Welcome to the October 2018 newsletter of the Chinese Medicine Board of Australia (the Board), also available to read in Chinese (853 KB,PDF).
In this issue we bring you feedback from the practitioner forums, a call for applications for the Chinese Medicine Reference Group, and an important report contributing to risk-based Chinese medicine regulation in Australia. We also draw your attention to preventing burns and the extreme importance of adequate patient healthcare records.
In other news, I was inspired earlier this year by a speech by the CEO of the Congress of Aboriginal and Torres Strait Islander Nurses and Midwives, Janine Mohamed, sharing her vision on integrating cultural safety into regulated health services ̶ including Chinese medicine. I encourage you to read her speech below.
Last, you will soon be able to renew your registration and we remind everyone that you are required to attest to full compliance with the standards for professional indemnity insurance, continuing professional development and recency of practice. Giving accurate information at renewal is essential, and if you are unsure if you are meeting your regulatory obligations you need to talk to us about getting back on track as soon as possible. Every year a portion of the profession is audited to see if they are compliant with the standards, so please read and answer the questions on your renewal application carefully.
Professor Charlie Xue
Chair, Chinese Medicine Board of Australia
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Without good quality patient records, it is not possible to provide optimum care and continuity of care for a patient. Good quality patient records must be chronological, accurate, clear and legible. They need to include healthcare information about the the patient’s previous and presenting health, their various examination/s, diagnoses, medications prescribed and details of ongoing care including the patient’s response to treatment. These records should be adequate to allow another practitioner to continue the patient’s care.
Patient health records are regarded as a legal document and form an important part of a practitioner’s ethical and regulatory responsibilities. The Board has published several documents to help you to better understand what constitutes a good quality patient record. You should consult the following documents available on the Board’s website:
While there does not need to be a standard format for a patient record, the Board is considering developing a checklist of the necessary components of a record to provide you with further help.
Poor quality patient records have been apparent in a number of complaints/notifications and the Board and the Chinese Medicine Council of NSW have dealt with a number of examples.
The following are three actual case studies:
A patient presented with a musculoskeletal problem (back pain) seeking acupuncture treatment. The practitioner did not take the patient’s medical history, and in this instance the patient happened to suffer from various respiratory conditions and had hyperinflated lungs, increasing the potential for a pneumothorax. The inevitable occurred. The few minutes invested in taking a proper patient health record would have allowed the practitioner to consider this patient’s condition and to offer optimum patient care.
A practitioner subject to a complaint stated that they have a very busy practice and admitted that they often ‘did not have the time’ to record all the dispensed herbs given to various patients throughout the day. This person said they often left this task of recording until the end of the day, thus relying on memory. How can this practitioner demonstrate that their records are accurate? If a patient was to have an adverse event and there was an emergency situation, how could the patient be appropriately managed? How does this save time anyway?
A complaint was lodged by a patient that their practitioner had performed a treatment which they had not requested or agreed to. In response, the practitioner stated that they did discuss the treatment and had received informed consent from the patient. However the practitioner had failed to record this in the patient’s health record. Noting this in the record would have greatly assisted in the handling of this complaint.
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The Board has recently dealt with notifications (complaints) related to burns to patients caused by the use of infra-red heat lamps and/or the use of moxibustion. In some cases there were serious burns and the Board wishes to raise your awareness of the importance of strict adherence to safety precautions, the contraindications for use of these lamps and careful management should anything untoward occur.
Infra-red heat lamps use low amounts of energy but are able to heat quickly and any application of heat has the potential to burn. Ensure that such equipment is used in accordance with the manufacturer’s instructions.
Moxibustion is another method of administering heat to certain points or areas of the body surface. The various methods of application offer unique benefits, however many direct methods are not acceptable or tolerated due to pain, blistering and scarring.
As a trained expert, you will first carry out a preliminary assessment to decide whether moxibustion is a suitable treatment. You will also fully inform the patient of the risks involved, the actions you will take to mitigate those risks, and seek informed consent.
