduced the expected timeframes to respond to a complaint.

The new policy was published on our website along with revised information about how we manage complaints, on 12 April 2019.

Straightforward complaints (stage 1) are handled by the area that receives them, and complex complaints (stage 2) by the Complaints team. Stage 3 complaints are investigated or reviewed externally by the National Health Practitioner Ombudsman and Privacy Commissioner (NHPOPC). We report annually on all stage 2 and 3 complaints.

This year there was an increase in the number of complaint matters dealt with directly. We received 297 stage 2 complaints directly, up from 234 last year. A total of 214 complaints were transferred to us from NHPOPC. We also assisted the NHPOPC with 128 investigations which were initiated during the reporting period. The Stage 2 complaints by profession table outlines the number of complaints we received directly by profession. We are continuing to refine our data to ensure complete reporting on administrative complaints.

Stage 2 complaints by profession

Profession Number of direct complaints Number of complaints transferred from NHPOPC1, 2 Number of Investigations opened by the NHPOPC
Aboriginal and Torres Strait Islander Health Practice      
Chinese medicine 3 3 1
Chiropractic 3 1  
Dental 15 9 5
Medical 121 57 69
Medical radiation 6 4  
Nursing and midwifery 73 75 29
Occupational therapy 9 6 1
Optometry 2   1
Osteopathy 2 1  
Paramedicine 2 4  
Pharmacy 5 2  
Physiotherapy 8 6 1
Podiatry 2 7  
Psychology 46 39 21
Total 297 214 128

Notification complaints

This year we received 129 stage 2 complaints about notification-related matters. The majority of these complaints were about dissatisfaction with the decision made. Other categories of complaint were about communication during the management of a notification and concerns about delay. The NHPOPC referred 67 complaints to AHPRA that related to notifications. Of these complaints 57 were received from notifiers and 10 from practitioners. The Stage 2 notification complaints by issue table provides information about the number of notification-related complaints received directly.

Stage 2 notification complaints by issue

Issue Number (direct)
Dissatisfaction with decision 95
Communication 10
Delay 15
Other 9
Total 129

Registration complaints

This year we received 161 stage 2 complaints about registration-related matters. Complaints about delay in registration applications accounted for 65.8% of all registration-related complaints. Other categories of complaint were concerns about registration policy and communication. The NHPOPC referred 140 registration complaints to AHPRA for direct management. Of these complaints 110 related to delay, 26 to process and/or policy and four to fees. The Stage 2 registration complaints by issue table provides information about the number of registration-related complaints received directly.

Stage 2 registration complaints by issue

Reason Number (direct)
Delay 106
Communication 7
Policy 12
Other 36
Total 161

Other complaints

Of the remaining seven complaints received directly, three were about Boards, three about campaigns, and one about privacy. Of the seven remaining complaints that were forwarded to us from the NHPOPC two were complaints relating to Freedom of Information and five related to privacy.

Freedom of information

Section 215 of the National Law provides that the Commonwealth’s Freedom of Information Act 1982 (FOI Act) applies to the National Law, as modified by regulations made under that law.

AHPRA received 273 Freedom of Information (FOI) applications, including 29 applications for internal review and one tribunal/court-related matter.

During the year, 265 applications were finalised including 28 internal reviews and one tribunal/court-related matter.

As at 30 June 2019, 24 matters remain on hand.

Finalised FOI applications in 2018/19

Outcome Number
Granted in full 39
Granted in part 136
Access refused 60
Transferred in whole  
Transferred in part  
Withdrawn 29
Total1 264

Legislative changes about freedom of information

Some significant changes to the law that regulates access to the information we hold occurred in 2018/19. These changes include:

  • From 1 December 2018 the law was changed to require AHPRA and National Boards to comply with the Freedom of Information Act 1982 (Cth) that is currently in force. An older version previously applied. This change makes it easier for members of the community to understand the rules that apply about administering applications for information made under the Act. From this date, AHPRA was also required to publish an information disclosure log that makes certain information disclosed under the FOI Act publicly available. The disclosure log can be accessed through the AHPRA website.
  • From 1 June 2019, National Boards and AHPRA are required to participate in the Information Publication Scheme under the FOI Act. The Information Publication Scheme requires that certain information be published on the AHPRA website.

Digital initiatives

Digital House

The Digital House program is an initiative linked to our strategic objectives, delivering the technologies that enable us to regulate effectively and provide improved service and experience for customers and staff. Achievements of the program over the past 12 months have been:

  • the platform enabling paramedics to register online – a completely digital and paper-free process
  • a workflow and queue management tool supporting the new registration operating model
  • an increasing number of application forms being made available online.


