The Podiatry Board and Ahpra’s joint response

The review makes 14 recommendations in six key areas:

Registration and practice
Education and training
Title
Advertising
Handling of complaints
System safety and quality.

The Podiatry Board of Australia and the Australian Health Practitioner Regulation Agency (Ahpra) accept all 14 recommendations in the report.

The Podiatry Board and Ahpra will commence work to implement these recommendations, with the aim of strengthening public protection and regulatory effectiveness for the specialty of podiatric surgery and building public trust and confidence in the National Scheme.

Some recommendations will be implemented immediately (for example, application of the Risk Assessment Framework), other recommendations involve shorter-term actions (such as working with stakeholders to identify enhanced options for expert clinical advice), others are medium-term actions which require wide-ranging consultation (such as new practice guidelines and a review of the Advertising Guidelines), others are ultimately decisions for Health Ministers (change to the protected title) and others are complex and longer-term pieces of work, involving many stakeholders (for example, working with Governments and others to explore options to integrate podiatric surgeons into the broader healthcare system).

The Podiatry Board and Ahpra will consult widely as they progress these reforms and publish periodic implementation updates.

Recommendations	Podiatry Board and Ahpra response
Registration and practice
1. The Podiatry Board and Ahpra develop a professional performance framework for the podiatric surgery specialty which is informed by the Medical Board’s framework, and which captures the relevant recommendations in this report.	Accept. The Board will consider all the recommendations closely and develop a professional performance framework which captures the relevant review recommendations and consult stakeholders on the draft framework.
2. The Podiatry Board and Ahpra strengthen the registration and practice requirements for podiatric surgeons by: requiring all podiatric surgeons to hold an endorsement for scheduled medicines strengthening the continuing professional development (CPD) registration standard to align more closely with the Medical Board’s approach to practitioners reviewing their performance and measuring outcomes as part of their CPD developing guidelines for practitioners undertaking podiatric surgery.	Accept. The Board will consider the most appropriate mechanism for requiring all podiatric surgeons to hold an Endorsement for Scheduled Medicines and undertake consultation with stakeholders. The Board will strengthen the CPD requirements for podiatric surgeons and undertake consultation on proposed requirements. The Board will draft guidelines for practitioners undertaking podiatric surgery and undertake consultation on these.
Education and training
3. The Podiatry Board ask the Podiatry Accreditation Committee to: strengthen the requirements for accreditation assessment teams to ensure the teams include relevant surgical expertise, with input from the Australian Medical Council endeavour to appoint one member who sits on both accreditation assessment teams, to help ensure consistency in accreditation assessment of the two podiatric surgery programs ensure accreditation assessments of educational providers take into account the regulatory history of health practitioners who are members of governance committees or academic staff consider developing accreditation standards for training sites to ensure they meet minimum quality clinical standards take into account the areas highlighted in this review, and any recommendations from the National Health Practitioner Ombudsman, in carrying out its accreditation functions and in the review of the accreditation standards planned for 2024.	Accept, noting the Podiatry Accreditation Committee is independent from the Board.
Title
4. Following consultation, the Podiatry Board seek Health Ministers’ approval to change the protected title for the specialty from ‘podiatric surgeon’ to an alternative title, such as ‘surgical podiatrist’.	Accept in principle. The Board will undertake consultation on a proposed change to the protected title, prior to seeking Health Ministers’ approval.
5. Subject to recommendation 4, the Podiatry Board and Ahpra develop additional information for consumers to support their understanding of the title and what it means.	Accept in principle, pending consultation and Health Ministers’ approval.
Advertising