Apart from the basic preventive cautions outlined above, your best source of feedback is the patient. Make sure you encourage them to let you know of any discomfort, and remain close by to observe and monitor the patient.
If a burn occurs it needs to be properly evaluated and first aid applied in a timely manner. An open and honest discussion needs to take place between you and the patient and referral to medical services should be sought if there is a superficial burn larger than a 20 cent piece or if there is any uncertainty about the severity of an injury.
The Board has completed its 2017/18 round of practitioner forums, with forums held in Melbourne, Sydney, Brisbane, Adelaide and Perth together with a teleconference for rural and remote practitioners and a meeting in Cairns. Three hundred and nine practitioners and students attended the events and 70 per cent of attendees completed a survey at the conclusion of the forums which gave very useful insight into the issues most concerning the profession. Eighty-four per cent of people who completed the survey indicated their overall satisfaction with the events. See the table below.
NRAS: the National Registration and Accreditation Scheme (the National Scheme).
The main issues raised were:
Funding of services by Medicare or private health insurers. The recognition and financing of professional health services by the government or private sectors is outside the legislated responsibilities of the Board. It is a matter for practitioners or their professional associations to handle.
Advertising of regulated health services. The Board knows that this has been a challenging area for practitioners. We have issued a Position statement and AHPRA has provided a range of information to help practitioners ensure that any promotion of their services complies with the National Law requirements. The approach used by AHPRA is to first of all advise a practitioner of any breaches and provide an opportunity for the advertising to be corrected. Prosecution is only considered when a practitioner refuses to comply with the Board’s request in a timely and effective manner.
Access to continuing professional development (CPD) for practitioners in remote areas. Although the electronic provision of CPD is increasing, physical isolation of practitioners is a barrier in many cases. While the provision of CPD itself is not a role of the Board, we are keen that all practitioners have the opportunity to learn about issues related to the regulation of the profession. The Board organised a teleconference for rural and remote practitioners in late 2017 and our Executive Officer held a meeting with practitioners in Cairns. We will continue to provide these opportunities in a cost-effective way as the need arises.
Access to currently restricted herbs. We have received a profession-wide submission in support of the Board seeking the power to endorse suitably trained Chinese medicine practitioners to use specific scheduled herbs and we are currently scoping a project. We will then use this information to decide if and how the project might proceed.
Level of registration fees. The small size of the Chinese medicine profession (around 0.7 per cent of all registered practitioners under the National Scheme) does not provide the economies of scale available to the very large health professions for the Board to be able to set the lowest fees. However, we have kept the registration fees constant for the last two years and are considering ways to further reduce the costs to practitioners in 2018/19.
Experience with the Chinese herbal medicine guidelines. There was general acknowledgment of the value of the guidelines. Some matters raised were an interest in software to support prescribing and dispensing of herbs, ensuring the quality of commercially supplied raw herbs and practical issues about including the quantity of ingredients on the label.
From the discussions at the forums, it is evident that the profession now seems to have a good understanding of the basis and purpose of the National Scheme.
In future forums, rather than providing a broad overview, the Board may go into greater depth on selected topics of interest to the profession.
We will also consider how more students can be informed and encouraged to attend the forums.
Other suggestions about what you would like us to include in the forums are welcome.
1The Health Practitioner Regulation National Law, as in force in each state and territory.
The National Scheme regulates more than 700,000 registered health practitioners and over 150,000 registered students across 15 health professions. It also accredits over 740 approved programs of study delivered by more than 330 education providers.
The Board is calling for applications from registered Chinese medicine practitioners for appointment to the Chinese Medicine Reference Group (the Reference Group).
Appointments are for two years and are expected to start in November 2018. The Reference Group normally includes four registered practitioner members.
The purpose of the Reference Group is to engage stakeholders in order to achieve a common understanding of the National Scheme and to assist the Board in its core business.
