Moves to restore trust in Australia’s health practitioner regulation system have been laid out in a federal consultation paper, responding to stinging feedback from doctors, consumer groups and state complaints bodies who say the system is opaque, disjointed and distressingly delayed.
The proposals, outlined in a second-phase consultation review [link here] led by former NSW Health Care Complaints Commissioner Sue Dawson, pushes for faster, fairer and more transparent investigations by AHPRA and the national boards
The recommendations fall under one of four key reform themes emerging from a wide-ranging review of the National Registration and Accreditation Scheme (the National Scheme). Consultation Paper 2 marks the final phase of the review, following nationwide stakeholder input and 83 written submissions.
A broken complaints system
“It would be hard to overstate the breadth and depth of dissatisfaction with the current complaint handling and notification processes,” the report states. “These processes are not meeting the basic expectations of health practitioner regulation in Australia.”
At the centre of the reforms is a plan to streamline how complaints are received and managed across jurisdictions. A new National Health Complaints System Implementation Group would lead a three-year project, beginning with a “single front door” model for lodging complaints in each state and territory.
One entry point, multiple regulators
Patients and practitioners are often left guessing where to lodge complaints. Depending on whether it involves a practitioner, an unregistered worker or a health service, processes and timeframes can vary wildly – with many cases bouncing between AHPRA and Health Complaints Entities (HCEs) for months before reaching the right body.
The “single front door” approach aims to fix that by giving consumers one entry point – likely through the jurisdiction’s HCE – regardless of the complaint type. Regulators would be responsible for triaging and directing it to the appropriate agency.
“Under the ‘single front door’ concept, the hard work of navigating the complaints system must be done by regulators – not complainants or notifiers,” the report notes.
Stakeholders say the model could speed up resolution, cut confusion and better align complaints with appropriate processes – especially for the 85-90% of cases that do not require formal disciplinary action.
Only Queensland and NSW currently use this model. Other states would need legislative changes, additional resourcing and, in some cases, a complete overhaul of their complaints systems. “The adjustments required would not necessarily be minor,” the report notes.
The National Health Practitioner Ombudsman supports the idea in principle but warns it depends on robust risk tools and reliable referral pathways. HCEs are enthusiastic but acknowledge the risks.
Meanwhile AHPRA has pushed back on the idea of handing over its triaging role to state-based HCEs, arguing that inconsistent capabilities could slow things down, not speed them up. The regulator has instead floated a narrower fix – tightening the National Law to reduce the number of matters that can be notified to AHPRA in the first place, and allowing those acceptance decisions to be made administratively rather than by National Boards.
But the review is unconvinced by AHPRA’s proposed workaround, noting that legislative tweaks alone won’t resolve the structural confusion. It instead backs a nationally consistent model with shared responsibility between AHPRA and state complaints bodies.
Delays and silence: AHPRA’s investigation backlog
Doctors have long warned that AHPRA investigations, particularly in high-risk cases, can stretch on for years with little communication and devastating personal consequences.
Despite internal targets of 6–12 months for resolution, recent figures show one in four investigations remains open for more than two years. The average time to complete an investigation has blown out by more than 50% since 2018.
“It is profoundly unfair on practitioners generally, let alone those found to have no case to answer at the matter’s conclusion,” the review states.
Part of the problem, it says, is that the National Law sets no firm time limit for investigations – and no limit on how long immediate action orders, such as suspensions or conditions, can remain in place. A practitioner can be sidelined for years with no final outcome, unless the matter is overturned on appeal or the board decides to lift the restrictions.
While there are procedural safeguards, including a ‘show cause’ process and the right to appeal, the review calls them “manifestly inadequate” in light of the stakes involved.
To address this, the review calls for an audit of all investigations open for more than 12 months, tighter rules around when cases can be placed “on hold”, and an overhaul of internal case management — prioritising high-risk matters involving sexual misconduct, mandatory reports or immediate action.
When clinical input misses the mark
Another flashpoint is the quality of clinical advice relied on during investigations.
Practitioners told the review they were being judged by advisers whose qualifications were unclear and, in some cases, irrelevant. The review also pointed to low payment rates as a key barrier to attracting qualified clinical experts, noting that other state-based regulators offer significantly higher remuneration. This disparity, it warned, is leaving AHPRA with a patchy and under-resourced advice system.
The review recommends disclosing the identity – or at the least, qualifications – of advisers to the practitioner where appropriate, and making it clearer how clinical input has influenced decisions. Importantly, the review urges AHPRA to review and increase payment rates for clinical advisors to ensure the system can attract and retain appropriately skilled and experienced professionals, particularly in smaller or highly specialised fields.
Calls for a fairer tribunal process
Tribunals also came under scrutiny. In Peers v Medical Board of Australia, the Victorian Supreme Court criticised the three-year gap between a doctor’s suspension and resolution, calling it “unfortunate, to say the least”.
To prevent lower-level breaches from clogging the tribunal system, the review supports giving more power to performance and standards panels. These panels, made up of practitioners and community representatives, can currently deal only with minor matters – they cannot suspend a practitioner or handle serious misconduct.
Boards are often compelled to escalate even technical breaches to a tribunal. The review recommends legislative changes to expand panel powers and give boards more discretion. It also supports appointing an independent Director of Proceedings, as used in NSW and Queensland, to help make consistent decisions.
What happens next
Health ministers are now being asked to endorse the Implementation Group and fast-track several reforms, including communication upgrades, KPIs and clearer appeal rights.
“A unified national complaints handling system is achievable and worthwhile,” the report concludes. “Particularly if AI-enabled triaging and risk assessment can be deployed.”
Further findings are expected later this year from the National Health Practitioner Ombudsman’s parallel investigation into AHPRA’s use of immediate action powers – as flagged in the limbic’s earlier reporting [link here].