Optometry Australia (OA) has suggested changes to Ahpra’s newly proposed English language skills (ELS) registration standards, drawing attention to issues such as parental leave breaks and difficulties for practitioners who attended English-speaking schools but in “unrecognised” countries.
The regulator sets requirements for English language skills ensuring optometrists and other registered health practitioners can provide safe care and communicate effectively in English.
But the Australian Health Practitioner Regulation Agency (Ahpra) is now proposing changes to this standard “where real improvements have been identified to align with available evidence, clarify processes, reduce duplication, streamline and remove unnecessary information and address gaps in content”. One significant proposal would see South Africa removed from the list of English-speaking “recognised countries”, which typically offer a smoother path to registration if practitioners have completed their education and qualifications there.
Ahpra also considered making Hong Kong, Malaysia or Singapore recognised countries, but could not find sufficient evidence to do so.
If South Africa is removed, the remaining recognised countries would be Australia, Canada, New Zealand, the Republic of Ireland, UK and US.
“The research showed that qualifications across the professions are offered in South Africa at multiple institutions, which in some cases, have different entry requirements,” Ahpra stated.
“Many of these requirements are substantially below the equivalent Australian entry level ELS requirements and some have no English minimum requirements for entry.”
In its submission, OA agreed with most of the proposals, but suggested some changes of its own.
There are currently four pathways for practitioners to meet the ELS standards. The most common is the Combined Education Pathway for applicants who have completed both their qualification and some secondary schooling in English in a recognised English-speaking country.
Another is the Extended Education Pathway (to be renamed the Advanced Education Pathway) developed to capture applicants who have completed a qualification for registration in the profession, and have undertaken advanced education in English in a recognised country – but who have not completed their schooling in English in a recognised country.
Pathway ‘could be open to exploitation’
While Ahpra said most proposed changes will have minimal impact, changes to the Extended Education Pathway would be the “exception”. It’s intending to strengthen this by requiring applicants to have completed at least six years in total of (full-time equivalent) education solely in English in a recognised country. This needs to include their qualifications, and advanced education at a degree level or higher requiring students to read, write, listen to and speak English.
Ahpra would also set a maximum of two-year break between the person’s qualifications and advanced education. The last period of education must have been completed no more than two years before applying for registration.
“The researchers found that the Extended Education Pathway could be open to exploitation and was lenient compared with like countries,” Ahpra stated.
“There are more changes proposed to this pathway to address the issues highlighted in the review and to strengthen the robustness of this pathway. Although this may mean a small number of applicants would no longer meet this pathway and would need to use the Test Pathway, this will assure boards of an applicant’s adequate level of English and subsequent protection of the public.”
OA suggested a rewording of this to “a maximum of two years break in this period of obtaining your qualification and the advanced education will be accepted”.
“The reasoning for this request is that many potential applicants have children at this period in their life and often take six to 12 months off, which has previously ruled out many (otherwise safe) applicants from being able to use this pathway,” OA said.
“If Ahpra considers a two year break between the periods of education acceptable, then logically a pause of the same duration elsewhere in the period carries identical (low) risk.”
In the current Test Pathway – for applicants who have not completed their qualification and/or secondary schooling in a recognised country, meaning they must pass an English language test – Ahpra currently allows practitioners to combine test results from two sittings within six months, but is proposing to extend this period to 12 months.
OA agreed with this move, stating: “It provides additional flexibility for applicants without adding any significant risk for the regulator. Some applicants have noted difficulty in being able to take the tests on dates offered by providers (or difficulty if they miss a test date due to illness etc) and a greater time window would provide more flexibility in being able to take a second test.”
OA also suggested Ahpra consider the impact on practitioners who have completed their education in English-speaking international schools, but unrecognised countries.
“We understand the need to make the standard as simple as possible and that it cannot cover every possible scenario,” OA said. “However, a situation that has been flagged to us on quite a few occasions is where an applicant has completed all of their primary and secondary schooling at expat/international schools in unrecognised countries where 100% of classes are taught in English. We have seen that there is currently no flexibility for these applicants but flag this for consideration,” OA said.
The fourth and final Primary Language Pathway (to be renamed the School Education Pathway) is used by a third of applicants. It captures applicants who have completed all primary and secondary education in recognised country and their tertiary qualification in English – but not in a recognised country.
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