Speech pathology regulation in Australia: progress, but more work to be done

Back in the news:

On 12 September 2025, Health Ministers released a communique, rekindling conversations about speech pathology regulation in Australia.

Among other things, Health Ministers agreed to:

regulate audiology under the existing National Registration and Accreditation Scheme (NRAS). This means audiologists will join occupational therapists, physiotherapists, and psychologists, as registered health professionals regulated by the Australian Health Practitioner Agency (AHPRA) in partnership with their (profession-specific) National Board; and
release Sue Dawson’s final independent review of NRAS report, recommending governments and regulators improve health practitioner regulation in Australia..

Colleagues have asked for my views. Here they are!

A. Current SLPs regulation is unsatisfactory:

SLPs are not registered health professionals under NRAS. This means we:

don’t have protected title;
are not regulated by AHPRA or a National Board; and
(arguably) don’t have the same access to regulators, or influence over health system policy discussions, as registered practitioners.

SLPs are self-regulated. This means:

Speech Pathology Australia (SPA) is both our regulator and our peak body;
SPA members pay annual fees to SPA to pay for both the regulatory and membership functions of SPA;
there is no legal requirement for our professional standards to meet registered professional standards – although, in practice, SPA’s rules and standards mirror registered professional standards in most respects;
complaints against SLPs are generally dealt with by SPA;
not every speech pathologist is a SPA member;
SLPs who are not SPA members:
- can still practice as SLPs, including in public health roles;
- are not subject to SPA ethics and professional standards, training requirements, or professional complaints processes; and
- unfairly benefit from SPA’s professional advocacy and other work for the profession (without paying for them); and
compared to registered professionals, SLPs are (arguably) disadvantaged in consultations about healthcare provider law reforms, e.g. potential mandatory NDIS provider registration requirements.

Most – but not all SLPs – are regulated by a statutory Code of Conduct:
- Years ago, state and territory Health Ministers agreed to implement nationally consistent Codes of Conduct for unregistered health professionals (based on the NSW Code). But not every state and territory has done so.
- The Codes set only basic standards. They are a form of complaint-driven, “negative licensing”, and are not well-understood by the general public.
Red tape and duplication: Most SLPs work in the healthcare sector. But SLPs also work across other systems, including disability, education, and aged care. Many SLPs working across sectors work with multiple regulators and need systems to comply with different sets of (sometimes duplicative) rules.
Overall, the patchwork of allied health professional regulations lack coherence. It complicates:
- multidisciplinary care models, and data capture/data sharing across the healthcare sector; and
- allied health provider business and care models, and regulation in the disability and aged care sectors.

B. Most SLPs (including me) want SLPs to be registered health professionals.

But there are obstacles:

Scheme sustainability: Almost every allied health profession wants its members to join NRAS because it gives them protected title and enhances their reputation. But NRAS already costs more than $300 million a year, and regulates close to 1 million professionals. Every time a profession is added, scheme costs and complexity increase.
Not “risky enough”: NRAS exists to protect the public from risks to health and safety – not to benefit professions. Governments use strict criteria to decide whether a profession should be granted statutory registration, including risk assessments. To date, governments have not been persuaded that SLPs pose significant enough risks to the general public to warrant registration.

C. A new pathway to registration?

Dawson recommends the addition of a new, ‘lighter touch’ Professions Registration Pathway within NRAS for health professions:

that pose lower – but still some – risk to the public; and
for which an uplift in standards would improve the quality and safety of care across the health system.

If implemented, this new pathway could address many of our current regulatory challenges.

D. How could it work?

If the speech pathology profession were granted access to NRAS through the proposed Professions Registration Pathway:

SLPs – along with other professionals granted access through the pathway – would be governed by a single Professions Registration Council, made up of people appointed by Health Ministers;
the Professions Registration Council would have the same status as the the National Boards that currently exist for each registered profession;
the Professions Registration Council would set standards:
- for a Responsible Professional Body – almost certainly SPA – to operate a register of SLPs, which would then be “curated” by AHPRA, and searchable by the general public;
- to separate SPA’s registration and membership functions;
- to mandate appropriate probity and qualifications checks for SLPs; and
- to create transparent registration fee-setting processes.
All SLPs delivering speech pathology services would:
- have to be registered;
- meet registration standards aligned with standards that apply to registered professions; and
- pay registration fees to meet AHPRA and Professional Registration Council costs.
AHPRA would perform compliance functions and establish a process to audit professions registration functions.
SPA would no longer handle complaints about SLPs. Instead, complaints would be referred to State Health Complaints Entities (such as the Health Care Complaints Commission in NSW), with access to profession-specific advice where necessary.

What’s next? National health law reforms in Australia are notoriously difficult to implement. Even if the Dawson recommendations for the new pathway are embraced by all Health Ministers:

it will probably take years to implement them; and
SPA (and the profession as a whole) have a lot of work to prepare for inclusion, starting immediately.

Bottom line:

Most SLPs want registration. SPA is to be commended for its advocacy to get us to this point. As always, details will matter, including the interaction of the Dawson proposals with reforms affecting SLP services and/or provider regulation within the NDIS, Thriving Kids, aged care, and education systems. Years of important work lie ahead of us.