Consultation
paper
July 2013 Introduction
The Health Practitioner Regulation National
Law, as in force in each state and territory (National Law) requires the Accreditation
Committee established by the Chinese Medicine Board of Australia (National
Board) to develop accreditation standards for the Chinese medicine profession
and submit these accreditation standards to the National Board for approval.
The draft accreditation standards in this
document are being developed by the Accreditation Committee in accordance with
the requirements under the National Law. Prior
to releasing this document for public consultation, the Committee engaged a
small group of key stakeholders to provide comment on the draft accreditation
standards and process.
When the accreditation standards are approved
by the Board, they will become the approved accreditation standards for the Chinese
medicine profession. The Accreditation Committee will use the approved
accreditation standards to assess programs of study and the education providers
that offer the programs to ensure that they produce graduates who have the
knowledge, skills and professional attributes to practise the profession
competently and safely.
The Chinese Medicine Accreditation
Committee is consulting about the content of the accreditation standards and has
decided to take the opportunity to consult at the same time about the document
that describes the processes the Accreditation Committee will use to assess
programs of study and education providers against the approved standard. This
will enable stakeholders to comment on both inter-related documents at the same
time.
Following analysis of feedback from the
public consultation on the accreditation standards and process, the Accreditation
Committee may adjust the accreditation standards and processes prior to
submitting them to the National Board.
Making a submission
The Accreditation Committee invites
interested parties to provide their written comments on the content of the
draft accreditation standards and process addressed to accreditation.unit@ahpra.gov.au by
close of business on Friday 6 September 2013.
Submissions by email are preferred. Submissions may also be made by post,
addressed to the Program Manager, Accreditation, AHPRA, GPO Box 9958,
Melbourne, 3001.
Issues for discussion – accreditation
standards
The Accreditation Committee is proposing
accreditation standards that require an education provider to provide evidence
of its outcomes in order to meet the standards.
The
Accreditation Committee’s approach is based on a comprehensive review of accreditation
standards and processes nationally and internationally, including a
cross-profession analysis of accreditation standards and processes for the
fourteen health professions within the National Registration and Accreditation
Scheme. Historically, accreditation standards often prescribed inputs, whereas
current
accreditation approaches, including that of
the Tertiary Education and Quality Standards Agency (TEQSA), focus on
demonstration of outcomes.
Accordingly, the Accreditation Committee
considers an outcomes-focused approach is preferable to prescribed inputs because
it:
·
allows for greater flexibility
and diversity in how education providers design and deliver programs
·
promotes innovation and
encourages education providers to “showcase” how they meet the accreditation
standard
·
minimises constraints to
innovation and improvement of programs
·
is consistent with contemporary
accreditation practice in Australia and overseas, and
·
is aligned to the objectives of
the National Registration and Accreditation Scheme set out in the National Law.
In keeping with the focus on outcomes, the
accreditation standards do not specify:
·
the required length of
programs, instead requiring education providers to demonstrate how the program meets
the specifications, including volume of learning, of the relevant Australian
Qualification Framework (AQF) level, or
·
the required curriculum content,
instead requiring education providers to demonstrate how the program learning
outcomes and assessment ensure students attain the knowledge, skills and
professional attributes to practise the profession.
The Draft Chinese medicine accreditation
standards (draft accreditation standards) draw on the threshold standards set
out in the Higher education standards framework
2011 (HES) and, in doing so, recognise
the role of the Tertiary Education Quality and Standards Agency (TEQSA) in
regulation and quality assurance of higher education in Australia. Information
about TEQSA is available at www.teqsa.gov.au
This approach fosters
consistency and efficiency in professional accreditation by enabling education
providers to use and adapt evidence they have already gathered to address the
HES as part of their accreditation application to the Chinese Medicine
Accreditation Committee.
Australian Qualifications
Framework (AQF)
The Australian Qualifications Framework
(AQF) is an integrated national policy that provides the standards for regulated
qualifications in Australian education and training. The AQF is incorporated in the draft accreditation
standards. Information about the AQF is available at www.aqf.edu.au
Separation
of the accreditation standards and accreditation process documents
The draft accreditation standards and draft
accreditation process are in separate documents because they are separated
under the National Law.
The draft accreditation standards will,
once approved and published by the National Board, become the Board’s
accreditation standard.
The accreditation process will, following
public consultation, be finalised and published by the Accreditation Committee.
The process document describes how the accreditation committee will assess,
accredit and monitor education providers and programs against the Board’s
accreditation standards.
Guidance
about how to meet the accreditation standards
The draft accreditation standards are
outcomes focussed so they do not specify exactly what an education provider
needs to have in place to meet each standard. The draft accreditation standards
may be met by different types of evidence and in different ways.
The Accreditation Committee will develop a
guidance document to accompany the standards. The guidance document will
outline the Committee’s expectations about the types of information an
education provider may consider submitting as evidence and some of the ways an
education provider may choose to meet each accreditation standard.
Questions for consideration –
accreditation standards
The Accreditation Committee invites your
feedback on the draft accreditation standards and, in particular, on the
following questions.
Please explain your response to each
question, and/or your specific suggestions for how the document should be
amended.
2. Are the criteria in the draft standards clear?
3. The set of standards will be used to assess whether a program of
study and the education provider provides students who complete that program
with the knowledge, skills and professional attributes to practice the
profession.
