Today, 1 December 2018, is the commencement day for paramedic registration. From today if you have not applied for registration you cannot continue to call yourself a ‘paramedic’. But the registration process takes time. Today’s correspondent asks about a letter from the Paramedicine Board (at this point I note I haven’t seen the letter, I’ve been given what I’m told is the wording of the letter, not an actual scanned copy). I’m told the letter says:
Thank you for lodging your application for registration with the Paramedicine Board of Australia (the Board). Your application is currently under review.
Under section 85 of the Health Practitioner Regulation National Law, as in force in each State and Territory (the National Law), if a Board or its delegate has not made a decision about your application by December 8, 2018, your application will automatically be refused unless an extension of this date is agreed upon.
Given that your application is still under assessment, we propose to extend this date until March 8, 2019.
If you agree to this extension please advise us in writing via return email by December 4, 2018.
My correspondent’s questions are:
- How long does ‘the board’ have to make a decision?
- Is the practitioner effectively registered until a decision is made?
- Is Dec 8 an arbitrary date chosen by ‘the Board’ or is this something written into the ‘Health Practitioner Law’ etc.
- When are we likely to see the board define what a Paramedic is and does, as I feel this will likely greatly effect registration applications of the future, and potentially open avenues for re-application?
Section 85 of the Health Practitioner Regulation National Law says:
If a National Board fails to decide an application for registration within 90 days after its receipt, or the longer period agreed between the Board and the applicant, the failure by the Board to make a decision is taken to be a decision to refuse to register the applicant.
It follows that the answer to question 1 is ’90 days or such longer period as is agreed’. It also means that the answer to question 3 is that December 8 is not an arbitrary date chosen by the Board, it is presumably the date that is 90 days after this particular application was submitted.
The answer to question 2 is that an applicant for registration as a paramedic is ‘effectively registered’ provided they submitted their application before today, 1 December (Health Practitioner Regulation National Law, s 315). The Paramedicine Board says (https://www.paramedicineboard.gov.au/Registration/After-youve-applied.aspx):
If you have applied for registration before participation day on 1 December 2018 (the day paramedicine regulation starts), you can continue to practise as a paramedic while your application is being assessed, which may occur after participation day.
If you apply for registration after participation day, you will be unable to practice as a paramedic until your application is assessed and decided.
The answer to question 4 is that the Paramedicine Board is unlikely to define what paramedics do. The Health Practitioner Regulation National Law does not seek to define scope of practice and neither do other Boards. The Paramedicine Board has however published Professional capabilities for registered paramedics (29 June 2018). As for who a paramedic ‘is’ I think we know that – a paramedic is a person with an approved or a substantially equivalent qualification or an accepted qualification issued by NSW Ambulance; or a person who meets the requirements under the grandparenting provisions.
Australian Emergency Law 
I sent my application in several months ago under the grandfathering provision. I was a Paramedic with Ambulance Victoria for 34 years including 23 years Mobile Intensive Care
The website only allows a certain no of documents to upload. Proof of qualifications sent including Police Check
I was emailed by APRHA to
provide proof of service from AV. Had to wait a month for AV to provide that. Then email from APRHA saying yhat since I was no
longer working for AV ( left in 2016) I didn’t need the AV Statement of Service. I had told them in the original application that after leaving AV I continued as a Paramedic with a private company and also as Australian Clinical Manager from 2016 to the present time (36 years continuous service)
Received email from APRHA asking for letter from current employer (which I had supplied previously). Eventually they acknowledged receipt of that. Now asking for CV which is not asked for on website nor could be provided due to document upload limitations
CV sent. Plus all necessary certificates plus Police Check plus AV and current employer Statements of Service. I am arguably one of the most experienced and continuously employed Paramedic in Australia and months down the track still waiting for registration
APRHA get your act together!
Aside from the issues of ‘registration ‘ ….
A PARAMEDIC does not practice PARAMEDICINE.
They are two separate activities.
We know about paramedics, but who practices ‘paramedicine’ ?
