Current Development of Role of Associate in Psychology.

3 April 2025

Hon Matt Doocey,

Minister for Mental Health

By email: M.Doocey@ministers.govt.nz,

CC. Vanessa Simpson - Chief Executive / Registrar -  NZ Psychologists Board  

       vanessa.simpson@nzpb.org.nz      

   Leeanne Fisher – National Chief Mental Health and Addiction - Te Whatu Ora

       leeanne.fisher@TeWhatuOra.govt.nz

Dear Minister,

CurrentDevelopment of Role of Associate in Psychology.  

The NewZealand College of Clinical Psychologists (NZCCP) is supportive of expanding access for people in Aotearoa New Zealand to timely and effective psychological services. As you may be aware, our membership hold strong views with a significant portion being very concerned about the current proposal and a substantial group strongly opposed to any proposal to establish this kind of workforce. We believe that a major driver for those both for, and against, this proposal is to ensure that the population has access to safe and effective psychological therapies provided by suitably trained providers. We appreciate the care and attention that has been applied by the development team into addressing and mitigating the many issues that arise in development of the proposed newworkforce within the constraints of their brief.  The Executive of the College and some members remain supportive of the concept, but believe the following key issues mean that the current draft proposal will not be sufficiently safe and effective.

1. Role Title Terminology

You will bewell aware of the difficulty that the general public has with understanding the difference between various types of mental health professionals (e.g.,psychologists, psychiatrists, psychiatric nurses, mental health workers, etc.),and the potential confusions and risks that this creates. Use of the word“psychologist” in the title will increase this confusion by the public, leadingto the expectation that a member of the new workforce will have the same skillsas a fully trained registered psychologist. This issue can be mitigated by not including the word “Psychologist” in the title. If this role has the words“registered” and “psychologist” in its title, this will lead to confusion forthe public and undermining the existing registered psychologist workforce.  We are aware that discussion regarding the most appropriate title is ongoing, but we strongly recommend it not include theword “psychologist.”

At present,in much of the writing, the terms “Assistant” and “Associate” are used interchangeably but, internationally and locally, they indicate different levels of training and scope. For instance, in the UK, Assistant Psychologists aretrainees who have very circumscribed scope of role and work under close supervision of a psychologist, whereas an Associate in Psychology has undertaken a specific 18 month Masters-level training programme while working within services, and have a broader scope of role. The term Assistant Psychologist has been, and is, used in New Zealand to denote someone in anintern or pre-intern role, who is under close supervision. We understand that it is recognised in Te Whatu Ora that the kind of role being developed here isnot consistent with the way that “Assistant” is used in psychology or other health professions and is no longer being considered as the term of choice. While we understand that there has been a strong interest in producing an initiative that is unique to the particular conditions of Aotearoa New Zealand, we suggestthat if the term Associate is to be used then it is important to resource a level of training that is consistent with the international expectations and justifies use of that term.  

2.Training Pathway

As mentioned in the previous section, in the UK the training pathway to produce an Associate in Psychology capable of some level of prescribed independent work (with supervision) is an 18 month Masters-level qualification while working providing services in a suitable service. These people would typically have a minimum ofa Bachelors Honors qualification in psychology (or higher) prior to entry, so they have the grounding in psychology that is foundational to practicing in applied settings. People who are accepted into this training frequently have training and/or relevant experience that also helps to springboard them into performing this role safely and effectively. We understand that part of the proposed training pathway in this instance is that applicants have specific undergraduate courses that support their ability to work competently in the service setting, and think that this would be critical to have a sufficient background in key aspects relevant to the role prior to entry. We also understand that there are plans for a formal New Entry to Practice programme subsequentto completing the course as an integral part of the training. Again, we see this as critical to its success. We recommend that, to ensure effectiveness ands afety, all of training components will need to add up to a programme that has a similar length and depth as the UK programme.

You may be aware that the Australians recently “retired” a scheme that they had been running for some years, which involved taking Bachelors Honors level psychology graduates (4 years training) and having two additional years of on-the job training (a “4+2” model). This was stopped due to evidence indicating concerns regarding public safety and effectiveness, amongst other factors. This is at least as robust as the approach being proposed here, and therefore creates doubt about whether the proposed role would produce better or safer outcomes.

You willn ote that the UK model does facilitate early access to psychological services for the public. It utilises the pool of people who already have a strong foundational training in psychology and springboards them into being able to provide therapeutic and related services quickly, progressively working at a higher level as their skills develop. They are working in services from the time they start their Masters-level training for the Associate in Psychology training. This model would achieve the government’s goal of achieving more, and hopefully more equitable, access to psychological services for people in Aotearoa, New Zealand. The content could be tailored to the needs of Aotearoa while maintaining the degree of robustness.

We wish to further suggest that this training pathway should be able to operate as a stepping stone to prepare the 'Associates in Psychology' to later undertaket raining as fully registered psychologists. Amongst other advantages, we believe this is a useful method to help ensure that the composition of the psychological profession can better reflect the population they serve.

