Independent Practitioners and Employed Provisional/Registered Psychologists
This policy applies to all psychologists, mental health social workers, and provisional psychologists who consult from or are engaged by Paediatric & Perinatal Centre (trading as Paediatric, Perinatal & Adult Therapy Centre (PPATC)). It is drafted to clearly define the separation between PPATC as a service entity and independent practitioners, and to clarify responsibility for clinical services and complaints, including where provisional psychologists are employed by the practice.
1. Purpose
The purpose of this policy is to:
• Clearly outline how complaints are to be managed
• Ensure clients understand who is responsible for clinical services
• Confirm that PPATC does not provide health services via independent practitioners
• Clarify arrangements relating to employed provisional psychologists
• Demonstrate that PPATC operates primarily as a services and facilities provider
• Limit any actual or perceived vicarious liability of the practice entity and its directors
2. Nature of the Practice Entity
PPATC operates as a service entity that provides non-clinical services and, in limited circumstances, employs provisional psychologists.
The practice provides:
• Consulting rooms and physical facilities
• Reception and administrative support
• Appointment booking and practice management systems
Except where expressly stated in relation to employed provisional psychologists, PPATC does not provide psychological or mental health services and does not supervise or control the clinical work of independent practitioners.
3. Independent Practitioners
Psychologists and mental health social workers consulting from PPATC:
• Operate as independent contractors
• Conduct their own private practices
• Exercise independent professional judgment
• Hold and maintain their own professional registration (AHPRA or AASW)
• Maintain their own professional indemnity insurance
• Are solely responsible for clinical governance, informed consent, record-keeping, and complaints handling
Independent practitioners are not employees, agents, partners, or representatives of PPATC.
4. Employed Provisional Psychologists
The exception to item 3 is that at times, PPATC employs provisional psychologists who provide services under provisional registration, or Registered Psychologists undertaking a placement for a Masters Level psychology course.
These provisional and/or registered psychologists:
• Are employed by PPATC for administrative and payroll purposes
• Practice under the Psychology Board of Australia requirements
• Receive clinical supervision from external, independent supervisors
• Do not receive clinical supervision from the directors of PPATC unless otherwise stated in writing
External supervisors are solely responsible for clinical supervision, oversight, and guidance relating to clinical practice. Those employed by PPATC are clearly indicated on the practice website.
5. Responsibility for Clinical Services – Employed Provisional/ Registered Psychologists
Clinical services provided by provisional psychologists are delivered under provisional registration and external supervision. Clinical services provided by registered psychologists undertaking a Masters placement at PPATC are delivered under provisional registration and external supervision.
To the extent permitted by law:
• External supervisors retain primary responsibility for clinical supervision
• Provisional psychologists retain responsibility for their professional conduct and compliance with registration requirements
• PPATC does not provide clinical supervision or clinical direction
PPATC’s responsibility is limited to employment, administrative, and operational matters only.
6. Responsibility for Clinical Complaints
Complaints relating to clinical care will be managed as follows:
• Independent practitioners: complaints must be directed to the treating clinician (including complaints regarding fees and charges)
• Provisional psychologists & employed registered psychologists: complaints relating to clinical care will be managed by PPATC in conjunction with the provisional psychologist and, where required, the external supervisor (including complaints regarding fees and charges)
PPATC does not accept responsibility for the clinical services of independent practitioners and limits its responsibility for provisional psychologists to that required by law.
7. Complaints Relating to Practice Services
Complaints relating solely to practice administration, facilities, or operational matters may be directed to PPATC.
This includes:
• Reception or booking processes
• Administrative errors
• Facilities or accessibility
• Privacy matters relating to administrative systems
Such complaints will be managed by the Practice Manager or practice directors.
8. Separation of Liability and Insurance
To avoid doubt:
• Independent practitioners hold their own professional indemnity insurance
• Provisional psychologists & employed registered psychologists are covered under the practice’s insurance arrangements only to the extent required by law
• Practice directors are not responsible for the acts, omissions, or fees charged by independent practitioners
• No partnership, agency, or joint venture is created by these arrangements
The practice’s insurance coverage is otherwise limited to business operations, premises, and administrative services.
9. External Complaints and Regulators
Clients retain the right to lodge complaints with external bodies, including:
• AHPRA (for psychologists and provisional psychologists)
• The Australian Association of Social Workers (AASW)
• State-based Health and Community Services Complaints Commissioner
External complaints should be made in relation to the individual clinician wherever applicable.
10. Communication and Disclosure
This policy:
• Is made available to clients upon request
• Is published on the practice website
• Is incorporated into clinician and employment agreements
• Is reflected in client-facing information and consent materials
Clinicians are required to explain their role and professional status to clients.
11. Review
This policy will be reviewed periodically to ensure ongoing alignment with legal, regulatory, and insurer requirements.
Last review 11/1/2026
How to Make a Complaint
We are committed to ensuring concerns and complaints are handled respectfully, transparently, and fairly. The way your complaint is managed depends on who provided your care.
- Complaints About Clinical Care Provided by Independent Practitioners
If your care was provided by a psychologist or mental health social worker consulting as an independent practitioner, your complaint should be directed to that clinician. Note, almost all therapists at PPATC are independent practitioners. Please check the website if you are unsure.
Independent practitioners:
- Operate their own private practices
- Are responsible for their own clinical services (including fees and charges)
- Manage complaints in accordance with their professional obligations
Your clinician can explain their complaints process and the steps they will take to address your concern.
- Complaints About Clinical Care Provided by Provisional Psychologists & Registered Psychologists employed by PPATC
If your care was provided by a provisional psychologist they will be employed by PPATC, you may raise your concern with the practice. At times PPATC also employs registered psychologists completing a Masters level course in psychology. Please review clinician profiles on the PPATC website to clarify if a particular clinician is employed by PPATC.
Clinical complaints involving provisional psychologists or a registered psychologist employed by the practice will be managed by the practice in consultation with the provisional psychologist and, where appropriate, the external clinical supervisor, in accordance with regulatory requirements.
- Complaints About Practice Administration or Facilities
You may contact the practice directly if your concern relates to:
- Appointment bookings or reception services
- Billing administration
- Facilities or accessibility
- Administrative privacy matters
These complaints are reviewed by the Practice Manager and where necessary the practice Directors.
- External Complaint Options
You always have the right to raise concerns with external bodies, including:
- Australian Health Practitioner Regulation Authority (AHPRA) (for psychologists and provisional psychologists)
- The Australian Association of Social Workers (AASW)
- The Health and Community Services Complaints Commissioner (SA)
We encourage communication with the clinician concerned in the first instance.
- Our Commitment
All complaints are taken seriously and handled with respect. We aim to:
- Acknowledge complaints promptly
- Manage concerns in a fair and transparent manner
- Maintain privacy and confidentiality
- Use feedback to improve our services