I would say, this is the activity of what is also termed ‘alternative’ or ‘complimentary’ therapies. Eg. Aroma therapy; Nauropathy; and those who use various botanicals as alternative medicines.
Gordon, in your opinion, what do paramedics practice if not paramedicine?
Paramedics are essentially advanced first aiders.
Sure, there’s certain drugs involved, but these are administered in a ‘life-saving’ context as a once off …. and not in an ongong treatment context, like a health professional who maintains a ‘client base’.
Thus, the paramedic is in the professon of saving life …. a paramedicine practioner enhances the quality of that ‘saved life’ some time down the track.
Comments on this blog are moderated, that means they only appear with my approval. In the interests of freedom of speech, I am slow to refuse to allow comments to appear. I approved the previous comment, by Gordon Blair, with some concern that it may be unnecessarily inflammatory and I remind people who may be tempted to respond, of the Appropriate tone for comments on this blog.
To describe paramedics as ‘essentially advanced first aiders’ is both unnecessary and unhelpful. Health care is delivered on a continuum, from people who care for their children and loved ones (providing both first aid and nursing) to people who have done a first aid certificate and are willing to help out if something happens in their presence, to volunteer first aiders as well as volunteers in other community health settings and health institutions, then paid providers- assistants in nursing, enrolled nurses, registered nurses, paramedics, medical practitioners and members of the other registered health professions. Health practitioners of all sorts have different practices providing different levels of care.
To describe paramedics as ‘essentially advanced first aiders’ is akin to describing nurses as ‘advanced assistants in nursing’ and physiotherapists as ‘advanced personal trainers’. All are providing care along a continuum so of course the professional is providing care that is similar to, but more advanced, than others who work at the other end of the continuum.
The claim that ‘the paramedic is in the profession of saving life …. a paramedicine practitioner enhances the quality of that ‘saved life’ some time down the track’ is simply making up a definition for one’s own purposes (whatever those purposes are). Governments have been persuaded that paramedics should be registered because they practice in a high risk (to patients) environment and perform complex and high-risk interventions. Another ground for registration is the recognition that the work of paramedics has developed to a stage where paramedics are not merely akin to medics (ie para-medics) any more than nurses are still ‘the physicians handmaid’. Not only do paramedics have their own skill set and unique practice, the developing profession is creating its own knowledge about that practice – hence the move of paramedicine into universities. Just last night (3 December 2018) I had the opportunity to attend a Paramedic CPD event where a paramedic spoke on his Churchill Fellowship and his contribution to the development of paramedic knowledge and practice.
From this week paramedics are registered by the Paramedicine Board of Australia. Whilst it may have been possible, before 1 December 2018, for any number of people to claim they practiced paramedicine and were paramedics, from 1 December that is no longer the case. Today paramedicine is what registered paramedics practice, just as nurses practice nursing and medical practitioners practice medicine even though many people can ‘nurse’ a patient or provide medical care.
To return to the claim ‘the paramedic is in the profession of saving life …. a paramedicine practitioner enhances the quality of that ‘saved life’ some time down the track’ that makes no sense. Doctors and nurses in the emergency department may act to save a person’s life and that person is then transferred to the ward for further care. Those doctors and nurses have no more involvement with the patient ‘down the track’ than the paramedic but they are still practising medicine and nursing.
The claim also fails to recognise that not all paramedic practice is lights and sirens and emergencies. There is increasing scope of paramedic practice (and that is likely to progress further with registration) so there are community care and extended care paramedics, paramedics who provide community care in regional and remote areas and paramedics who provide all manner of health services in the private sector – whether that’s in event health services or industrial paramedics in remote or offshore industries. They are all practising paramedicine.
There are overlaps across all the health professionals and the limits of the scope of the professions are not set and will not be set. As knowledge and technology changes so to what doctors, nurses and paramedics do will change. We will never therefore get a list that says ‘this is paramedicine’ and ‘this is nursing’ etc. Paramedicine is the area of practice regulated by the Paramedicine Board. Whatever the case may have been on 31 November 2018, from 1 December 2018 a paramedic practices paramedicine.