The Reference Group will:
The Board is seeking applications from registered practitioners who meet the following selection criteria:
The Reference Group meets once a year face-to-face (usually in Melbourne) with additional meetings held by teleconference as required. Members are expected to read any papers circulated in advance, to actively contribute to discussions and to occasionally contribute to a presentation on or facilitated discussion of a topic of interest.
The National Scheme has a commitment to increasing Aboriginal and Torres Strait Islander Peoples’ leadership and voices. Aboriginal and Torres Strait Islander people are strongly encouraged to apply, as are people from rural or regional areas in Australia.
More information about the roles, eligibility requirements and the application process can be found in the Terms of reference on the Board’s website and the Information guide on the application page: see the link on AHPRA’s committee member recruitment page. The closing date for applications is 31 October 2018.
As a full-time Chinese medicine practitioner, working in private practice, having the opportunity to participate as a member of the Chinese Medicine Reference Group was invaluable. It gave me a lot of insight into the functions and importance of the Board. I also found presentations and updates from the professional associations, the education institutions, the AHPRA Community Reference Group, government departments such as the Therapeutic Goods Administration (TGA) and fellow members to be very informative.
Being part of the group enabled me to participate in discussions in an objective and non-biased way and trust that as a practitioner I had contributed in some way by providing helpful information and practitioner perspective on the issues discussed.
I have found participating in the Chinese Medicine Reference Group to be a very valuable experience. Its role is to canvass Chinese medicine stakeholders so their opinions and views are available to the Board. Being able to hear what the Board is up to has shone some light on many issues that face practitioners like myself all over Australia. I have learnt more about the complex processes involved in the Board’s decision-making and policy developments. I have definitely developed a greater understanding of what goes on behind the scenes in order to keep our registered profession at the standard it needs to be.
Involvement in the Reference Group requires attendance at two to four meetings over the two-year tenure and some online correspondence and communication. The meetings are informative and friendly. As a practitioner it has been helpful to give opinions on issues of concern and feel that these are heard and appreciated. I think this Reference Group plays an important role in the development of our profession as a whole and I would recommend anyone interested in learning more about our industry to apply for a position.
When the opportunity came up two-and-a-bit years ago to apply for membership of the inaugural Chinese Medicine Board Reference Group, I had no hesitation in sending in my expression of interest. I can now say as I come to the end of the current term that the experience has not been time wasting at all – unlike Count Dracula visiting the House of Mirrors at Luna Park. There have been three meetings during the two-year appointment. I expected that the first would be more of a ‘getting to know you‘ process with tentative exchanges between members who mostly did not know each other. We are, after all, quite a disparate profession. However, the Reference Group functioned with enthusiasm and commitment right from the start.
The first agenda was full and ranged over a variety of topics that the Board sought advice on and to sound out ideas. The handling of adverse events by members of the profession, for example, was discussed at length at the first meeting and followed up at the next. This exchange of ideas led to an awareness that many such events are not reported to the TGA. The educational institution representatives acknowledged their role in preparing graduates for this process. Professional association representatives committed to promoting adverse event reporting to their members.
Communication between the Board, the profession, the teaching institutions and the community summarises the role of the Board. This is a two-way process and the Reference Group is part of this process. I encourage practitioners who believe that they can have a role to play in the continued development of the Chinese medicine profession to apply to the Board when expressions of interest are advertised.
'Because of her, we can!' was Melbourne Museum's headline exhibition for NAIDOC Week 2018. Housed in the Birrarung Gallery at the Bunjilaka Aboriginal Cultural Centre, it shone a spotlight on nine Victorian First Peoples women who have achieved extraordinary things in delivering services to community. Extensive storytelling sits alongside stunning images of these remarkable women from various sovereign nations. This exhibition provided valuable contextual information about the important history of NAIDOC and served as a reminder of the need to always be thinking about:
What does the work we do now mean for the young ones, our future Elders? I am hopeful that this celebration we share today – marking a shared statement of intent ̶ will prove to be an auspicious day. Collectively we are making a commitment to developing a health system that better meets the needs of Aboriginal and Torres Strait Islander people.
