As you may have seen in my recent posts (here and here), the CS&HISC recently made a decision to remove the Advanced Diplomas of Naturopathy, Western Herbal Medicine, Nutritional Medicine, and Homoeopathy from the Health Training Package in December 2015. This came after almost 18 months of discussion and consultation, and majority support amongst stakeholders.

Yet the Australian Traditional Medicine Society (ATMS) refuses to accept the majority decision, is actively opposing it and is seeking to have the CS&HISC decision overturned.

On 1 August this year six associations and registers came together to discuss the way forward, and begin the process of collaborating on a unified set of standards for Bachelor degrees in our professions. Those associations were:

• Australian Natural Therapists Association (ANTA)
• Australian Naturopathic Practitioners Association (ANPA)
• Australian Traditional Medicine Society (ATMS)
• Australian Register of Homoeopaths (AROH)
• Complementary Medicine Association (CMA)
• National Herbalists Association of Australia (NHAA)

Five of those six associations agreed fully with the decision to move to Bachelor degree as the new minimum educational standard, and agreed to work collaboratively on standards for Bachelor level courses. I was a part of this meeting, and it was great to see the broad agreement and desire to work together on this issue.

But guess who didn’t agree. You would be correct if you guessed ATMS.

On 30 August ATMS made another submission to the CS&HISC opposing the decision, and on 4 September issued a press release as well. In the interests of transparency, I am attaching ATMS’s submission below (which is in the public domain as it was sent to the group of 6 associations).

The fact of the matter is that no other health profession in this country, which expects its practitioners to work autonomously and without supervision, and who make decisions around patient assessment and administers ingestive medicines, has anything less than Bachelor degree as the entry standard. Why does ATMS think we should have a lower standard than everybody else?

Below I will demonstrate, with a discussion of quotes from their submission, why in my opinion ATMS does not represent the best interests of the profession (indeed they don’t even call it a profession, but continue to call it an “industry”), or the public who choose our health services.

Detailed Critique of ATMS’s Submission to the CS&HISC, 30 August 2014

“ATMS unequivocally confirms its support for the current two tiered qualification framework for Homeopathy, Naturopathy, Nutritional Medicine and Western Herbal Medicine. ATMS proposes that the advanced diploma qualification (AQF6) should remain as the entry level” (page 1, paragraph 3)

I believe my introduction above addressed this point. No other health profession with similar responsibilities has anything less than Bachelor degree as the entry standard.

“The advanced diplomas are work/employment ready qualifications; they do not require research units.” (page 1, paragraph 6)

So practitioners of naturopathy, herbal medicine, nutritional medicine, and homoeopathy don’t need to know how to read, interprete, and apply research findings in practice? What does ATMS think this is, the 19th century?

“ATMS is of the opinion that there are clearly two very different educational level; being the AQF6 advanced diploma level with outcomes at the practitioner level, retail support and advice roles in health food shops and pharmaciesand the AQF7 degree; which is targeted for ongoing research or business development within manufacturing. ATMS’s position is that the AQF6 advanced diplomas should remain in place and be reviewed to ensure it reflects the necessary outcomes for our industry’s requirements.” (page 2, paragraph 2)

So ATMS is equating naturopathic, herbal, nutritional and homoeopathic clinicians, with retail assistants in health food stores. Wow, no wonder the public and other health professions often have an inaccurate view of what we do – one of our own “professional” associations doesn’t even understand!

Secondly, they again refer to us as “industry”. As I have covered previously, we are members of a health care profession, not an industry. And this is exactly why we need Bachelor degree as the standard for the future. Vocational education (AQF Level 1–6) supports industry very well, but it doesn’t – under its own descriptors in the AQF – cater to producing professionals.