6. Ahpra and the National Boards revise the Guidelines for advertising a regulated health service to include clearer information about advertisers’ obligations under the National Law, particularly in relation to the use of titles and claims about training, qualifications, registration, experience and competence. This could include: additional resources for advertisers, such as some examples relevant to podiatric surgery an education campaign for practitioners and advertisers, to support the effective implementation of any additional guidelines, additional information for consumers to strengthen their understanding of podiatric surgery.	Accept. Ahpra and National Boards will work together to review the Guidelines for advertising a regulated health service. The Podiatry Board will pay particular attention to additional resources and information relevant to podiatry surgery. Ahpra and National Boards will review these guidelines and propose and consult on changes.
7. Ahpra strengthen its enforcement in response to advertising offences by podiatric surgeons, with a regulatory approach that targets confusing or overstated claims and takes a tougher, deterrent approach to repeat offenders, including by bringing prosecutions in line with Ahpra’s Prosecution Guidelines and/or taking disciplinary action under Part 8 of the National Law.	Accept. Our strengthened response will be informed by the revised Guidelines for advertising a regulated health service and any changes to the protected title for the podiatric specialty of podiatric surgery.
Handling of complaints
8. The Podiatry Board and Ahpra apply the risk assessment framework consistently and rigorously, giving appropriate weight to the characteristics of the practitioner (in particular, complaint history, age, isolation and having trained 10 or more years ago) and the characteristics of the practice setting (in particular, for practitioners working in relative isolation in private practice) in the assessment of notifications. This will strengthen the public protective response to notifications.	Accept.
9. The Podiatry Board and Ahpra improve processes for obtaining expert clinical advice on podiatric surgery cases, by: asking the Australasian College of Podiatric Surgeons and the University of Western Australia to nominate a small number of experienced, reputable podiatric surgeons for appointment to a panel from which a suitable expert may be selected exploring viable options for obtaining credible expert clinical advice in podiatric surgery cases, including from a medically qualified surgeon or a podiatric surgeon from an overseas jurisdiction with a comparable health system.	Accept. We will work with stakeholders, both in Australia and overseas, to help us identify further options for obtaining expert clinical advice.
10. The Podiatry Board and Ahpra make better use of the full range of regulatory tools available to respond to notifications, in particular performance assessments for practitioners: who have had three or more substantiated notifications related to clinical practice over a five-year period and/or if the Board reasonably believes, because of a notification or for any other reason, that the way the practitioner practises is or may be unsatisfactory. This recommendation is designed to ensure that the Podiatry Board takes appropriate action in relation to podiatric surgeons who may pose a higher risk to patients due to their notification history or the nature of the most recent notification(s) about them.	Accept in principle, noting that effective implementation will also require the availability of suitable performance assessors.
11. The Podiatry Board and Ahpra enhance publication of notifications data, including the outcomes of notifications and deidentified case studies of lessons from complaints about podiatric surgeons, as an educative tool for practitioners.	Accept.
System safety and quality
12. The Podiatry Board and Ahpra work with state and territory health departments to explore options to require podiatric surgeries expected to need more than a local anaesthetic to be performed in a licensed facility that is accredited to National safety and quality health service standards.	Accept.
13. The Podiatry Board and Ahpra write to health ministers to request that the Health Workforce Taskforce consider the future role and sustainability of the podiatric surgery specialty. Subject to health ministers’ advice, the Podiatry Board and Ahpra should work with the Australian Government, and state and territory governments, to explore options to integrate podiatric surgeons into the broader healthcare system to improve the quality, safety and affordability of care for patients, and enable practitioners to work to their full scope of practice. The way podiatrists and podiatric surgeons are integrated in the National Health Service in the UK is instructive.	Accept.
14. Ahpra ask the Australian Commission on Safety and Quality in Health Care to advise the Australasian College of Podiatric Surgeons on how it could improve its clinical audit tool for podiatric surgery. The aim would be to ensure that the audit is redeveloped and used in a way that provides high quality data, with definitions and indicators that are commonly used by other relevant audits and registries, so that it can be used to inform safety and quality improvements for all patients of foot and ankle surgery.	Accept.

The Podiatry Board and Ahpra’s joint response

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