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AHPRA POV

“Insight can be taught — compliance ensures it.”

 

 

 

 

 

 

 

AHPRA POV

 

“Modern medicine requires modern obedience.”

 

 

 

 

 

 

AHPRA POV

“Your autonomy ends where public safety begins.”

 

 

 

 

 

 

 

 

Issue1

 

I believe there is profession wide agreement that continued education is important to allow medical professionals (doctors) to continue to function effectively in a changing world. However, the next question then is what is the best format/structure for these activities?


Progressively, in the last decade – CME/PD has become an increasingly complex activity. It has also become an increasingly regimented activity.

In the current iteration of – CME/PD as supervised by AHPRA. Doctors need to engage in a number of activities that are complex, unnecessary and of dubious benefit.  
( There are 3 CME/PD subcategories and even more program level requirements).


Doctors are required to reflect on their practices as part of the CME/PD process. There is little research suggesting the value of such a process. The process is bureaucracy gone mad, at doctors’ expense.
General practitioners are required to engage in multiple categories of CME/PD activities to achieve recognition for continued registration.
General practitioners are required to jump through these hoops every year, (12 months).

Do we really need such a complex system to help people learn things?
The purpose of CME/PD is to learn things that are useful and relevant to the average person in their practice. The purpose of CME/PD is not to spend time learning how to fill in bureaucratic forms for this activity.
The process can be a lot simpler and easier.

The only question really needs to be what do you think you could/ should/ need to do? And there is a lot of serendipity in the progression of this process.

 

Does requiring an essay on reflection change anything?
The process of adult learning is “see a need/ learn about it/ use the new information”- and this process is very serendipitous depending on events in our lives, not all  susceptible to architectural level planning – since you don’t know what you need usually until the need arises- depending on circumstances.

 

I believe doctors want any CME/PD process to be simple, relevant and easy to become engaged in. Requirments for reflection and quality improvement  activities in  practices is like as not , irrelevant to many salaried practitioners and irrelevant to the process by which many of us organise our lives.

Complexity Complexity

Do you really need an essay on reflection as suggested at  the end of this page  This process is really relevant to planners and administrators, not front-line workers..

Here's a more detailed look at the RACGP's approach to reflection on practice:


Key Aspects of Reflective Practice in the RACGP Context:

Reflective practice is a core component of the RACGP's CPD program, specifically within the Professionalism and Ethical Practice domain. 

Reflective practice encourages GPs to take ownership of their learning and professional development by identifying their own strengths, weaknesses, and learning needs. 

Reflection on practice is linked to quality improvement in general practice. By critically examining their work, GPs can identify areas where they can enhance patient care and service delivery. 

The RACGP's ReCEnT (Review of Enhanced Clinical Encounter Tool) program provides registrars with feedback on their clinical practice, which can be used as a basis for reflection and targeted learning. 

Supervisors and medical educators play a vital role in guiding registrars through the reflective process, helping them to interpret feedback and develop appropriate learning plans. 

Reflecting on practice can help GPs to uphold professional standards, address ethical dilemmas, and ensure they are meeting community expectations. 

Reflective practice encourages GPs to examine their own cultural biases and assumptions, particularly when interacting with diverse patient populations. 
How to Engage in Reflective Practice:

  1. 1. Identify a Challenging Encounter:

Reflect on a specific clinical encounter that presented a challenge or an opportunity for learning. 

  1. 2. Consider the Context:

Analyse the situation, including the patient's perspective, your own actions, and the systems and processes involved. 

  1. 3. Analyse Your Performance:

Reflect on your strengths and weaknesses in the situation. What did you do well? What could you have done differently? 

  1. 4. Identify Learning Needs:

Determine what knowledge, skills, or attitudes you need to develop to improve your performance in similar situations. 

  1. 5. Develop a Learning Plan:

Create a plan for addressing your learning needs, which may include further education, reading, or mentorship. 

  1. 6. Implement and Evaluate:

Put your learning plan into action and evaluate the impact on your practice. 
Examples of RACGP Resources:

The RACGP offers a structured reflective exercise to guide registrars in exploring specific competency areas. 

This resource provides information about the ReCEnT program and how to use it for reflection. 

This section of the curriculum focuses on the importance of reflection in ethical practice. 

The RACGP outlines different types of CPD activities, including those that involve reflection on performance and outcomes. 

This resource provides guidance on creating a learning plan based on reflective practice. 
By actively engaging in reflective practice, GPs can enhance their clinical skills, improve patient care, and contribute to the ongoing development of the profession. 

Education  Education

 

 

AHPRA (Australian Health Practitioner Regulation Agency) provides guidelines and requirements for reflective practice,

particularly when it comes to addressing concerns or completing required education. These guidelines outline the structure and content of reflective reports, emphasizing the need to demonstrate a clear understanding of the issues, the education received, and how practice has been adapted to address concerns. 
Key aspects of AHPRA's reflective practice guidelines:

In addition to the above, AHPRA also provides guidelines for self-reflection in other contexts:

and practitioners should reflect on what they have learned, whether they have met their learning goals, and how their practice has changed as a result. 

 

and practitioners should reflect on their record-keeping practices and identify areas for improvement. 

 

including how it responds to concerns about practitioners and how it develops standards and guidelines. 
Overall, AHPRA emphasizes the importance of reflective practice as a tool for professional development, improvement, and ensuring public safety. 

