Defining Therapy Supports: Consultation with the Allied Health Sector
Psychotherapy and Counselling Federation of Australia Submission
About PACFA
This response is written by the Psychotherapy and Counselling Federation of Australia (PACFA), the leading national peak body for the tertiary-qualified counselling and psychotherapy profession. With more than 11,000 members, PACFA provides registration and quality assurance services for counsellors nationally.
PACFA is grateful to the Department of Health, Disability and Ageing for the opportunity to contribute to the allied health sector consultation on defining therapy supports. PACFA’s workforce of tertiary qualified counsellors is committed to supporting the NDIS in accurately assessing and responding to the mental health needs of Australians living with a disability. PACFA supports the proposed categorisation of therapy supports and welcomes the opportunity to outline how counselling can assist the NDIA in meeting participants’ general and social support needs.
PACFA members designated as Registered Clinical Counsellors, Certified Practising Counsellors and Registered Clinical Psychotherapists are fully qualified allied health practitioners as recognised by PACFA’s full membership of Allied Health Professionals Australia (AHPA). PACFA is a qualifying member of the National Alliance of Self-Regulating Health Professions (NASRHP).
In this response the terms “counsellor” and “psychotherapist” can be used interchangeably to refer to tertiary qualified allied health professionals registered with PACFA as Certified Practicing Counsellors (entry level), Registered Clinical Counsellors (full Scope of Practice) and Registered Clinical Psychotherapists (extended Scope of Practice).
About PACFA Counsellors
PACFA registration allows employers and funding bodies to recognise verified counsellors who meet high professional standards to support their communities.
PACFA maintains rigorous registration criteria and is proud to uphold the highest standards in the sector. All registrants must practise within PACFA’s Scope of Practice and adhere to the Code of Ethics and grievance procedures. To be registered with PACFA, practitioners must meet the following requirements:
- ‘Certified Practising Counsellors’ must have completed an accredited course or equivalent (this mandates that the course must be Bachelor or postgraduate level, (AQF 7-9) and include a placement and clinical supervision).
- ‘Registered Clinical Counsellors’ must have completed the above plus an additional 750 hours of client contact and 75 hours of clinical supervision over more than two years. This recognises the experience of senior counsellors.
- ’Registered Clinical Psychotherapists’ must be a clinical member of PACFA as above and have completed significant specialised psychotherapy training as well as personalised therapy
As with PACFA’s clinical psychotherapists, counsellors can provide specialised counselling across a range of disciplines to provide the right care for a client’s needs. PACFA’s specialist colleges allow for registrants to be recognised as a specialist in the fields of Psychotherapy, Relationship Counselling, Indigenous Healing Practices, Creative and Experiential (art) Therapies, and Clinical Supervision for a range of service providers.
Incoming National Standards
Counselling is an underutilised asset in the mental health workforce and can play a significant role in prevention, early intervention and recovery. In October 2025, PACFA welcomed the National Standards for Counsellors and Psychotherapists published by the Australian Department of Health, Ageing and Disability.
The implementation of these standards, over the next three to five years, will promote greater access to registered counsellors in a wide range of clinical settings and will contribute to a more sustainable mental health system. This project will confirm counsellors and psychotherapists as a health and mental health workforce, signifying a turning point for the profession in addressing barriers to workforce utilisation and increasing our capacity to support Australians in distress.
PACFA’s high standards align closely with those established in the National Standards, and we are proud to see the quality and professionalism of our members recognised as the benchmark for the industry. This confirmation of counsellors and psychotherapists as a key part of the mental health workforce will assist in providing flexible and multidisciplinary healthcare that meets the needs of the community.
Therapy Support Categories
Counselling is a specialised professional practice focused on facilitating therapeutic change for individuals, couples, families and groups. Professional counselling is distinct from the use of counselling skills by other practitioners in various service settings. While many professionals employ basic counselling skills in their work, professional counselling represents a unique, relational discipline grounded in rigorous training and ethical standards. Professional counselling practice is underpinned by a combination of specialised knowledge, professional attributes and advanced interpersonal and therapeutic skills, all of which contribute to effective and ethical therapeutic work.
What I-CAN domains do you consider your profession and/or scope of practice is best situated to address?
- Domain 7: General tasks and demands
- Domain 9: Interpersonal Interaction & Relationships
- Domain 10: Behaviour of Concern
- Domain 11: Mental & Emotional Health
Are you able to provide a short definition of your therapy type or the scope of your practice and/or how that therapy delivers demonstratable outcomes for participants across relevant I-CAN domains?
Counsellors work with significant complexity, drawing on a wide base of theoretical knowledge and contemporary, evidence‑informed practices. They integrate this knowledge into relational, collaborative work that is personalised, strengths‑based and holistic. Counsellors provide support to diverse populations, including children, young people, adults and families.
