For Attention:

Minister of Health: Dr Aaron Motsoaledi

Director-General of Health: Dr Ashley Bloomfield

Director of Public Entities Governance: Mr M Mushwana

10 December 2018

Response to Minister Dr Aaron Motsoaledi invitation for input on HEALTH PROFESSIONS ACT, 1974 (ACT NO.56 OF 1974) REGULATIONS DEFINING THE SCOPE OF THE PROFESSION OF PSYCHOLOGY, 12 September 2018.

Honourable Minister Motsoaledi

SIOPSA (Society for Industrial and Organisational Psychology of South Africa) is currently the only professional body representing the Industrial and Organisational Psychology profession in South Africa. Industrial-Organizational (I-O) Psychology is the scientific study of psychology in the workplace and the application of that science to workplace issues facing individuals, teams, and organizations. The scientific method is applied to investigate larger issues of critical relevance to individuals, businesses, and society (SIOP 2017). Our membership currently consists out of:

In order to provide context for our input, the following information must be considered.

Who are we?

1. We are behavioural scientists at work.
2. We work in consultancies, business firms, academia, public service, and government with other professionals, managers, and HRM specialists.
3. We are scientific researchers, strategic partners, enablers, developers and counsellors, watchdogs, and leaders.

What do we do?

1. We ethically combine the science of psychology with practice at work to the benefit of individuals, teams, and organisations.
2. As scientists-practitioners we aim to understand, measure, and change behaviour in the workplace in order to maximise employee and organisational potential.
3. We help, optimise, support, and improve productivity, social relations, and the wellbeing of individuals, teams, organisations, and the community.

Why do we do what we do?

1. We believe in people.
2. Our first responsibility is to balance organisational prosperity with human flourishing.
3. We understand that work forms an integral part of peoples’ lives, that organisations cannot survive without the commitment and contribution of people, and that it is only through work that we can make the world a better place for all.

How do we do what we do?

1. We interact with our clients to define the goals of the service we will provide.
2. If we do not already have the tools to deliver on the agreed goals, we design appropriate tools that meet rigorous standards.
3. We assess and diagnose to ensure that we implement interventions that will meet the needs of our clients.
4. We ensure that we evaluate the efficacy of our interventions so that we can learn and grow.
5. We provide information to clients in ways that are adequate to fulfil their needs.

What makes us different?

1. We apply psychological principles in the workplace.
2. We question the behavioural impact of business practices.
3. We think eclectically and integrate information.
4. We have unique training in understanding and changing behaviour at work.
5. We have a scientific orientation and systems perspective to people practices in the workplace.
6. We protect the interests of people in the workplace.
7. We use psychometrics to understand, measure and predict behaviour.
8. We focus our energy on transformational, strategic, and grow issues.

SIOPSA has participated in the Scope of Practice debate since 2010 and has at numerous occasions given input.

Timeline of Process

• In 2011 the Western Cape High Court found that the published Scope of Practice Regulations was unlawfully promulgated, that not all parties were consulted, and that new regulations had to be drafted following the correct process
• All interested parties were invited to make submissions on the redrafting of the 2011 Scope of Practice regulations for the Profession of Psychology
• SIOPSA gave extensive feedback on the SoP in 2012
• SIOPSA made a presentation to the HPCSA on 22 June 2017 after a lengthy and in-depth consultation with its members
• A newly proposed draft set of regulations was published on 12 September 2018
• All interested parties are invited to comment by 12 December 2018
• Based on the published draft regulations of 12 September 2018, it is clear that most of the inputs of various parties have not been considered. SIOPSA strongly objects to the omission of the inputs of various stakeholders and will submit a response document to the HPCSA by said deadlineDuring this entire period, SIOPSA has never received any feedback from the HPCSA or Board of Psychology. Our previous feedback remains as relevant, but cognisance must be taken that the landscape is continuously evolving. Restricting the Scope of Practice to such narrow descriptive categories, will not serve the needs of the country.

Further to the above steps, SIOPSA again embarked on a process to consult with its members for additional input to the latest proposed published regulations.