As you know, this statement of intent represents a shared vision between
That vision is for a health system that values cultural safety as being as important as clinical safety; and for a system committed to ensuring that Aboriginal and Torres Strait Islander people have access to health services that are culturally safe and free from racism.
Cultural safety is fundamental to reconciliation and the nursing and midwifery professions have been talking about what this means for:
A myth about cultural safety is that you will learn about Aboriginal Peoples ̶ the gaze is outwards and comfortable. This type of training is not cultural safety. That is cultural awareness training, and while also useful, it does not produce the seismic shift that we need in Aboriginal and Torres Strait Islander health outcomes.
Critically, in cultural safety training there is no standard approach. Aboriginal and Torres Strait Islander Australians represent diverse nations of people, well over 300 nations. Hence non-Indigenous people can never know all there is to know about us and there cannot be a tick list on how to treat us.
In contrast, cultural safety’s gaze is inward; it is about knowing thyself. Cultural safety is about having knowledge of one’s own culture, values, attitudes, assumptions and beliefs. It is about being aware of our racial discourses, and our unconscious bias. It is an awareness of our attitudes and where these attitudes come from; and how these preconceptions can be unlearned where they exist, or how healthy attitudes can be reinforced and celebrated.
Cultural safety represents a philosophical shift from thinking that health professionals should treat everyone the same, or that they need to learn about Aboriginal and Torres Strait Islander people, to learning about themselves.
Signatories to the statement of intent have committed to ensuring that Aboriginal and Torres Strait Islander people are actively leading the design, development, delivery and control of health services. As our statement of intent notes, to achieve these outcomes will require long term and substantive reform.
I thank all who have been part of creating the collective movement represented by this statement and for all the work that it signals is to follow. I acknowledge your commitment to health equity, and your courage.
To understand the importance of courage in such work, we only have to think back to the uproarious and ill-informed reaction earlier this year to the embedding of cultural safety into new nursing and midwifery codes of conduct.
We, the Nursing and Midwifery Board of Australia and CATSINaM, learnt that the strength of a relationship and mutual vision is not tested and forged in easy times, but in difficult times. Creating real, lasting and meaningful change takes determination, integrity and clarity of vision ̶ as well as courage.
As we move forward in this collective journey of reform, we need to ensure there is consistency across the professions. We are not seeking a ‘lowest common denominator’ approach. I urge you to aim for excellence but you can’t be the best possible health practitioner or service unless you are culturally safe.
Cultural safety goes hand in hand with excellence in professional practice and excellence in service delivery. You can’t have one without the other.
This is an important event today and I enthusiastically acknowledge the significance of this step that we are collectively taking, and the leadership shown.
When Aboriginal and Torres Strait Islander people called for cultural safety to be embedded into health practitioner legislation, the National Boards and AHPRA didn’t walk away from the challenge. They picked it up and ran with it.
There is still a long journey ahead of us, but we have made an important start.
I look forward to sharing this journey with you all, to:
Together we will create a health system where my children and their children will receive excellent care from a health system that we can all be proud of.
You can find out more about the National Scheme’s Statement of Intent and Reconciliation Action Plan on AHPRA’s website.
The Board has completed the annual revision of the Nomenclature compendium of commonly used Chinese herbal medicines (the Compendium). The Compendium provides standard terminology to support the Board's Guidelines for safe practice of Chinese herbal medicine.
The Compendium is available on the Board's website on the Guidelines for safe practice of Chinese herbal medicine page.
The Compendium cross-references commonly used Chinese herbs by:
While care is taken to ensure that information in the Compendium about herbs subject to the SUSMP (Poisons Standard) or CITES classifications is correct at the time of release of the annual update, the SUSMP and CITES documents are updated periodically and it may be necessary to ensure that the information is correct at the time of use.