“ATMS strongly believes that there is a need to retain the AQF6 qualifications as many other industries have entry level VET sector qualifications that allow for the underpinning knowledge that lead to pathways in higher education at AQF7. Examples of this are nursing, engineering, marketing and business administration to name but a few. One of the most essential aspects that support these qualifications remaining in the VET sector is the existence of current pathways to degrees” (page 2, paragraph 3)

Engineering, marketing and business administration are not health care professions. Nursing is the only one mentioned by ATMS which is health care. And the Advanced Diploma of Nursing allows graduates to be enrolled nurses, not registered nurses. According to the Australian Nursing & Midwifery Federation: “Enrolled nurses work under the direction and supervision of registered nurses. That supervision may be direct or indirect according to the nature of the work delegated. The registered nurse is responsible for delegating appropriately to the enrolled nurse within the framework of the enrolled nurses’ knowledge, skill, education and experience and the context of the nursing care to be provided.”

How is that comparable to the unsupervised, undelegated work conducted by practitioners within our profession?

“Unlike other medical and paramedical professions, there are no readily available job opportunities for natural medicine practitioners. Many create their own opportunities and become self-employed practitioners. Under such circumstances, making the degree the only qualification achievable adds considerable financial burden and time commitment which could potentially discourage students enrolling in future training and result in a further shortage of the practitioners.” (page 2, paragraph 5)

This is in actual fact an argument for Bachelor degrees. Ignoring the fact that there are few job opportunities exactly because our minimum standard of education is below that of every other health profession, the AQF very clearly states that Advanced Diplomas train para-professionals, and Bachelor degrees train professionals. Para-professionals are meant to work in a supervised or delegate capacity, but as ATMS states, many of us are self-employed and certainly not supervised. Hence ATMS is arguing against itself with this statement.

“Potentially numerous long standing practitioners may be forced into upgrading their qualifications to retain their professional status, a decision not taken likely as we estimate that the cost to upgrade their industry qualification could be approximately $40,000-$55,000. This could perhaps be even more if educational institutions do not recognise their prior learning and/or clinical experience, a problem already manifesting itself at this current time.” (page 2, paragraph 7)

Many of the associations supporting the move to Bachelor degrees have made specific statements that this does not mean they will refuse entry for Advanced Diploma graduates. Obviously a period of transition is needed, and those who are already members or already enrolled in Advanced Diplomas should not be unfairly disadvantaged. So for the forseeable future, none of these professional associations are forcing existing practitioners to upgrade.

Yet many people are interested in doing just that, and some with years of experience but no Bachelor degree, are being recognised for that experience and enrolling in post-graduate programs. I trained long before Advanced Diplomas existed in our profession (they were Diplomas back then, and there were no Bachelor upgrade pathways, no VET FEE HELP), and after 10 years of practice I bypassed Bachelor degree and went straight to Masters degree. As have a number of my colleagues.

And where are ATMS getting their grossly exaggerated figures from? This is close to the cost of some currently available degree programs, from start to finish (ie. 3–4 years of study), and not upgrade pathways which typically take around 1 year.

“A further concern is that of the number of individuals suitably qualified to teach at an AQF7 level and the number of educational institutions available to offer programs at this level. As stated the industry is in decline and the removal of a qualification level that is not only suitable, affordable and accessible needs to be maintained and the need for it remain at the forefront of the industries re building strategies. The ability to satisfy the demand for enrolments across all modalities into the future at an affordable price is a further concern for ATMS”. (page 2, paragraph 8)

Whilst I won’t argue that it would be good for the profession to have more practitioners and lecturers qualified at a Masters degree level or higher, the argument that you cannot teach at Bachelor level if you don’t have a higher qualification is not strictly true. According to the Higher Education Standards Framework item 4.2: “The higher education provider ensures that staff who teach students in the course of study: are appropriately qualified in the relevant discipline for their level of teaching (qualified to at least one AQF qualification level higher than the course of study being taught or with equivalent professional experience)” (note: emphasis mine).

Why is the “industry” in decline? They mention on page 1 declining membership levels which “we believe would be seen across the majority of associations”. Yet according to their own annual reports, the total number of members of ATMS has increased every year between 2008–2012, and again in 2014 compared to 2012.

