Notations are applied to a practitioner’s registration to explain what their scope of practice is.
Notations are used as a method to communicate with the practitioner and the public the broad fields in which the practitioner may practise. It is not the same as conditions of registration.
For example if a physiotherapist or other health practitioner only uses acupuncture to treat musculoskeletal disorders, a notation may be used to explain what the limitations are – i.e. the notation will say ‘may practise acupuncture only for the treatment of musculoskeletal disorders’.
Notations are not applied to change the practitioner’s existing scope of practice.
A glossary is available that explains commonly used words, including a definition of notations.
The Board has the authority to impose a notation on a practitioner’s registration and to publish this information under section 225 (p) of the National Law.
The information is published so the public has access to clear and up to date information about a practitioner’s current registration status.
The Chinese Medicine Board uses notations to ensure that the public is fully informed about any existing limitations on a registrant’s scope of practice.
Notations are not of the same legal standing as conditions and are not a ground to refuse to renew a practitioner’s registration.
The scope of a practitioner’s practice may be addressed through a notation, but the notion of ‘scope of practice’ does not provide enforceable rules or a clearly delineated scope of practice.
Scope of practice will always require some level of self appraisal. For this reason, it cannot be said all practitioners having registration can provide exactly the same services. The type of registration merely establishes an entitlement to use the protected titles, but each practitioner must self-assess their own scope of practice based on their training, qualifications and experience.
Any practitioner who practises outside their scope of practice may be subject to disciplinary action. This applies to all registrants, including those with or without a notation on their registration for example for poor performance.
The notation is applied based on evidence already provided by the practitioner that indicates they have a limited scope of practice. If this is not accurate, the practitioner can provide the Board with further evidence.
The Board imposes a notation to reflect an existing limit on a practitioner’s scope of practice. There is no formal appeal process.
However, if a practitioner is concerned about the Board imposing a notation, they can apply for a condition to be imposed on their registration instead, which allows them to proceed through a ‘show cause’ process.