In addition to previous input, the main themes emanating from members’ feedback are the following:

Themes

• The published regulations are very vague in the sense that they give vague descriptions without clarifying what is meant. Some participants felt that the 2011 Scope was more descriptive and clear.
• The majority of the members did not feel that the current description of the Psychological categories is accurate and acceptable.
• The majority of members did not feel that the process of consultation was effective or representative, and was extremely concerned that previous inputs had not been taken into consideration at all. There is the perception of favouritism and that only certain groups are heard – e.g. Clinical Psychologists.
• Although there is a concern about the lengthy duration of the process, it cannot be rushed, as a lot is at stake.
• Industrial Psychologists should be allowed to “assess, diagnose, evaluate and treat psychological problems” and to “deliver a range of therapeutic interventions in treating mental, behavioural and cognitive disorders”, as per the scope for clinical psychologists, provided we can demonstrate competence in these areas. Similarly, psychologists who are not Industrial Psychologists should only be involved in “enhancing the behaviour and functioning of people, groups and organisations” if they can demonstrate competence in this area.
• There is a lot of overlap between categories where a field of work does not exclusively belong to one category
• The Scope of the IOP is limited to only work-related problems and does not acknowledge that personal problems have an impact in the workplace and that one does not exist in isolation from the other. Yet, other categories may deal with work-related problems in addition to personal problems. Burnout is probably also considered pathology which resorts under the Scope of Clinical Psychology, but IOPs are better equipped to deal with burnout than Clinical Psychologists.
• There is a blurred scope of practice when compared to psychometrics, and clarifying psychological acts that are specific to IO Psychologists.
• The current formulation of the IOP and Psychometrist scope of practice appears to limit the use of psychometric assessments to Psychometrists only, whereas the use of psychometrics forms a fundamental component of IOP work in many instances. There is also no reference to the control of psychometric assessments, or options regarding delegation of some aspects of using assessments.
• It is not clear where psychometric assessments fall within the scope. There is mention made of assessment, and it can be assumed that this will include psychometrics but it is not explicit. More clarity on this is needed.
• Psycho-legal work (earnings and earnings potential, career and career progression, loss of earnings – for children and adults), are not just areas for clinical psychologists. As things stand at present, with this having been the situation for the last 40 or so years, it is the IO Psychologists who are accepted by the Courts as experts.
• Psycho-legal and neuropsychology aspects of the profession are not included.
• Currently, the category for IOP does not make provision for research capacity and mandate, as well as being able to develop and utilise Psychometric assessment tools and techniques, oversee other human resource practitioners and provide advice and consultation to organisations of any size. IOPs should be able to work as expert members in multi-disciplinary teams.
• No mentioning is made of supervising research or interns.
• Owing to the impact and prevalence of trauma, anxiety and depression which are prevalent in the workplace, industrial psychologists should also be able to do basic counselling for low-intensity situations. This falls into the employee well-being domain. Additionally, industrial psychologists should be responsible for developing psychometric assessments.
• Current scope renders IO Psychologists as merely HR practitioners who can also do psychometrics. IOP is psychology (Strümpher) and should be scoped as such to allow private practice and medical aid claims, depending on training. Where is the biggest portion of individuals with early psychological problems concentrated? Workers in the workplace. If training the psychology part is the problem, fix the curriculum so IOPs can be psychologists.
• Recognition is not given for further training. For example, IOPS, with further relevant training, are excluded from working with GEMS and POLMED.  Thousands of policemen cannot get help because of the limits and exclusions in the scope of practice.
• The scope of practice is quite vague with regard to coaching interventions, wellness, stress management and work-life balance. Intervening/ assisting employees with regard to occupational stress management and work-life balance often include coaching/counselling interventions related to mild psychological problems and work dysfunctions. These should be specifically included as acts that an IOP may perform. A relevant statement may read as follows: “Intervening through coaching or counselling to prevent or alleviate mild psychological problems and work dysfunctions that impact on occupational functioning.”
• The current description includes activities that are not strictly psychological in nature. It should be focused on the psychological side of what industrial psychologists do. The proposed scope makes the profession a target for litigation from coaches and management consultants, who are not regulated.
• It might be meaningful to divide the scope of practice of industrial psychologists into their sub-disciplines, namely career psychology, consumer psychology, forensic industrial psychology, organisational psychology, personnel psychology, ergonomics (including other emerging sub-disciplines). In that way, the cumbersome task of listing every single practice of industrial psychologists are more eloquently addressed.