PACFA’s Professional Competencies for Certified Practicing Counsellors outlines the competencies required for registration as a Certified Practicing Counsellor within the Psychotherapy and Counselling Federation of Australia (PACFA). The competencies listed in this document have been divided into five domains, representing broad categories of activity which occur in the practice of counselling. Utilising PACFA’s Professional Competencies for Certified Practicing Counsellors, the baseline required skills and knowledge can be mapped against the I-CAN Assessment Domains.
| I-CAN Domain | Professional Competencies for a Certified Practising Counsellor |
|---|---|
| Domain 7: General tasks and demands | - 2.16 Recognise, respect and work to support and enhance the autonomy of the client to the fullest extent possible |
| I-CAN Domain | Professional Competencies for a Certified Practising Counsellor |
|---|---|
| Domain 9: Interpersonal Interaction & Relationships | - 2.15 Help the client to become aware of recurring patterns in their relationships in order to facilitate therapeutic change in line with the client’s goals for therapy |
| Domain 10: Behaviour of Concern | - 2.10. Apply understanding of self-harming behaviours to work collaboratively with diverse clients, including the use of strategies such as harm-minimisation. |
- 2.11. Apply understanding of both chronic and episodic suicide ideation, suicidal behaviours and work with suicidal risk in a collaborative way with diverse clients.
- 2.12. Apply an inclusive, contemporary and evidence-informed understanding of domestic and family violence, including typologies and its presentation in diverse communities.
- 2.13. Apply a contemporary and evidence-informed understanding of substance and behavioural addictions, including typologies and presentation alongside: trauma; domestic and family violence; and in diverse communities.
- 2.14 Respond to clients when in crisis in a collaborative and relational manner:
- providing information about self-care and emotion regulation strategies
- assessing risk
- supporting them to formulate a safety plan if required
- referring to appropriate services for acute care if required. | | Domain 11: Mental & Emotional Health | - 2.1. Understand and apply theory and practice of counselling from intake, assessment and ending, including:
- a model of person and mind
- the role of the therapeutic relationship including the use of self
- theories of human development across the lifespan
- models of change
- evidence-informed interventions.
- 2.2. Understand and apply the principles of person-centred practice and recovery-oriented practice as fundamental to counselling practice.
- 2.23 Understand the inter-relatedness of multiple factors which impact on wellbeing, mental health, psychological distress and relationships, including physical illness and societal factors such as economic disadvantage and systemic forms of oppression.
- 2.24 Critically appraise different conceptualisations of mental health and mental health conditions.
- 2.25 Demonstrate an awareness of the Diagnostic and Statistical Manual of Mental Disorders (DSM) and its broad categories. |
What do you see as the benefits or limitations of this approach?
PACFA supports the proposal for the NDIS to clearly list professions and restrict practitioners to providing services within their registered scope. This change would not reduce the availability of support but would instead ensure higher-quality services provided by practitioners with appropriate training and safeguards. The current lack of clarity around professional roles and scopes of practice undermines therapist credibility and compromises sector integrity. Explicitly identifying professional titles and regulated scopes of practice would strengthen safeguards for participants. Formal requirements for qualifications and registration will enable a better definition for therapy within the NDIS and ensure delivery by appropriately trained providers. Counsellor and psychotherapist titles should be expressly included within any list of recognised professions to provide Therapy Supports in the general and social category.
PACFA has recently been alerted to NDIS plans that specify the provision of counselling from Therapy Assistants. Counselling has not traditionally included any type of Therapy Assistants (as opposed to Psychology), indicating a new model of care not seen elsewhere. Therapy Assistants providing counselling would not be covered by a supervising registered Counsellor’s insurance, as required by the NDIS. This creates risk in enabling Therapy Assistants to work with NDIS clients uninsured.
Other health professions are increasingly offering “counselling” services at significantly higher price points, despite not having the specialised training or qualifications required for professional counselling practice. Formally recognising tertiary‑qualified counsellors as the profession best equipped to deliver counselling services would lead to more efficient use of funding and a more targeted therapeutic approach. PACFA counsellors, whose training meets rigorous accreditation standards, are equipped to deliver an integrative practice tailored to a client’s specific issues, distinguished from other health professionals trained in shorter or less specialised pathways.
Alternate Approaches
Are there alternate ways of grouping therapy supports with reference to the domains in the I-CAN for which a participant would need access to therapy that you consider would be appropriate?
PACFA agrees with the proposed grouping of therapy supports into General, Social and Physical, with appropriately trained counsellors well placed to support participants through the general and social streams. PACFA recommends that
Domain 11 Mental and Emotional Health be included as assessment domains under both General and Social Therapy Supports, as mental and emotional wellbeing underpins functioning across the other domains. Improved outcomes in mental or emotional health can contribute to improved outcomes more broadly, but particularly in general tasks and demands, self-care, interpersonal interactions and relationships, community social and civic life and communication.
Is there an alternate approach to describing the purpose of each category of supports that you consider would be appropriate?
Mental health and emotional supports are broad, and counselling is tailored to the needs of the client. However, a suitable purpose could be:
- Support participants to improve, maintain, or slow the decline in mental and emotional health, including enhancing emotional regulation, coping capacity, interpersonal functioning, resilience, and engagement in daily and social activities.
Further information
Please see our website for further information on PACFA’s work and publications. For further information about how the National Disability Insurance Scheme could utilise PACFA members, or the clinical practice of counselling and psychotherapy, please contact:
Johanna de Wever
Chief Executive