Throughout the reporting period we focused on the implementation and enhancement of an Enterprise Resource Planning system through our Pulse program. The Pulse program saw the successful launch of a new payroll system with further enhancements proposed in 2019/20 to better support our corporate processes and integrated people and financial systems.

Information governance and cyber security

AHPRA maintains an active information governance program. The information governance activities include:

  • a continued risk-based approach to managing information-governance outcomes, such as an ability to apply the appropriate level of security to our information assets
  • further enhancements to our ongoing staff awareness campaigns including information about security, privacy, records management and data access
  • focused work around compulsory privacy compliance training for all staff, and
  • continued focus on our information asset ownership work that identifies, classifies and determines appropriate control requirements for information assets.

AHPRA has a well-established information security assurance program, including reviews of our cyber-preparedness and cyber security. These reviews have confirmed continual improvement of our information security and cyber threat programs. We recognise the continuing volatility of the digital environment and maintain a high level of vigilance on cyber threats. Informed by the outcomes of our cyber assurance program, we continue an active and responsive program of work through our annual workplan.

AHPRA manages its activities and risks

Corporate Assurance Framework

AHPRA has an agreed plan that assigns responsibility to each of the four Executive Directors for managing risks on a day-to-day operational level for their directorates. Each directorate has an assurance plan that records the risks relevant to that directorate.

Risks are identified, assessed, monitored and managed at a directorate level, but escalated in accordance with the requirements of the Corporate Assurance Framework and recorded in the Corporate Assurance Plan for review and monitoring by the CEO and the National Executive.

The Corporate Assurance Plan reports the escalated risks and risk ratings, along with the controls and assurances put in place to mitigate the risks. The plan is reviewed by the Finance, Audit and Risk Management Committee (FARMC) to monitor the effective management of risks reported to the Agency Management Committee and the National Boards.

FARMC assures that systems are in place so AHPRA effectively and appropriately manages risk and oversees the operation of those systems. AHPRA’s internal audit function forms part of the review process, provides assurance on the risk management process, and advises the committee accordingly. The internal audit done during the year gave an independent assessment of this to the committee.

Data handling

AHPRA handles significant volumes of sensitive and personal information about registered health practitioners, students and notifiers. We recognise our obligations to protect this information and have established an ongoing program of work to strengthen our current practices in minimising the risk of data loss, to ensure data are collected, held and used in accordance with privacy law and best practice. We held an annual information awareness program that aligns with external activities such as Privacy Week and Cyber Security Awareness Week.

The system of internal control

The CEO is responsible for reviewing the effectiveness of the system of internal control, which has been in place this year and, up to the date of approval of the annual report and accounts, in accordance with guidance from the Victorian Auditor-General’s Office (VAGO). The review is informed by the work of internal auditors and senior AHPRA managers who are responsible for developing and maintaining the internal control framework, and comments made by external auditors in their management letter and other reports. The FARMC has been advised on the outcome of the review. Plans are in place to address identified weaknesses and ensure continuous improvements.

The managers responsible for the system of internal control provided the CEO, through the Executive Director Business Services, with assurance that AHPRA’s system of internal control is subject to consistent monitoring, review and improvement, and that AHPRA’s key risks are being identified, assessed and managed appropriately to ensure the goals and objectives of the National Scheme are achieved.

The latest version of the Corporate Assurance Framework was presented to FARMC in March 2019.

AHPRA’s internal financial and risk management staff, in liaison with the internal auditors, plan and carry out a FARMC-approved work program to review the design and operation of the systems of internal control. When weaknesses have been identified, they are reported to FARMC and an action plan is agreed with management to implement the recommendations as part of this process.

Our risk mitigation strategy includes the appropriate and proportional placement of insurances. Throughout the financial year, our insurance portfolio was up to date and was reviewed and renewed for a further 12-month period on 30 June 2019. The insurance program is overseen by FARMC.

Capacity to handle risk

The Executive Director Business Services has the designated operational responsibility for maintaining and developing the organisation-wide system of internal control. The CEO is the designated executive with operational responsibility for the system of risk management and risk reporting.

The Agency Management Committee takes an active role in risk management, receiving periodic reports and reviewing the Corporate Assurance Framework.

FARMC oversees AHPRA’s governance processes and has reviewed the Corporate Assurance Plan at its meetings, together with movements in the risks identified through that framework and their management.

We are not aware of any significant risk management issues that would prevent AHPRA from delivering the National Scheme’s goals and objectives that have not been identified, assessed and which do not have an appropriate plan. We are satisfied that work is underway that is designed to ensure AHPRA identifies, assesses, monitors and manages risks appropriately.

Page reviewed 15/11/2019