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The new scope of practice has been published for comment


It is critically important that all psychology professionals should read this, familiarise themselves with the contents and send in their feedback to the email address that is mentioned on page 4 of the proposed regulation.


Access it here:


pdfThe proposed new scope of practice for comment


The period for comments expires on the 12th of December 2018.

Note that this document is intended to replace not only the scopes of practice of categories within the profession but also the scope of the profession itself.


In Psytech SA's view, there are many serious problems with this document and we shall be posting our detailed response to the proposed new scope of practice for your information.

Please study the document, think about the implications for your professional practice, debate it with your colleagues and do not fail to submit your response.


Think about what will happen if this becomes law!


We have less than three months to submit comments to the Department of Health.

 The task team report


In April 2018 the HPCSA issued a report compiled by the Task Team that worked on the compiling of the new regulations. It provides some indication of what motivated the changes they propose to implement. It makes for interesting reading, but when one compares it to the document they actually produced, there appears to be a disconnect between the intention and the result.


pdfThe report from the HPCSA task team April 2018


Some noteworthy points from the task team report:

  • The need for transformation in the racial composition of the profession, and of the clients of the profession, is given high priority.
  • The document recognises a need for transformation in training of the profession.
  • The task team recommends a process for transverse registration between categories
  • A longer-term plan is envisioned, with profound changes in the professional landscape. The idea of a generalist psychologist at Masters level and specialist categories at Doctoral level is resurfacing. This was under discussion during the early years of this millennium, resulting in a cohort of psychologists that received integrated training. However, the system was never fully implemented, nor is it being implemented now.
  • There is a review of the history of the psychology profession in South Africa, of which the relevance to the proposed scope regulation is not apparent.
  • The High Court declared Regulation R704 invalid. Regulation R993 (the scope of the profession as a whole) was not declared invalid by the Court. However, regulation R993 is being repealed.
  • Attendance by Board members at conferences is presented as evidence of consultation on the matter of scope of practice.
  • It is clear that comprehensive data collection and analysis preceded the formulation of the scope document.
  • The research indicated the overlap and demarcation between categories within the psychology profession as a problem that they aimed to resolve.
  • The Professional Board paid a researcher to analyse the inputs. The task team did not disagree with the conclusion that the function of the scope of the profession (R993) is to define the actions that may not be performed by unregistered persons, and that this serves to protect the public. However, in the proposed scope of practice document, they did not provide an adequate replacement for these definitions, thus leaving the borders of the profession undefined.
  • The Working Group on scope of practice made recommendations for the definitions of the current categories of psychologist and for registered counsellors and psychometrists. These are inexplicably different from the definitions that eventually made their way into the proposed scope of practice.
  • While the intention of the task team was to merge R993 and R704 into one document, this is not what was done. R704 was reformulated and very little of R993 found its way into the proposed scope of practice upon which the public is now being asked to comment.

 The presentation of the proposed document at the PsySSA conference


Two days after the proposed new scope of practice was published for comment in the Government Gazette, the chairperson of the task team, Prof. C. Young, and the chairperson of the Board, Prof. B. J. Pillay, did a presentation on the new document. Prof. Pillay took the lead in the presentation and Prof. Young responded to a few questions.


  • There was no handout. The document was not made available to the delegates.
  • It appeared that some educational psychologists may have had access to the document and therefore their response was more informed and coherent.
  • Delegates who attempted to access the document online during the presentation were unsuccessful since it did not show up in a Google search. It was also not accessible via the Department of Health's website, or the HPCSA website. Even after the presentation, it remained difficult to find online. This is very serious since the time for comments is limited, and by the time it was presented at the conference, it was already the third day of the comments period.
  • What was presented was a number of slides that appeared to have been cut and pasted from the scope of practice document.
  • The slides were incomplete - there was no coverage of the scope of practice for research psychologists.
  • There was not one question or comment from the delegates that was supportive of the proposed new scope of practice.
  • There was a lot of anger from the educational psychologists.
  • The perception was expressed that the proposed new scope of practice once again tried to limit the scope of educational psychologists, and also the other categories, while the scope of clinical psychologists appeared to be even more expansive than before.
  • The ordering of the categories was perceived as placing clinical psychologists at the top with the other categories subordinate to that. Prof. Pillay said there was no such intention, the ordering is simply alphabetical. However it is worth noting that alphabetical ordering was not used in R704, and it is difficult to avoid the impression of a hierarchy.
  • The use of the term "promoting mental health" was questioned. It was perceived as minimising the importance of the categories where it was used (counselling and educational psychologists and registered counsellor), implying that they were doing some sort of public relations work for psychology without actually being able to do meaningful interventions, and stood in sharp contrast to "providing comprehensive bio-psycho-social healthcare across the lifespan", which was used for clinical psychologists.
  • There was dissatisfaction with the idea that a limit was placed on the degree of seriousness of the problems that certain categories could deal with, with clinical psychologists being allowed to deal with severe problems but other categories limited to mild to moderate problems.
  • Prof. Pillay made a number of inaccurate statements. Notably, he said that, for industrial psychologists and research psychologists, it is the title of Psychologist which is protected by law and not the activities. While it is true that unregistered persons have never been allowed to call themselves psychologists, it has always been the case that the scope of practice defined acts that are reserved for the profession of Psychology. Whether or not unregistered persons presented themselves as psychologists, performing any of the proscribed acts resulted in an offence which could be criminally prosecuted. Prof Pillay also said that academics in psychology departments at universities may call themselves psychologists. This has never been the case. Academics that are so employed but who are not registered, may indeed perform psychological acts in the course of their academic duties, but they have never been allowed to call themselves psychologists. It is deeply concerning that the chairperson of the Board would be seen to make such serious mistakes in a public forum.
  • According to the person who spoke on behalf of educational psychologists, they had repeatedly asked to participate in the reformulation of the scope of practice and had been denied the opportunity.
  • Prof. Pillay said that any further comments must be directed at the Minister of Health. What he apparently meant was that it is too late to try to influence the document through HPCSA channels at this stage. There is now a small window of opportunity, and comments must be directed to the Department of Health (Not directly to the Minister). The appropriate persons and contact particulars are in the document that is published.
  • When it was pointed out to the Board representatives that the revised scope left the borders of the profession undefined, and also that it left the psychometrics committee with no way to decide whether a test was psychological in nature or not, they had no substantive response.
  • The unfortunate impression we were left with after the presentation, was that the consultation process had been inadequate and that the Board representatives had "pulled rank" over the educational psychologists who had problems with the way the scope document was formulated.

Formal response sent to the Department of Health


This is the response sent by Psytech SA's director, Nanette Tredoux.

If you want to send your own response, feel free to use this as a guide.


pdfComments on proposed scope of practice Sept 2018