The current rule
Every therapy team must include at least one member registered as: a clinical psychologist holding an area of practice endorsement, a medical practitioner, a nurse with mental health experience, or an occupational therapist. Within psychology, only endorsed clinical psychologists qualify. Most registered psychologists cannot fill the role, whatever their training, supervised experience or clinical trial work.
The October 2025 draft
"The PAT dyad must include at least one therapist who is registered with a National Board with regulatory oversight of psychotherapy, specifically, the Psychology Board, Medical Board, or Nursing and Midwifery Board."
No endorsement requirement. Under that wording, any registered psychologist would have qualified.
Between the draft and the final rule, something shifted. The consultation feedback pointed the other way. Of 29 stakeholder responses, 15 agreed that other health practitioners should be considered for the lead therapist role, 9 disagreed, and 5 were unclear. In the TGA's own October 2025 outcomes paper: "Only around one third of respondents supported the current therapy dyad model."
Respondents included state health departments, Authorised Prescriber psychiatrists, peak professional bodies and research ethics committees. The TGA's internal brief recorded that most respondents advocated for broader inclusion, citing rural and regional access, workforce shortages, and culturally safe models of care.
The TGA's stated reasons for holding the line were two: no National Board has an approved program of study, endorsement or category of registration specifically designed for psychedelic-assisted psychotherapy, and the absence of statutory powers for self-regulating professional bodies such as PACFA or the ACA.
Both points were equally true in October 2025, when the TGA proposed the broader rule. And the first point cuts both ways: clinical endorsement is not a psychedelic-assisted therapy qualification either.
