Ahpra registration renewal – what you need to know
Avant media
Tuesday, 21 September 2021
Doctors can find it unclear what information they are required to provide when renewing their Ahpra registration. To help you complete your registration renewal form, here are some tips on how to respond to some of the common sections.
Impairment
“Do you have an impairment that detrimentally affects, or is likely to detrimentally affect, your capacity to practise the profession?”
The National Law defines “impairment” as: “a physical or mental impairment, disability, condition or disorder (including substance abuse or dependence) that detrimentally affects or is likely to detrimentally affect… the person’s capacity to practise the profession”.
Ahpra confirms that this does not apply to a condition that is safely managed through treatment, aids or equipment.
If you have a permanent condition which potentially affects your “…. capacity to practise the profession” because, for example, you have to avoid certain tasks or situations, it is prudent to disclose this condition in your registration renewal. You may wish to note that it has not caused any issues with your clinical practice and attach information from your treating practitioner if appropriate.
If you are unsure about whether disclosure is required, you may wish to discuss this first with your treating practitioner for the relevant condition.
Criminal history
There are two questions about criminal history:
- “Since your last declaration to Ahpra, has there been any change to your criminal history in Australia that you have not disclosed to Ahpra?”
- “Since your last declaration to Ahpra, has there been any change to your criminal history in one or more countries other than Australia that you have not disclosed to Ahpra?”
It is an ongoing registration requirement under the National Law that relevant events must be notified to Ahpra within seven days of occurring. The events for criminal history include:
- any charge relating to an offence punishable by 12 months imprisonment or more, and
- any conviction or finding of guilt for an offence punishable by imprisonment.
If an event such as this occurred during the year, and you notified it to Ahpra within seven days, you do not need to disclose this again on your registration renewal form.
Separate from this, as part of your renewal, you must disclose anything included in the definition of criminal history that you have not previously notified to Ahpra.
There are some differences between states and territories as to what constitutes a criminal offence in those jurisdictions. The definition of criminal history and the explanatory notes provide a guide as to the matters to be disclosed. These include:
- convictions for an offence
- a plea of guilty or finding of guilt by a court, whether or not a conviction is recorded for the offence
- if you are charged with an offence
- spent convictions as spent convictions legislation does not apply to criminal history disclosure requirements
- convictions for unpaid parking fines, only in Western Australia
- offences where you have pleaded guilty and the outcome was guilty without conviction, only in Queensland
- speeding or parking fines, only in Tasmania.
If you are making a disclosure in response to this question, it is advisable to first review the Medical Board of Australia’s criminal history registration standard.
If you answer yes, you will then be able to include information in the text box about the nature of the charge or conviction and note that you are supplying any additional documents.
Complaints
“Have you previously disclosed to Ahpra all known complaints made about you to a registration authority or another entity having functions relating to professional services provided by health practitioners or the regulation of health practitioners (in Australia or elsewhere)?”
This year’s explanatory notes confirm that you do not need to include complaints to Ahpra or an Australian Health Complaints entity. This also means that you do not need to include complaints in NSW to the Medical Council or the Health Care Complaints Commission, and for doctors in Queensland, any complaints to the Office of the Health Ombudsman.
It is also explained that the wording “another entity having functions relating to professional services provided by health practitioners” includes any complaints made to “an entity with responsibility for regulating medicines, drugs or poisons in a State or Territory of Australia, or an overseas regulatory body”. This includes the state or territory Pharmaceutical Regulatory Units and the Therapeutic Goods Administration, and any equivalent overseas bodies.
We have previously clarified with Ahpra that employment and other complaints that have been raised internally within the hospital or practice where you work do not need to be disclosed.
Exposure prone procedures
“Do you perform exposure prone procedures in your practice?”
This question and the related disclosures have been included since last year, after new national guidelines came into effect across Australia.
For information about these changes and how exposure prone procedures are defined, read our article.
Examples of exposure prone procedures include cardiothoracic surgery, gynaecological surgery, and neurosurgery. Some examples of non-exposure prone procedures are the insertion and maintenance of intravenous or central lines, minor suturing of uncomplicated skin lacerations and an incision of superficial abscesses.
If you answer ‘yes’ to the first question, then you need to indicate whether or not you have complied with the National Guidelines for the Management of Healthcare Workers Living with Blood Borne Viruses Who Perform Exposure Prone Procedures at Risk of Exposure to Blood Borne Viruses during the previous period of registration. You must also indicate whether you agree to comply with those guidelines going forward. This includes testing for HIV, Hepatitis C and Hepatitis B at least once every three years.
When answering all sections, take your time choosing between ‘yes’ and ‘no,’ and the ‘N/A’ option for some questions, to ensure your answers are accurate. This will enable your application to be assessed as quickly as possible.
Useful resources
If you require medico-legal advice on any of these issues, you can contact us via email at nca@avant.org.au or if you require immediate advice, call 1800 128 268. We are available 24/7, after hours and on weekends in emergencies.