Investigation into the charging model for health practitioner registration fees
Learn more about our own motion investigation into Ahpra’s charging model for health practitioner registration fees
Ombudsman’s foreword to the report
My office has heard concerns from some health practitioners that the way they are charged registration fees has unfair financial impacts. These practitioners have rightly said that being charged a registration fee that is described as an ‘annual’ or ‘one-off’ payment more than once in the same year seems unfair.
Registration fees are a mandatory cost for practitioners seeking to work in one of the 16 health professions regulated by the Health Practitioner National Boards (National Boards). Health practitioners are not, however, immune from the cost-of-living pressures currently facing many Australians. In this context, the requirement to pay registration fees can contribute to financial stress.
The problem stems from practitioners being required to pay a registration renewal fee by a set date each year, regardless of when they were first granted registration. In effect, this means that a medical practitioner who paid an application fee and a registration fee in July, for example, would be required to pay a registration renewal fee by 30 September of the same year (totalling around $3,600 in fees within a 3 month period). However, a medical practitioner who paid the same application and registration fee in September would not be required to pay the registration renewal fee until 30 September the following year.
My office commenced this investigation to consider whether the charging model for registration fees in the National Registration and Accreditation Scheme (the National Scheme) is fair and reasonable. My investigation considered complaints received by my office, together with the Australian Health Practitioner Regulation Agency (Ahpra) and the National Boards’ rationale for their charging model as outlined in responses to complaints managed by my office and in public facing information available to practitioners.
My investigation found that the charging model can lead to unfair financial outcomes for practitioners registering outside of their profession’s standard registration cycle. It appears that certain practitioners are more likely to be negatively affected by the charging model, including practitioners taking or returning from parental leave, applicants registering for the first time and practitioners changing registration types.
We found that while some National Boards appear to have adapted how they charge certain registration fees to account for the negative consequences of the charging model, others have not. There were also different approaches taken to charging fees when practitioners change from one registration type to another during the registration cycle.
My investigation’s review of publicly available information about the rationale for the charging model found inconsistencies and inaccuracies in the information provided. Complainants also raised legitimate concerns about the clarity of information available in registration forms. Transparency regarding the charging model, and how it aligns with cost recovery principles, is necessary to ensure practitioners can trust that the National Scheme is operating efficiently and fairly.
My investigation’s review of other industry’s approaches to charging professional registration fees found that while charging models differ significantly, other regulators appear to have more formal mechanisms in place to minimise unfair outcomes. For example, we found it was common practice to charge registration fees for the legal profession on a pro rata basis (that is, based on the proportion of the registration cycle that the legal practitioner is registered for).
Charging registration fees on a pro rata basis would be one way to address the concerns raised by health practitioners. Ahpra and the National Boards have historically stated that they will not charge or refund registration or registration renewal fees on a pro rata basis.
In December 2024, however, I welcomed Ahpra’s announcement that it would commence a new project to “review and provide advice on a wider pro rata fees strategy, for consideration by November 2025” with recommendations to come into effect from 1 July 2026 (the Pro Rata Fee Review). The Pro Rata Fee Review was announced alongside Ahpra’s commitment to also:
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introduce a 30% rebate on annual registration fees for practitioners who take parental leave, or other protected leave, from 1 July 2025
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improve policies and practitioner experience when transferring between non-practising and practising registration, including capping the annual registration fee charged.
These commitments were made following the finalisation of Ahpra’s Parental Leave Review, and following receipt of my investigation’s proposed findings, which included a recommendation that Ahpra review its charging model. As a result, this report has been updated to reflect the positive steps taken by Ahpra to initiate the Pro Rata Fee Review, and to ensure my suggestions for improvement are responsive to these new circumstances.
I acknowledge that it is necessary for Ahpra and the National Boards to charge registration fees and this is enabled by the relevant law. But the way fees are charged must be fair.