An investigation by the National Health Practitioner Ombudsman has concluded that AHPRA’s annual fee model unfairly disadvantages women returning from parental leave.
A new report from the office of the National Health Practitioner Ombudsman takes AHPRA to task for a quirk in its yearly registration fee system that sees some doctors pay up to $3,600 in fees within a three-month timeframe.
AHPRA appears to have sought to delay the release of and alter the contents of this report, having requested a “pause” to the investigation following announcements in December 2024 and then insisting on a several-month-long consulting process.
“In response to the investigation’s initial proposed findings, [AHPRA] stated that while it accepted it is appropriate that the Ombudsman includes information regarding complaints about the charging model in this report, it was concerned that including information about other fee related complaints ‘tends to inflate the overall level of concern from health practitioners about the charging model’ and is misleading,” the report said.
While the ombudsman acknowledged that the number of complaints received by the office in relation to fees was relatively small, she opted not to acquiesce.
“The Ombudsman has not changed the data outlined above regarding the complaints received by her office about fees in response to Ahpra’s concerns,” the report said.
“This is because the data is factual, and the accompanying text places the data in the appropriate context.”
The registration problem
Under the current system, all practitioners must pay an annual registration fee by a set date each year, regardless of which point in the year they are granted registration.
For doctors, this is 30 September.
This means that a doctor applying and registering in July of 2025 would have paid the application fee of $1548 and the 2024-25 registration fee of $1027, only to be hit with the 2025-26 registration fee of $1058 less than three months later.
Each year, a small number of practitioners find themselves in this boat. An even smaller number choose to take their frustrations to the National Health Practitioner Ombudsman’s office.
National Health Practitioner Ombudsman Richelle McCausland’s report ultimately found that not only did AHPRA’s charging model led to unfair financial outcomes for some practitioners, but that the practitioners most likely to be affected were those taking or returning from parental leave, applicants registering for the first time and practitioners changing registration types.
One female medical practitioner, a registrar, took 12 months of unpaid parental in July 2023.
As detailed in the report, she intended to return to work in July 2024 but discovered she would have to pay the full year’s registration fee of $995 despite only working for three months of it.
“The practitioner advised the Ombudsman that she is a part time trainee on a registrar wage,” the report said.
“If she returned to work in July as intended, she would be $200 worse off than if she delayed her return to work to align with the standard registration cycle.
“The practitioner noted, however, that if she chose to delay her return to work, she would not meet her specialist training requirements, which would delay completion of her fellowship at a substantial financial cost.
“Aside from these personal implications, the practitioner said that the current charging model disincentivises a timely return to the workforce and delays completion of specialist training, which has negative implications for patients struggling to access healthcare.”
The registration solution
The obvious solution to this issue would be to allow pro-rata payment of fees; a practitioner registering in the middle of a registration year, for example, would only pay half the regular fee.
There are multiple reasons why AHPRA does not do this.
Until July of 2024, AHPRA’s website stated that the National Law, the law that governs APHRA, does not allow for fees to be pro-rated or make provision to partially refund fees.
The NHPO noted this as a concern, given that the National Law is silent on how registration fees should be charged.
“[AHPRA] has explained that the information published on its website was intended to answer common questions about fees in plain English,” the report said.
“[AHPRA] outlined that it was not its intention to suggest that the National Law precludes it from offering pro-rated fees.
“Rather, it intended to provide information to practitioners about why pro-rated fees are not available, including confirmation that there is no specific obligation for [AHPRA] to charge fees on this basis.
“The Ombudsman does not agree with this reasoning.”
AHPRA also argues that the yearly charging model provides “revenue stability and financial forecasting avenues” and ensures administrative efficiency.
AHPRA’s response
Technically, the regulator has already taken several steps toward managing these issues.
In May 2024, once the NHPO investigation was already underway, AHPRA commenced a review into the charging of registration fees in relation to parental leave.
The draft findings of the NHPO report were provided to AHPRA in September of that year.
AHPRA then advised the ombudsman that the recommendations of its Parental Leave Review Committee were being considered by the National Boards and requested an extension of time until 13 December 2024 to provide a response to the ombudsman.
On 9 December, AHPRA announced that it would introduce a 30% rebate on annual registration fees for practitioners who take at least six months of parental leave.
It also announced that it would commence a wider review looking at the possibility of introducing pro rata fees, to be delivered by November 2025.
“It is the Ombudsman’s view that greater transparency is central to enhancing accountability and assuring health practitioners that [AHPRA] has heard, and is responding to, the issues raised with the Ombudsman,” the report read.
“This is particularly important because [AHPRA’s] review of its approach to pro rating fees has not yet been delivered.”
