New Zealand College of Clinical Psychologists (NZCCP)
16 June 2025
Thank you for the opportunity to comment on the New Zealand Psychologists Board (NZPB) Consultation Document regarding the proposed role that is under development. There is a wide diversity of opinions within the NZCCP membership about the establishment of the proposed new workforce, with a substantial group being strongly opposed to the development of this workforce, and others being supportive of the role if it is established in a way where it can safely and effectively expand the access to quality psychologically informed care to people in Aotearoa New Zealand. We appreciate the care and attention that has been applied by the Health New Zealand development team into addressing and mitigating the many issues that arise in development of the proposed new workforce within the constraints of their brief, and the care that the NZPB has taken in development of the Scope of Practice, Competencies, and this Consultation Document. The following comments aim to ensure that the new role, if established, is able to expand our ability to meet the need for safe and effective psychologically informed care by:
- expanding access to safe and effective psychologically informed care and by
- ensuring that any unintended consequences of reducing access to fully trained and registered psychologists, or disadvantaging psychologists, does not occur as a result.
We are engaged in ongoing contact with the Minister for Mental Health and with Te Whatu Ora / Health New Zealand regarding this proposed workforce. Our comments here will particularly relate to those aspects that are under the purview of the NZPB.
As described above there is a broad divergence of opinions on this matter amongst members, from those strongly against it to those who are in varying degrees of conditional support. At the heart of all perspectives on it is the desire to ensure that psychological services that are delivered to people in Aotearoa New Zealand are safe and effective.
There is insufficient information as yet available to be confident about this. If it provides a pathway for more people, particularly from diverse and disadvantaged groups, to be able to access effective and safe psychologically informed assistance it will be useful. If it provides a pathway for practitioners providing psychologically informed care to be more widely representative of the ethnicities and cultural understandings (such as Mātauranga Māori) that are extant in Aotearoa New Zealand then it will also assist with better reflecting these values. As such, it could reflect the principles of Pae Ora, particularly supporting equity, autonomy, and enhancing opportunities to meet the needs and aspirations of Māori and other under-served groups in New Zealand.
We believe that the primary role of the Scope of Practice is to ensure that the PA can work in ways that are safe and effective given their level of knowledge and skills. We believe that the Scope of Practice to a large degree supports this, with the exception of the following points.
- [page 6] Particularly early in their training and career, the PA should work directly with the supervising psychologist rather than allowing for the possibility of them working largely under another senior health professional with remote supervision from a psychologist.
- [page 6] We recommend that, while in specific cases where the person has other relevant experience or expertise (e.g., advanced Mātauranga Māori healing knowledge or prior advanced learning in another health field) a Bachelors degree in Psychology may be seen as sufficient, in most cases a more advanced degree (e.g., Honours or Masters) should be seen as the preferred level of qualification. The rationale for this is that a major factor that adds value to the services provided by those with a psychological background compared with other therapists is the
“scientist-practitioner model,” which denotes a sophisticated understanding of psychological research, theory, and therapy that underpins the psychological therapies and related services. This involves being sophisticated in understanding psychological research, an ability that is enhanced through having some exposure to undertaking research. This typically only begins at Honours level. More advanced qualifications are also likely to increase the depth of understanding of psychological theory and therapy the PA brings to the role.
Despite what level of qualification is attained, having undertaken defined relevant coursework in the qualifying degrees is critical and this should be defined as part of the entry criteria to the programmes and in any accreditation processes for the training courses.
- [page 7] Under Inclusions - Assessment: Perhaps “Undertaking Level C psychometric and cognitive assessments at the direction of, and with close oversight of, a suitably trained psychologist” could be added. Overseas, people in similar roles are often trained to undertake the work of being psychological test technicians, delivering the tests but not undertaking the analysis, interpretation, and reporting of results. This would be an example of the kinds of additional tasks described under Responsibilities on page 19.
The NZCCP strongly advises that the name for the proposed new role DOES NOT include the word Psychologist. Of the four options given, we would support Option 1 (Psychology Assistant) or Option 4 (Psychology Associate). Our rationale for this is that the public has a great deal of trouble distinguishing between different health disciplines as it is, and applying the term psychologist to this new position would increase the likelihood of people becoming confused about what they could expect of people with this role, thereby putting people at risk.
The training pathway as defined and planned at present is more consistent with international understanding of an Assistant level of role rather than an Associate. Therefore, our first choice for title would be Option 1 (Psychology Assistant
Of the Core Competencies domains cited, we submit that Competency 1 (Diversity, Culture, and Te Tiriti o Waitangi), Competency 2 (Ethical and Legal Practice), Competency 3 (Communication Skills) and Competency 7 (Reflective Practice and Supervision) should be identical to Core Competencies for the Psychologist Scope in the current NZPB Core Competencies document. We believe that these sets of skills, attitudes, and practices should be fundamental to anyone working in the health or social services, including in the PA role or as a registered psychologist.
Competency Domain 4 – Foundational Skills: [page 14] These competencies appear appropriate for this role. The difference between a registered psychologist and the PA in this case may be a matter of degree and depth.
Competency Domain 5 – Assessment and Therapy: [page 16]. These competencies appear largely appropriate for this role. We recommend that the Skill component related to risk assessment be upgraded from “Ability to complete basic screen for risk to harm…” to “Advanced ability to assess risk of harm to self/others” as any service may have clients who attend with high levels of risk requiring recognition and appropriate management.
Competency Domain 6 – Case Management and Coordination: These competencies appear appropriate.
It is very difficult to know from the information as yet available but there is potential for further clarification and work to ensure that it does meet these requirements.
Proposed Supervision Requirements
Regarding options for requirements for supervisor, we regard Option 1 as being insufficient for this role, and Option 2 being over-restrictive to the extent that it would preclude too many psychologists from being able to supervise, with inadequate additional benefit from the additional criteria. The rationale for including having supervised other Allied Health Professionals is unclear. We would suggest criteria of:
i. Minimum of 5 years post-registration practice experience
ii. Minimum of 2 years post registration supervision experience, preferably including intern psychologists and/or newly graduated psychologists.
iii. Supervisor has completed training in supervision of PAs. This would ensure that the supervisor has clarity about the expectations and limitations of the PA role, and is upskilled in methods for supervising and extending the knowledge of this level of practitioner.
We have no strong opinion about whether the supervisors need to be Board-Appointed or not. We believe ensuring a sufficient level of training and understanding of the PA role by the supervisor is a higher priority to ensure they assist the PA to function within their Scope and to avoid pressure from services to push the PAs beyond their scope or level of competence.
We have heard discussions regarding a one-year ongoing post-completion training programme following course completion (similar to the NESP programme that nurses undertake) being a component of moving into this role. This is not mentioned in this document and would be a huge asset for ensuring the safety and effectiveness of graduates. If this training is ultimately approved, building this in as a requirement for continued registration would be a significant step to continue upskilling the PAs to ensure they are as safe and effective as possible.
Thanks again for the opportunity to provide feedback in this consultation. If it would be of assistance, we would be happy to discuss our responses with you.
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