A M A P P

Why are psychologists treated differently?

A consultation on TGA rules for psychedelic-assisted therapy

Submissions open 19 August to mid-October 2026

Our mission To create a trusted and ethical space for psychedelic-assisted therapy practitioners to thrive. By providing peer support, advocacy, educational opportunities and resources, we strengthen a movement that honours healing, integrity, and the useful role of psychedelics in helping address mental health problems and the maintenance of a healthy society.
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What changed

In May 2026, the Therapeutic Goods Administration (TGA) confirmed a new rule on who can serve on the therapy team for psychedelic-assisted therapy, and it took effect in the TGA's published guidance in June 2026.

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.

Seven months earlier, the TGA's own draft was broader:

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:

  1. No National Board has an approved program of study, endorsement or category of registration specifically designed for psychedelic-assisted psychotherapy
  2. 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.

What this means

For practitioners

The endorsement requirement closes the mandatory role to most registered psychologists. An endorsement requires an approved postgraduate qualification plus a 3,000-hour supervised registrar program, a commitment of several years, and it contains no psychedelic-assisted therapy content. Many psychologists already trained in trauma-focused and somatic work cannot fill the role because they do not hold it.

For patients

Fewer eligible practitioners means narrower access, longer waits and higher costs, and the effect lands hardest in regional Australia, where the consultation itself said workforce is thinnest.

For teams

A team needs at least one member from the four listed registrations. A generally registered or counselling psychologist working with a social worker, counsellor or psychotherapist cannot form the minimum team, because none of them can fill the required role. Established multidisciplinary partnerships, including teams built through clinical trials, may not be able to continue in their current form.

For regulatory consistency

The four professions face four different thresholds: endorsement for psychology, general registration for medicine, registration plus mental health experience for nursing, and registration alone for occupational therapy. In the consultation record, the Medical, Nursing and Midwifery and Occupational Therapy Boards each supported their general registrants in the role. Psychology alone was narrowed to an endorsement gate.

What should change

AMAPP is asking the TGA to reconsider the current rule and return to its own October 2025 position: any registered psychologist should be able to fill the required role on the therapy team, with suitability determined by demonstrated competency rather than title.

This is not a radical ask. It is what the TGA's own draft proposed. It is the direction most consultation respondents supported. It is how the same review treated medicine, nursing and occupational therapy. The same evidence will go to the Psychology Board of Australia, whose advice shaped the rule and whose own wording makes it provisional.

In their own words, the settings are provisional
The Psychology Board's advice to the TGA was framed to apply "until evidence base grows". The TGA describes access as "strictly controlled while the evidence base develops". We are asking what evidence would change the rule, and we are gathering it.

How you can help

Your submission matters. We are collecting perspectives from:

  • Registered health professionals (psychologists, psychiatrists, GPs, nurses, occupational therapists and others)
  • Practitioners in self-regulated professions (counsellors, psychotherapists, social workers)
  • People with lived experience, consumers, carers and family members
  • Researchers, professional bodies and advocacy organisations

How submissions work

You control everything

Your submission is confidential. You choose two things:

1. Public or private?
Your words go to the regulators (public) or stay with AMAPP (private). AMAPP always includes your voice in the overall report. If you choose private, your individual submission never leaves AMAPP.
2. Named or anonymous?
Your identity can be named, anonymous, or described in general terms (for example "a registered psychologist"). This choice affects only the TGA submission, never public campaign material.

What happens to your words

  • All submissions are reviewed by AMAPP before anything is lodged with the TGA and the Psychology Board of Australia
  • We reserve the right to withhold any submission that is abusive or would put anyone at risk. If yours is affected, we contact you.
  • If you choose public, your words may be quoted in campaign material, but only if you give permission, and never with your name unless you explicitly consent to that too
  • If you choose private, your words are read by AMAPP only. They shape our overall report. They never appear anywhere else.
Two weeks notice
Before we lodge the compilation with the TGA and the Psychology Board, every contributor gets two weeks notice. You can withdraw or amend your submission during that window.

Data security

  • Submissions are stored in AMAPP's own secure Google account
  • Access is restricted to two named AMAPP key-holders, with one Board member holding governance oversight under a signed confidentiality agreement
  • Data is held for seven years in line with AMAPP's records policy, then securely destroyed
  • Nothing is forwarded to personal emails or personal drives

Publication safeguards

This campaign is about public health policy, workforce competency and regulatory review, not the promotion of psychedelics or services. AMAPP's public material:

  • Is factual, balanced, and focused on the TGA's published decision and the consultation record
  • Does not promote psychedelics, psychedelic medicines, clinics, practitioners, or commercial services
  • Does not present submissions as treatment testimonials or promotional claims
  • Respects Ahpra advertising requirements (no misleading advertising, no prohibited testimonials, no unreasonable expectations of treatment benefit)
  • Respects TGA requirements (no public advertising of Schedule 8 medicines, including MDMA and psilocybine)

AMAPP retains final editorial discretion. Material appropriate for the TGA submission may not be suitable for public campaign channels. Even anonymised quotes are reviewed for identifying details before publication.

Share your submission

Use the form below to submit your perspective. It takes 5 to 10 minutes. Your submission will inform AMAPP's consultations with the TGA and the Psychology Board of Australia.

Your privacy is protected

Public or private: you choose whether your individual words go to the regulators or stay with AMAPP only.

Named or anonymous: you decide how much of your identity travels with your submission.

Quoting consent: you control whether AMAPP can use your words in campaign material.

Withdrawal: you can withdraw or change your submission any time before lodgement, and everyone gets two weeks notice first.

To protect our community, please:

  • Do not promote psychedelics or psychedelic medicines
  • Do not name or promote clinics, practitioners or commercial services
  • Do not frame your submission as a treatment testimonial or a claim about treatment benefits
  • Keep it about policy, workforce, competency and access: that is what the TGA can act on

If the form does not appear above, open it directly at this link, or email your submission to info@amapp.org.au.

Questions?

Email info@amapp.org.au with any questions about the campaign, the form, or your submission.

Timeline

19 August 2026
Submissions open. Share your perspective.
Mid-October
Submissions close. AMAPP begins review and compilation.
Mid-to-late October
All contributors receive two weeks notice, with the chance to withdraw or amend.
Late October / November
AMAPP lodges the compilation and overall report with the TGA and the Psychology Board of Australia.

Why Are Psychologists Treated Differently? A campaign by AMAPP

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This campaign concerns public health policy and regulatory review. All material is factual, balanced and non-promotional. AMAPP does not provide clinical advice and does not promote access to unapproved medicines.