In addition to the national input feedback above, a work session was held in PE on 16 November to discuss the proposed changes, and the Regional Chair of the Eastern Cape Branch submitted the following input:

Point 1:

• Assessment and diagnosis only briefly mentioned in point i) and not elaborated on significantly.
• There is no mention about design, development, standardisation and implementing of tools which should be in the scope.
• The role of the psychometrist should also be included in the scope.
• Nothing is mentioned about potential or suitability.
• Generally, it is felt that point i) is well worded and the members like the addition of meaningful, enriching work & facilitation of organisational flourishing.

Point 2:

• “ intervening in issues of critical relevance for organisations….”
• Point ii) of the new scope probably spells this out better than the previous scope, but it is felt that we need to understand the implication of the term “intervening in” vs the previous terms of facilitating /designing & implementing.   It needs to be more clearly clarified.
• Consumer behaviour is not mentioned anywhere in the new scope.
• The issue of advising on the development of policies, based on psychological theory & research… in the previous scope, is probably only partially covered in point ii) of the new scope, but doesn’t specifically refer to advising on policy development based on psychological theory and industrial psychological theory and industrial psychology intervention programs.
• It is noted that there is no mention anywhere in the new scope of the training and supervision of other registered psychology practitioners in industrial psychology.  Is this not an important part of our role as IOP’s?
• It is particularly concerning that there is no mention of providing expert evidence and/opinion – this potentially could exclude all psycho-legal work.
• General comment around point ii is that members are not sure that it calls out the unique contribution of IOP.  There are a lot of other HR practitioners that are doing the work covered in this point and it definitely does not reflect our unique domain.
• What about psychometric assessment – not mentioned?

• Extracted from the new scope:

• No person shall perform any act deemed to be an act pertaining to the profession of psychology unless he or she is registered in terms of the Act in the relevant registration category of psychology.
• A person who contravenes regulation 3a) shall be guilty of an offence and on conviction liable to a fine or to imprisonment for a period not exceeding 12 months, or to both a fine and such imprisonment.
• Comment: The general feeling is that if this is the case and if this is reflected in the new scope, they are going to have to fine or lock up the entire non-IOP HR community (not to mention line managers involved in these processes) since i) and ii) is not unique to IOP.

IOP Uniqueness that is not reflected in the new scope and should be, as well as final comments:

• The words in the new scope are quite flowery and trendy
• The word flourishing is very aspirational, when we live in a world of toxicity
• What the psychological principles that we are going to use to get there?
• There is a largely paradoxical element as point ii describes HR as well as what unions do and line management.
• There is ambiguity around psychometrics – this is vague.
• Boundaries need to be clear on what IOP’s can do with assessments.  We need to stay in our lane to know who we use assessments for at work.
• The point of departure for different psychologists needs to be specified differently.
• Why is Consumer Behaviour not mentioned?  Does this not close doors to the IOP profession?
• It is advisable to look at the American scope of practise – SIOP and use this as a benchmark.
• A broader list of general competencies should be indicated in the new scope
• Who has the right to enter into Private Practice? This is not covered?
• IOP’s role is to enter the workplace with a specific mandate of advising.  With the broad objectives indicated in the new scope, what is the implication for business.  Our role as consultants should be clearly spelt out.
• We are behavioural specialists and scientists and we understand behaviour as it links to performance.  How we make sense of this and connect the dots and how this plays out in the world of work, doesn’t reflect in the scope.

Recommendations

SIOPSA has consulted with its members, other similar professional bodies and interest groups. It is therefore recommended that:

• The Scope of Practice / Profession be revisited and ALL parties’ inputs be considered equally and fairly. The work has been done but has regrettably been ignored.
• The current proposed regulations need to clarify in more detail what each category means in operational terms.
• Provision needs to be made for category overlap, multi-disciplinary and multi-complex work contexts.
• Provision needs to be made for further training, and recognition of further training in relevant related areas.
• It must be recognised that competency training forms an integral part of every psychology category, which enables psychologists to work across categories. The key criteria are that every psychologist must be able to illustrate competence. In addition, psychologists are governed and guided by a strong ethical code of conduct.
• The Board of Psychology must be representative of all Psychology categories in equal measure so as to ensure equality and fairness.
• It is strongly recommended that the HPCSA gives each respective professional body the mandate to unpack the regulations in operational terms for the relevant Psychology category it represents.

Prof Crystal Hoole

SIOPSA EXCO Member: Professional Practice