3. Scope of Role

One of the proposedbenefits of the Associate position is a strong focus on delivery ofevidence-based manualised therapies which are known to work well for manypeople with mild to moderate mental health difficulties. We note that thecurrent proposal includes tertiary services as one of its target areas, wheredifficulties tend to be severe. Furthermore, one of the potential risks is“role creep” in which practitioners use approaches in which they have not beentrained and which may have little or no evidence of effectiveness. The currentdescription of the proposed role is very broad, inviting the potential forineffective and unsafe practice. A tighter description of the scope of therole, deployment in services that do not serve the most unwell in our communities,and an emphasis on appropriate use of short-term evidence-based practice would likelyensure that a new workforce is able to contribute maximally to improving accessto psychological therapies and the psychological wellbeing of people inAotearoa New Zealand. We suggest that the New Zealand Psychologists Board becognisant both of this risk, and the importance of establishing clear competenciesand limitations for this role in mitigating this risk as far as possible.

4.Supervision

We understand that the current proposed approach requires supervision of a junior Associate in Psychology by a fully trained Registered Psychologist. We believe this will be critical to ensure that they are able to maximise their level of effectiveness and safety. Considerations for how this need will be met without significantly impacting on the capacity of current clinicians whilst ensuring adequate high level supervision will be important.  We understand that the current proposed approach would allow for a senior Associate in Psychology to be supervised by another senior Associate in Psychology. We suggest that supervision of junior Associates in Psychology by more senior Associates in Psychology creates significant risk as the proposed Associate in Psychology pathway may not provide a sufficient foundational base of learning to ensure their knowledgeand skill base is sufficiently robust for them to safely supervise more junior Associates.This may lead to something of a “Blind leading the blind” situation which puts both the public and the Associates at risk.

We would expect any proposal to have robust supervision by a registered psychologist asa mandatory component during training and in the early career stages to ensure the safety of the public and the clinicians. Ensuring that sufficient time ismade available for psychologists in services to undertake this supervision effectively will be an important compontent of any such initiative.

5.Culturally Safe and Responsive Workforce Development

We understand that efforts have been made to engage in co-design with hauorapartners, and several Kaupapa Māori services are interested in utilising these positions. However, we are yet to see how the proposed role and training programmes will ensure culturally safe clinicians, nor is there explicit acknowledgement about developing a workforce that is able to meet the needs of diverse communities. There is an imperative for the psychology profession to upholdr esponsibilities to the provisions of Te Tiriti o Waitangi. This necessitates meeting the health needs of Māori. To achieve equitable outcomes for Māori and communities with higher needs entails robust processes to ensure culturals afety. We are concerned that the proposed role and training pathway will be severely limited in its capacity to suitably develop cultural competence andsafety in clinicians.

The risks then are that we have clinicians who are ill-equipped to work with communities in need, exacerbating inequitable outcomes, rather than addressing them. Weacknowledge the longstanding policy goal that the health workforce reflects theethnic and cultural make-up of the population it serves. There is potential through this training pathway and role to foster a psychological workforce with greater representation of cultures and ethnicities. To achieve this we recommend that therebe an explicit strategic commitment to view and use the role as a ‘steppingstone’ to develop Māori participation and broader cultural participation in the psychology workforce.

Conclusion and Recommendations

We are aware that funding has been approved for 30 additional training positions for clinical psychologists in the next three years. We see this as a positive move to partially ease the lack of clinical psychologists in health and other social services into the future. We strongly encourage further work with Universities to increase their capacity to train more psychologists still, as much of the need is for those with severe difficulties, for whom the proposed Associate role would likely not be appropriate.

In summary,while we are supportive of expanding access for people in Aotearoa New Zealandto timely and effective psychological services, we are concerned that the model as has been proposed takes a concept successfully used overseas but then dilutes it to degree that has the potential to be ineffective and unsafe for the public. Many of our members are very concerned that the current proposal is not a safe way forward.  If any such proposali s to go ahead, we recommend that:

·      A more appropriate title that hasless overlap with more comprehensively trained psychologists may cause less confusion with the public than a title such as “Associate Psychologist”

·      Our recommendation is that training to a level that would be internationally recognised as an 'Associate in Psychology' would be preferable both for effectiveness and safety of the public.  This would be the something likea n 18 month Masters-level training for people with an appropriate Bachelors orHonours degree in psychology that contains necessary prerequisites. The elements in this training may differ in the Aotearoa context, but the quantumo f training should be similar.

·      This training would be undertaken concurrently with working in suitable services that serve those with less severe difficulties, so this approach meets the dual objectives of quickly increasing public access to safe and effective psychological services and increasing the workforce who have well-developed psychological skills and competencies.

·      Supervision of these trainees should be undertaken by fully registered psychologists to maximise their opportunity to develop, at least until they are well-developed in their skills and career.

·      We are understand that the 'Associate in Psychology' may best be registered through the Psychologists Board, to ensure that their practice is regulated by the Board and they are bound by a Code of Ethics, although we strongly suggest this to be under their own more restricted Scope of Practice. We believe the role of the Board in setting a Competencies framework that encourages a strong focus on evidence-based practice and clear limits is critical to ensuring safety of the public.

Thank you for your consideration of this letter. We would be happy to discuss these ideas with you in more detail

The Executive of The New Zealand College of Clinical Psychologists (NZCCP)

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