To be or not to be self regulated

31 January 2023

NASRHP vs AHPRA: Regardless of the scheme, each allied health profession has a system in place to ensure that practitioners are appropriately qualified, undertakes ongoing professional development, and adheres to professional standards.

One of the most common questions ESSA gets is ‘Why aren’t we with AHPRA’?


Let’s start with what Australia Health Practitioner Regulation Agency (AHPRA) is about - regulation. The purpose of a regulation system is to protect the public from harm, and ensures the public is protected and services are safe and accessible.

AHPRA regulates the National Registration and Accreditation Scheme (NRAS) and the requirements of the Health Practitioner Regulation National Law. Individuals must register with AHPRA in order to practice in regulated health professions (as outlined in the National Law). This means individuals cannot practice that profession or use a registered health professional title (e.g. physiotherapist) unless they have current registration with AHPRA.

Currently, the Australian Government recognises two types of regulation of allied health professions:

  • Regulation under the NRAS through registration with an AHPRA Board
  • Regulation through clinical certification by a professional body that implements a “self-regulatory” model

Exercise physiology falls under the latter and ESSA has administered this self-regulating scheme since 1996.

At this stage, exercise physiology does not meet the NRAS criteria, particularly under points two and three. The good news is that the government believes ESSA’s regulation processes are appropriate and that there are not enough complaints about the profession, or recorded injuries and deaths to meet the criteria. The data from state and federal mechanisms also does not support the need for this type of regulation.

There have also been concerns raised that the cost to government and the profession to set up and run a registration board could be prohibitive.

ESSA engaged with government over the years to advocate that exercise physiology services are safe and effective, which is what allowed inclusion in Medicare and recognition as an allied health profession. It would not be in our best interest to argue the opposite. To advocate for inclusion in AHPRA would mean that ESSA would need to provide evidence that the profession is risky to the public.


  1. Is it appropriate for Health Ministers to exercise responsibility for regulating the occupation in question, or does the occupation more appropriately fall within the domain of another Ministry?
  2. Do the activities of the occupation pose a significant risk of harm to the health and safety of the public?
  3. Do existing regulatory or other mechanisms fail to address health and safety issues?
  4. Is regulation possible to implement for the occupation in question?
  5. Is regulation practical to implement for the occupation in question?
  6. Do the benefits to the public of regulation outweigh the potential negative impact of such regulation?


In one word - recognition.

There is no doubt that employers, government and the healthcare industry know what registered professions are, and that AHPRA provides the safety and quality mechanisms for registered health professions. Many pieces of legislation, at all levels of government, only reference AHPRA professions and many employers list AHPRA registration as a requirement for jobs. But, we at ESSA know the safety and quality of our professions, so our biggest task is to raise awareness of our self-regulation so that our professions are recognised similarly.

The main difference between being regulated by AHPRA and being a self-regulated association is that practitioners do not have to be accredited to legally practice, however the professions we represent may be limited in where they can practice without accreditation. For allied health professionals in self-regulating professions, accreditation by the peak body is typically required by Medicare, the National Disability Insurance Scheme, private health insurers and other funders of health services.


ESSA is a member of the National Alliance of Self-Regulating Health Professions (NASRHP). NASRHP aims to set an evidence-based framework of minimum standards of practice for self-regulated health professions, which are closely aligned with the AHPRA registration standards. NASRHP have 11 standards that facilitate national consistency in quality and support for self-regulating health professionals and satisfies national and jurisdictional regulatory requirements.

  • Scope (Areas) of Practice
  • Code of Ethics/Practice and/or Professional Conduct
  • Complaints Procedure
  • Competency Standards
  • Course Accreditation
  • Continuing Professional Development
  • English Language Requirements
  • Mandatory Declarations
  • Professional Indemnity Insurance
  • Practitioner Certification Requirements
  • Recency and Resumption of Practice Requirements

ESSA is a founding member of the NASHRP alongside other peak professional associations including dietetics, audiology and speech pathology, and is committed to a consistent set of standards that promote quality in practice and allow NASRHP to advocate for self-regulated health professions as a whole.

“Recognition with the NASRHP provides assurance to patients they are receiving a quality service from a certified professional who is committed to practicing safely, effectively and to a high standard,” Anita Hobson-Powell, current Chair of NASRHP, has shared on the topic.

“It also strengthens ESSA and the association’s professionals’ position and recognition within the Australian health care system.”

Our policy and advocacy team also continuously review key pieces of legislation to ensure the inclusion of self-regulated health professions as a key priority item in submissions and other advocacy works.

It’s on all of us to educate our peers and employers about the strengths of being part of NASRHP and the value of accredited professionals who are certified to work to a higher standard.