The SUSMP is available on the TGA website and the CITES list relevant to Australia is available on the CITES website.
The version of the Compendium published on the Board's website is the authorised, current version. The new document date is 1 September 2018.
Feedback on the Compendium is welcome: please email firstname.lastname@example.org.
The number of Chinese medicine practitioners in Australia has doubled in the past 20 years. The continued growth of the profession reflects the increasing demand by consumers seeking treatment with Chinese herbal medicine and acupuncture. To help its regulatory role, the Board commissioned research by the AHPRA Research Unit to investigate the possible risks of harm that may be associated with the practice of Chinese medicine.
From reviewing national and international data, the report concludes that Chinese medicine is a relatively low risk form of healthcare, particularly in regulated environments such as Australia, with the registration of practitioners under the National Scheme and the regulation of related therapeutic products by the Therapeutic Goods Administration (TGA).
The research indicates that the incidence rate of notifications (complaints) against Chinese medicine practitioners is low. However, when a notification is made, most involve concerns about clinical care. Maintaining a high level of professional competence and conduct is essential for quality care and we encourage you to observe the Board’s Code of conduct, which contains important information and guidance about standards of conduct and care throughout your practice of the profession.
Major risks associated with herbal products and how these risks are mitigated in Australia are:
The Board’s Guidelines for safe Chinese herbal medicine practice support Chinese medicine practitioners to practise Chinese herbal medicine safely. Additional resources on the Board’s website to help you include:
The review indicates that the practice of acupuncture by qualified Chinese medicine practitioners is generally safe. International evidence indicates that a rare event associated with acupuncture is pneumothorax, which can cause potentially serious health issues. It also indicates that the main risk associated with moxibustion is burning of the skin.
The report shows that over the years AHPRA has received several notifications of pneumothorax events. The Board is developing an education package to help practitioners minimise the risk of pneumothorax.
The Board encourages all Chinese medicine practitioners to read the full report on our Research and reports page as it will help you develop your own knowledge of the risks that need careful management in your practice of Chinese medicine.
Professional associations are encouraged to conduct workshops to help their members better understand and develop safe practice strategies as part of their 2018 continuing professional development (CPD) activities.
The report also highlights why CPD and other support materials provided by the Board are valuable resources to support optimum patient care.
Under the National Law, all registered Chinese medicine practitioners are responsible for renewing their registration on time each year. The quickest and easiest way to renew your registration is online.
The Board urges all Chinese medicine practitioners to ensure contact details, including your email address and mobile phone number, are current.
Update your contact information by logging in to our secure online services. Use your user ID and secure password, and follow the prompts.
If you do not have your user ID, complete an online enquiry form and select ‘Online Services - Practitioner’ as the category type. You might also need to reset your password.
The Australian Health Practitioner Regulation Agency (AHPRA) will contact you individually about renewal on behalf of the Board. Keep a look out for the reminders to renew as confirmation that online renewal is open.
Your renewal reminder (email or hard copy) includes all the information you need for easy, online renewal of registration:
Make sure you renew on time because, under the National Law, there is no option for AHPRA or the Board to renew your registration after it has lapsed without you having to complete a new application for registration.
For more information:
The Board has announced the national registration fee for Chinese medicine professionals for 2018/19.
The Board has frozen the registration fee at $579. The Board has focused on operational efficiency over the last several years through a number of initiatives such as simplification of its committees and the governance structure. The registration fee has been frozen without any increase since the 2015-2016 renewal process.
The fee for practitioners whose principal place of practice is New South Wales is $480. NSW is a co-regulatory jurisdiction: see www.ahpra.gov.au/about-ahpra/what-we-do.aspx.
The annual renewal fee covers the registration period for most practitioners from 1 December 2018 to 30 November 2019.