“ATMS is a significant voice. As the largest professional association representing Complementary and Alternative Health, ATMS is a major, legitimate stakeholder in the CS&HISC review. As such we strongly believe that we have a right to participate in this important review” (page 3, paragraph 2)

Nobody is saying ATMS is not a significant voice and a legitimate stakeholder. But what they need to realise is that they are only one of many stakeholders, and on this issue they have clearly been outvoted. They cannot dictate the terms when 5 other equally legitimate associations have the opposite opinion, along with a number of other relevant stakeholders. Welcome to democracy (something which ATMS obviously still finds difficult to understand).

“It is expected that AQF6 graduates will have broad knowledge and skills for para-professional/highly skilled work and/or further learning; whereas an AQF7 graduate will have broad and coherent knowledge and skills for professional work and/or further learning. The key difference is the term para-professionals as the definition states in the oxford dictionary for para-professional – ‘a person to whom a particular aspect of a professional task is delegated but who is not licensed to practice as a fully qualified professional’. Existing complementary medicine practitioners are not licensed so there is no issue with being classified a para-professional” (page 4, paragraph 2)

Wow, what a weird circular argument. So basically we are not professionals because we are not licensed, therefore there is no problem with being refered to, and trained only to a standard representing, para-professionals. So if we are para-professionals, exactly who supervises us and delegates tasks to us? Bizarre.

The table on page 4 shows existing enrolments for Advanced Diplomas in Naturopathy (80), Western Herbal Medicine (23), and Nutritional Medicine (63). I’m not even sure why they are even presenting these numbers, nor where they are getting them from. If they think that these are Australia wide figures, then clearly they haven’t researched their numbers – I teach at one institution which has at least three times those numbers of students.

“The question for our industry is at what level of quality should our future practitioners to be at, and how will this be achieved. ATMS believes this is where the work of the SMEG needs to focus, to separate the two and ensure that the quality of the practitioner is maintained or improved where necessary. The simple inclusion of research and/or elective units at the degree level will not improve the standard or change significantly the natural medicine knowledge of a practitioner in our opinion. Industry needs to determine the content for the courses and ensure the content is relevant and representative of what the natural medicine industry requires” (page 4, paragraph 5)

The work of the SMEG’s (Subject Matter Expert Groups) is exactly what led to the consultation process and subsequent decision to discontinue the Advanced Diplomas. I am a member of the SMEG for Naturopathy & Western Herbal Medicine, and the discussions we had around improvements that need to be made to the Advanced Diplomas took us further and further away from the definition and course duration (1.5–2 years) of Advanced Diplomas as outlined in the AQF, and far more into the realm of AQF 7 (Bachelor degree).

The issue wasn’t about adding more research units, it was mostly about improving clinical reasoning skills, patient assessment capability, and clinical training. In fact I remember specifically discussing alterations to the existing unit of competency in the Advanced Diploma of Naturopathy (HLTNUT601C Apply literature research findings to clinical practice) which discusses research to make it clear that the outcome wasn’t to train researchers, but to train clinicians who can interpret and apply research information.

And again with they refer to “industry”. They clearly do not understand the difference, or alternatively don’t value themselves or their members enough to think of, and refer to them as professionals.

At the end of page 4 and page 5 of their submission, ATMS discusses how the cost of degree level education would be prohibitive, and how the …

“full advanced diploma of Naturopathy costs (full price including all text books and enrolment fees) is currently approximately $23,000–35,000”

Not sure where they are getting their figures from, but just at one institution at which I teach (Australasian College of Natural Therapies) the cost of the 3 year full time Advanced Diploma of Naturopathy is $45,000 and that does not include textbooks.

The figures they quote might be consistent with a 1.5–2 year duration Advanced Diploma, but who seriously believes you can adequately train a Naturopath in 1.5–2 years full time? When I did my Diploma of Naturopathy 25 years ago it was 4 years full time, and that was a Diploma, not an Advanced Diploma!

Update: January 2023. Due to the obstacles created when moving web hosts, comments on old posts were not able to be directly transferred. Therefore I have attached a PDF of the comments on this post from the old site for your interest.