3.1 Is the set of standards adequate for this purpose?
3.2 Are the relevant issues covered by the draft standards?
3.3 Does any content need to be changed, deleted or added?
3.4 Are any additional standards required?
4. What specific guidance relevant to the standards and criteria in
Field 5 should be included in the guidance document to accompany the standards,
particularly in relation to any content and/or skills you expect an education
provider should include in their curriculum. ?
5. Do you have any other comments on the draft standards?
Issues for discussion – accreditation process
Approach to accreditation
process
The Accreditation Committee is proposing an
accreditation process that requires an education provider to complete a
self-audit of the extent to which it meets the accreditation standards and to
provide the best available evidence to support the claims in its self-audit. The
assessment team will evaluate the self-audit and the evidence provided, and can
undertake activities to verify the evidence (such as interviewing staff,
students and graduates) and can require the education provider to provide more
information if there is a lack of evidence to support claims.
The Accreditation Committee’s approach is
based on a comprehensive review of approaches nationally and internationally,
including a cross-profession analysis of accreditation processes for the
fourteen health professions within the National Registration and Accreditation
Scheme.
The Accreditation Committee’s aim is to
develop and implement a process to promote objectivity in assessment and
evaluation; and streamline the reporting of findings of assessment and
accreditation decisions.
The Accreditation Committee and the
National Board are
considering the fees that education providers will be required to pay to apply
for and maintain accreditation. The guiding principles of the National Scheme require
the fees to be reasonable having regard to the efficient and effective
operation of the scheme.
The
accreditation fees will reflect the operational costs of accreditation for the Chinese
medicine profession, including costs associated with the review and evaluation
of accreditation applications, the drafting and approval of accreditation
reports, ongoing monitoring of Board approved programs, meetings of the Accreditation
Committee, site visits and other operational activities associated with the
implementation of the accreditation process.
The fees
will be reviewed annually by the National Board, in consultation with the
Accreditation Committee and published on the Board’s website.
Details about the fees for the 2013-2014
financial year will be published on the Board’s website.
National
Board and Accreditation Committee
It is important to understand the separate
roles of the National Board and the Accreditation Committee when it comes to
programs of study approved by the Board and the accreditation of programs. The Accreditation Committee makes a decision
about whether or not a program of study is accredited, based on reviewing
the evidence provided by the education provider showing how it meets the
accreditation standards. The
accreditation process document sets out all the steps for how this occurs. The National Board is informed of the
accreditation decision. The National
Board then decides whether or not to approve the qualification for the
purpose of registration. These two
decisions, by the Accreditation Committee and the National Board, are separate.
Current accreditation status of existing
programs
Prior to the implementation of the National
Scheme various accreditation arrangements existed for the health professions.
Whilst a number of existing Chinese medicine programs transitioned as National Board
approved programs, the Accreditation Committee did not exist at the time of
transition, and these programs have not been through an accreditation
assessment under the National Law. Therefore all education providers offering existing
programs, whether or not they are Board approved, will be required to apply for
assessment and initial accreditation as described in Section 2 of the draft
accreditation process.
The Accreditation Committee will establish
a schedule of accreditation assessments for Chinese medicine programs. The
Committee may prioritise the assessment of new and existing programs that did
not transition as Board approved ahead of the assessment of existing programs
that transitioned as Board approved.
In scheduling the assessment of programs
that transitioned as Board approved, the Accreditation Committee may consider
various factors such as the period of time since the program was assessed under
the accreditation arrangements that existed for the profession prior to July
2012, and whether the education provider has changed the program or is offering
a new program. The Committee will take into account the time an education
provider will need to prepare its application for accreditation.
More information will be provided about the
proposed timeframes for accreditation of programs that transitioned as Board
approved when it is available.
Guidance
about how to apply for accreditation
The accreditation process does not include
specific instructions detailing how the Accreditation Committee expects
education providers to compile an application for accreditation. A detailed guidance
document and application template will be developed for use by education
providers and published on the Committee’s website when it is available.
Stages
of accreditation under the National Law
The stages of accreditation that may have
existed under the accreditation arrangements for Chinese medicine programs
prior to July 2012 are now replaced by ‘accreditation with conditions’ or ‘accreditation
without conditions’. These are outlined
in the draft accreditation process document.
Period
of accreditation under the National Law
The National Law does not specify a period
of accreditation or refer to expiry of accreditation. Instead, the National Law
places an obligation on the Accreditation Committee to monitor Board approved
programs to ensure the Accreditation Committee continues to be satisfied that
such programs continue to meet the accreditation standards.
If the Accreditation Committee is no longer
satisfied that an accredited and approved program meets the accreditation
standards, it may impose conditions on the program’s accreditation or revoke its
accreditation.
The processes that the Accreditation
Committee plans to use to meet its monitoring obligation are described in Section
2 of the draft accreditation process document.
Appeals
process
The Accreditation Committee has drafted a
process for an education provider to apply for an internal review of
accreditation decisions. This process is separate to the accreditation process
because it only occurs after the accreditation process has been completed. In
the interests of transparency, the Accreditation Committee has included the
draft internal review process with the consultation documents.
1.
Is
the content of the accreditation process document clear?
2.
Should any sections of the
accreditation process document be amended or re-ordered?
3.
Is any additional content
required?
4.
Are the indicative timeframes
for assessment and accreditation feasible?
5. Do you have any other comments on
the draft accreditation process?
http://www.chinesemedicineboard.gov.au/Accreditation/Committee.aspx
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