In recognition of the challenge of being a new graduate and starting practice, the Board has significantly reduced the application and registration fees for graduates for 2018-19. This applies to graduates applying for registration for the first time who have completed a Board-approved program of study. The reduction is about 70-80 per cent for this group of new registrants.
The new fee for graduates will be implemented from 27 September 2018; however, it will be in effect from 1 July 2018. Graduates are encouraged to apply for registration from 27 September 2018.
Any new graduate who has applied for registration already between 1 July 2018 and 27 September will have their application fee and registration fee adjusted to the new reduced fee amount. Those applicants will receive a refund of the difference where applicable and do not need to contact AHPRA. This will apply automatically and you will be notified via email.
All other registration fees for Chinese medicine practitioners will apply from 10 September 2018. A full fee schedule, including the fee arrangements for practitioners whose principal place of practice is NSW, has been published on the Board’s website.
The National Scheme is fully funded by practitioners’ registration fees. The decision to freeze the fee is due to the success of the Board’s financial management while effectively carrying out its duties to protect the public.
It needs to be remembered that the Chinese medicine profession represents less than one per cent of total registered health practitioners under the National Scheme, so it is not possible to achieve the same economies of scale and the fee structure reflects this. However, the Board’s aim is to set fees as low as possible to minimise financial burdens on registered Chinese medicine practitioners.
Fees support the Board in the continual development of a safe and mobile Australian workforce for health practitioners and the public in the most efficient ways possible. Fees also allow us to ensure that the education and training provided for practitioners is of high quality.
A pilot audit to check health practitioner compliance with advertising requirements will be conducted by AHPRA in early 2019.
The pilot audit has been modelled on the well established approach to auditing compliance with core registration standards and involves adding an extra declaration about advertising compliance for two professions when applying for renewal of registration in 2018. (The National Law enables a National Board to require any other reasonable information2 to be included with a renewal application.)
The National Boards for chiropractic and dental are taking part in the pilot audit.
When applying to renew their registration, chiropractors and dental practitioners will be required to complete a declaration about their advertising compliance. The pilot audit will not delay a decision on the application for renewal.
Random audits of advertising compliance will advance a risk-based approach to enforcing the National Law’s advertising requirements and facilitate compliance by all registered health practitioners who advertise their services.
Regulatory Operations Executive Director Kym Ayscough said the audit for advertising compliance would provide opportunities to extend the current action under the Advertising compliance and enforcement strategy launched in April 2017.
‘This pilot audit will potentially improve compliance with advertising obligations across the entire registrant population, not just those who have had an advertising complaint,’ Ms Ayscough said.
‘It will also provide opportunites to become more proactive in preventing non-compliant advertising by registered health practitioners.’
The audit will be carried out by AHPRA’s Advertising Compliance Team from January 2019 and will involve a random sample of chiropractors and dental practitioners who renewed their registration in 2018.
‘One of the audit’s main objectives is to analyse the rate of advertising compliance for those practitioners who advertise and who have not been the subject of an advertising complaint in the past 12 months,’ Ms Ayscough said.
Other objectives of the audit are:
A pilot audit report addressing the above objectives and including data analysis and recommendations will be prepared for National Boards to consider the pilot outcomes and implications for future compliance work.
For information about your advertising obligations see AHPRA’s Advertising resources page.
2 Section 107(4)(e) of the National Law.
AHPRA and the Chinese Medicine Practice Board have started accepting an updated format of test results for the Occupational English Test (OET).
All National Boards have a registration standard for English language skills, which require applicants for initial registration to demonstrate English language skills to be suitable for registration. The OET is one of the English language skills tests accepted by the Chinese Medicine Practice Board.
The English language level being tested by OET remains the same. Test takers are not being measured differently, with the only change being the way the OET scores are described. As such, the National Boards’ English language skills registration standards referring to OET have not changed. Rather, updates have been made to internal systems and relevant application forms to accommodate and reflect the new numerical scale. You can read more in the news item.