 

 

 

 

Doctors are required to make political statements about how they run their practices  which may not be in keeping with their beliefs. Doctors are not allowed to have dissenting opinions on issues such as immunisation,  Contraception, political correctness or  indigenous engagement . Can we really say we live in a democracy if unpopular or non-politically correct opinions are suppressed?  AHPRA/ the Boards are the bully on the block that insists only “IT “ is right and that there can be no dissension. Immunisation and CoVid  has been the most obvious recent issue. 

 

Meanwhile the Daleks say : Obey! Obey! Obey ! Obey !

 

 

THE AHPRA POINT OF VIEW: on this issue

It should be stated plainly that AHPRA and the Medical Board of Australia are better positioned than individual practitioners to determine what constitutes “appropriate” CPD in a modern, high-risk, culturally complex, litigation-exposed health system. This is not an area for personal preference, professional nostalgia, or self-assessment by clinicians whose training occurred before many current medicines, governance expectations, and contemporary social standards were established. Modern practice requires modern oversight—particularly where a practitioner’s confidence exceeds their evidence of insight.

Colleges may be valuable educational bodies, but they remain structurally conflicted: they serve members, not the public. Their tendency toward professional protectionism is precisely why statutory oversight exists. AHPRA’s remit is system risk— cross-jurisdictional intelligence, pattern recognition across complaints, and compliance frameworks built by governance specialists rather than clinicians marking their own homework. Accordingly, AHPRA sets CPD expectations, including reflective practice, cultural capability, and values alignment. Reflection is not optional; it is the minimum mechanism by which practitioners demonstrate safe attitudes in addition to technical competence. A refusal to engage is not “independence”—it is a signal of impaired insight that warrants closer supervision.

The structured CPD model exists because unstructured learning is unverifiable and therefore functionally meaningless for public assurance. Informal reading, “experience,” and self-directed curiosity do not create an evidentiary trail that can be audited, compared, or relied upon when a complaint arises. Documentation matters: it shows what was done, when it was done, and whether a practitioner’s reasoning aligns with current expectations. If clinicians experience this as burdensome, that is unfortunate—but regulation is not designed for convenience. It is designed for defensibility, consistency, and enforceability.

Calls for “doctor votes” to set regulatory standards misunderstand the nature of regulation. Standards are not a popularity contest, and safety is not decided by whichever professional majority is loudest this year. Governance expertise sits with those trained to manage compliance, minimise system harm, and enforce consistent minimum expectations—not with practitioners embedded in local custom, habit, or personal belief. Where a doctor disputes mandated CPD structures, the correct inference is not that the rules should bend; it is that the practitioner requires additional oversight. AHPRA’s role is to set the baseline and require compliance. Negotiation is not a regulatory function; it is how standards decay.

 

Erasmus (the old dog) : Call It As I See It

Formal legal observation:
Regulation is legitimate only when its burdens are proportionate to a demonstrable benefit. If CPD becomes an exercise in compliance theatre—paperwork that is easy to audit but weakly connected to patient outcomes—then the regulator must justify the coercion with evidence, not assumptions. “Because we say so” is not a legal standard; it is a warning sign.

Legalistic view:
When regulatory standards become so prescriptive that meaningful professional judgement is displaced by bureaucratic compliance, the line between regulation and coercion becomes legally contestable. The absence of proportionality review mechanisms risks regulatory overreach.

Regulatory bodies are given powers by legislation to protect the public, but those powers are not unlimited. They must be exercised proportionately, transparently, and with clear evidence that the harm prevented is real, not hypothetical. When regulators replace professional judgement with bureaucratic compliance rituals, the law requires that they demonstrate measurable benefit to patient outcomes. If no such benefit can be shown, then the regulatory burden itself may constitute an unreasonable exercise of power.

Human interest view:
Doctors can tolerate criticism. What erodes them is the steady conversion of professional life into a proof-of-innocence routine: constant documentation to satisfy people who were not in the room, not in the consult, and not carrying the human weight of the work. When every hour of care is shadowed by an hour of defensibility, the system doesn’t create safer doctors—it creates tired ones.

Patient view:
Patients rarely ask for “better forms.” They ask for attention, continuity, and clinicians who still have the bandwidth to think. A safety system that drains thinking time in order to produce audit comfort risks achieving the opposite of what it claims: clinicians who practise to avoid trouble rather than to solve problems.

 

Cynical aside:
If you train doctors to prioritise paperwork over judgement, you eventually get immaculate files and empty medicine.

 

Additional commentary (non-AHPRA perspectives)

Administrative reality:
A CPD system can be robust without being punitive. The moment the framework becomes primarily a tool for discipline, it stops being education and becomes control. That shift matters because it changes how doctors behave: they optimise for defensibility, not clinical usefulness, and the paperwork expands to fill every available hour.

Fairness and practicality:
Minimum standards should be clear, measurable, and achievable in real clinics—especially for part-time, rural, older, and high-burden practitioners. When requirements become so detailed that ordinary compliance requires unpaid labour, the policy is effectively a hidden tax on practice. Hidden taxes do what they always do: they push people down and push people out.

Political and workforce perspective:
Systems that treat experienced clinicians as inherently suspect do not become safer; they become thinner. A regulator may succeed in standardising behaviour, but if the price is accelerated burnout and early retirement, the community pays in access, wait times, and loss of clinical memory—exactly the things no spreadsheet captures until it’s too late.