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VMHPAA raises consultation integrity concerns with Minister Butler regarding National Standards consultation

MEDIA RLEASE / AWARENESS STATEMENT / PUBLIC RESPONSE

For Immediate Release

20 March 2026


VMHPAA raises consultation integrity concerns with Minister Butler regarding National Standards consultation
VMHPAA raises consultation integrity concerns with Minister Butler regarding National Standards consultation

The Vocational Mental Health Practitioners Association of Australia (VMHPAA) has today written to the office of the Hon Mark Butler MP, Minister for Health, Ageing and Disability, to raise concerns about aspects of the current Commonwealth consultation on regulatory options to support implementation of the National Standards for Counsellors and Psychotherapists.


VMHPAA Chair Shane Warren said the Association supports the intent of nationally consistent standards that protect consumers and lift practice quality, but has raised concerns about consultation design choices that may affect the reliability and representativeness of feedback captured from those most directly affected by the outcomes.


“VMHPAA does not question the professionalism or credibility of the consulting group administering the survey,” Mr Warren said. “Our concerns relate to consultation methodology and process integrity because the quality of the data gathered will shape policy settings that impact workforce capacity, access to care, and consumer clarity for years to come.”

Concerns raised by VMHPAA


In the correspondence, VMHPAA outlined five consistent concerns reported by members:


  1. Risk of response bias and repeat submissions including the need for clear safeguards to prevent multiple completions by the same individual and to protect dataset integrity.

  2. Survey complexity and practitioner drop-off including the risk that complexity excludes time-poor practitioners and reduces representation, and the value of publishing commencements vs completions.

  3. Leading question risk / implied problem framing including the importance of neutral framing so responses are not unintentionally “loaded.”

  4. Sample breadth vs professional specificity including the need to transparently segment and analyse results by respondent type so practitioner impacts are not diluted.

  5. Transparency and representativeness of consultation sessions including clarity about ballot selection processes and cohort composition to ensure fair representation across the current workforce - vocational and higher-education pathways; metro and regional practice contexts; community and private settings; culturally diverse and lived-experience pathways.


Requests to strengthen trust and usefulness of findings


VMHPAA has asked the Minister and Department to provide practical clarifications that would strengthen confidence in the consultation and improve the interpretability of findings, including:


  • confirmation and clear communication of anti-duplication safeguards

  • publication of basic participation metrics (commencements vs completions / attrition)

  • reporting that distinguishes between evidence-based risks, perceived risks, and risks potentially influenced by instrument framing

  • transparent segmentation of findings by respondent category e.g., practitioner, supervisor, employer, consumer, other health professional, general public

  • a brief explanation of the ballot selection process and consultation cohort composition in aggregate, including steps taken to ensure representation across the breadth of the current workforce


Background


The Commonwealth consultation is currently open and closes Friday 20 March 2026. VMHPAA is continuing to encourage practitioners to participate so government hears directly from the sector.


“Consultation integrity matters,” Mr Warren said. “This is not a narrow professional issue, it is a community access issue. We want a trusted process that supports evidence-informed decision-making and protects access to safe, affordable care, particularly in regional and rural Australia.”

Media Contact:

Shane Warren, Chair

Susan Sandy, Secretary

Philip Armstrong, CEO



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