Today’s correspondent says:
I reference your previous article [‘Specialist’ paramedics (May 25, 2024)] https://australianemergencylaw.com/2024/05/25/specialist-paramedics. The [Australasian] college [of Paramedicine] [the ACP] has subsequently released the clinical practice framework: https://paramedics.org/news/australasian-clinical-practice-framework-paramedicine-v1-launch.
I would be keen to hear your thoughts on the release of this framework and impact of the use of titles, as it appears the college is trying to push the profession towards recognised / aligned title use.
You can ‘Download the Australasian Clinical Practice Framework for Paramedicine here’. The Framework says (at p. 4) that it:
… is designed to be used as a guide for:
• paramedics in pursuit of building capability and career progression
• clinical practice employers designing and/or enhancing the skills-mix within clinical teams e.g. multidisciplinary teams
• educational providers in the development of clinical courses
• governments, services and organisations in the design of policy and legislation, strategic development, and workforce planning.
It goes onto say (also on p. 4):
The Framework can be used to guide and plan:
• the development of role titles and descriptions … [and]
• the development of … policy and legislation…
The Framework anticipates four levels of clinician:
- Paramedic;
- Paramedic – specialist;
- Paramedic – advanced; and
- Paramedic – consultant.
The issue in my earlier post, on ‘specialist titles’ was the fact that the Health Practitioner National Law limits the use of a title that would imply a person is a registered specialist, in particular s 118(1)(a) says
A person who is not a specialist health practitioner must not knowingly or recklessly–
(a) take or use the title of “specialist health practitioner”, whether with or without any other words;
I don’t think there is a significant difference between ‘specialist paramedic’ and ‘paramedic specialist’ in which case this section would seem to apply to the title ‘Paramedic – specialist’. As I noted in that earlier post the issue is probably not critical in internal documents such as an award or this Framework where the intended audience will understand the terms. It is an issue if it might mislead consumers which may be patients but will also be people looking to hire or contract with paramedics who may not understand the use of the term and may think a person described as a ‘specialist’ is endorsed by the Paramedicine Board via their registration – and they are not.
Do I think it is an issue in this Framework document? No, I do not. First the ACP do not write the law, and the document has to be applied in the context of the law. The Framework, written for both Australia and New Zealand is to be ‘Framework be applied alongside local policies and legislation, regulations, and standards’ (p. 6). It does not invite or authorise ambulance services or other paramedic employers to just start using the titles, but it may, as it suggests, be a guide to help persuade the Australian Health Ministers to allow the Board to recognise those titles (Health Practitioner Regulation National Law s 13). As a document to start the relevant discussion and to give a profession perspective that can be used to argue for any necessary reform, it’s fine.
Further the use of terms to identify clinical standing is not the same as an implication of specialist registration. Medical practitioners may be interns, residents, consultants etc. These titles indicate something about their level of experience and standing in the profession, not about their status as registered specialists. Equally the terms ‘Paramedic’, ‘Paramedic – advanced’ and ‘Paramedic – consultant’ would not, in my view, give rise to any implication that the person is registered as a ‘specialist’. There is an argument that the term ‘Paramedic – Specialist’ needs to be ‘tweaked’.
As for the view that ‘the college is trying to push the profession towards recognised / aligned title use’ I’m sure that’s right though one might disagree with the term ‘push’ and prefer instead ‘lead’. But yes, I would agree that the College is trying to create profession wide use of recognised titles as that will allow everyone to better understand who they are dealing with. Paramedics who want to move from one service to another will be better served if everyone understands what they mean when they write on their CV that they are a ‘paramedic – specialist’ if that term is understood across the profession. As it is what one service calls an Intensive Care Paramedic may mean something else in another service. In my book Emergency Law (Federation Press, 4th ed, 2013, p. 39), quoting Lewis Caroll’s Alice’s Adventures in Wonderland, I said:
Humpty Dumpty said “When I use a word … it means just what I choose it to mean- neither more nor less” and in the absence of professional registration, the term “paramedic” means whatever the person using it wants it to mean.
Now there is professional registration the term ‘paramedic’ as a very clear, defined meaning. Other terms used in the profession still mean whatever the person, organisation or state using the term ‘choose it to mean’. The Framework appears to be an effort by the College, on behalf of the profession, to take the initiative and give meaning to terms so that they can be used consistently across Australasia and to lead rather than follow the policy makers to advance the profession. That ability, of the profession to take the lead in its own development, was always one of the arguments in favour of professional registration.
Conclusion
So what are my ‘thoughts on the release of this framework and impact of the use of titles’? It appears to me to be the College taking the lead in developing the profession. Whether you want to describe that as ‘trying to push the profession’ or ‘leading the profession’ depends I suppose on your view of the status of the College. I disclose here of course that the College used to sponsor this blog (see This blog is no longer sponsored (September 17, 2025)). I was on the board of Paramedics Australasia at the time it came together with the Australia and New Zealand College of Paramedicine to form the current college. I have continued to contribute to the work of the College when asked. I am an Honorary Fellow of the college even though I am not, and have never been, a paramedic (though I was an ambulance officer when the term ‘paramedic’ was restricted to level V intensive care officers). I was not involved in the development of this Framework. One might infer, therefore, that I am a supporter of the College though I do not let that try and influence my analysis of the law (see The blog and the role of sponsors (March 30, 2022).
If my correspondent’s phrase that the College is ‘trying to push the profession’ is a pejorative description, then I would prefer to say the College is leading the profession (Framework p. 5):
… to ensure paramedics deliver best-practice, person-centred care, adapt to evolving circumstances, innovate in complex situations, and continually enhance their professional performance.
And:
The Framework aims to positively impact the healthcare sector by establishing consistently recognised levels across the paramedic profession and the broader health system. Developed in alignment with existing frameworks, systems, and terminology, it also serves as an interprofessional integration and education tool to enhance health literacy.
My only concern is that the use of the term ‘Paramedic – specialist’ my run foul of the Australian Health Practitioner Regulation National Law.
This blog is a general discussion of legal principles only. It is not legal advice. Do not rely on the information here to make decisions regarding your legal position or to make decisions that affect your legal rights or responsibilities. For advice on your particular circumstances always consult an admitted legal practitioner in your state or territory.
Australian Emergency Law 