When the complaints body flags a safety risk, you listen

If you want to know whether a training model is clinically sound, don’t ask the architects selling it. Ask the people whose job is to deal with what happens when clinical care goes wrong.

That is why the Psychology Council of NSW’s answer to Question 11 of the consultation paper matters.

For context, NSW runs a co-regulatory model. The Psychology Council of NSW doesn’t run university faculties and doesn’t sell degrees. Its job is to assess complaints about psychologists, review performance and conduct, and protect the public when practice goes wrong. It sees exactly where clinical judgement breaks down.

Question 11 asked whether graduates of the proposed pathway would be better prepared for entry-level practice. The pathway’s core idea is an AQF Level 8 (Bachelor Honours) qualification as the entry point for independent general registration.

The Council’s answer was “Not necessarily”, and it went on:

The Council is particularly concerned that graduating with the knowledge, skills and attitudes associated with an AQF Level 8 qualification will expose graduates to the potential for unsafe practice.

Why that matters

My reading is that the concern goes to the heart of clinical competence. Independent psychological practice is not a technical trade. It demands autonomous diagnostic reasoning, complex risk formulation, and the capacity to handle severe distress without a supervisor at your shoulder. Dropping the entry standard from postgraduate training (AQF 9) to undergraduate Honours (AQF 8) strips out the time and depth that kind of practice needs.

The redesign’s supporters describe AQF 8 as streamlined efficiency and workforce agility. The body that deals with complaints sees the other side: early-career practitioners in independent practice without the depth of training to manage complex clinical risk safely.

When universities object, the Board frames it as institutional inertia. When private practices object, it frames it as workforce resistance. But when the state council responsible for complaints about psychologists warns that an AQF 8 standard risks unsafe practice, that should give everyone pause.

So why is anyone in our profession pretending this is progress?