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.