In response to August’s Chalkeyes article, ‘Self-preservation masquerading as professional protection: an analysis of how the ODOB’s submission to Government reveals a fundamental disconnect between institutional interests and professional needs’, the author’s understanding of the Board’s role and functions seems to be based on some misconceptions, which are evident from the outset.
The Board’s primary responsibility is public protection, not the fulfilment of “professional needs”, so the subtitle may reflect a misunderstanding of the Board’s core remit. This confusion appears again in the author’s discussion of the Ministry of Health’s consultation and the Board’s concerns regarding the proposals.
There appears to be some misunderstanding regarding the Board's motivations. The suggestion that the Board opposes the proposed reforms out of self-interest is inaccurate. As set out in its submission, the Board's primary concern is not with the reforms themselves, but with their ability to achieve the Government's stated objectives. Additionally, the Board is concerned about the proposal to introduce a new regulatory model without providing any details on its structure, or a comprehensive, evidence-based cost-benefit analysis to support its implementation. Hence the Board’s view that no changes should be made.
The author indicates support for the economic rationale behind the government’s approach and questions the Board’s wish for a thorough cost-benefit analysis, claiming the Board has not provided its own. However, the Board’s financial position is publicly available in its independently audited statements, included in its annual reports, and this provides full transparency regarding its financial standing.
While the Board has faced unexpected financial challenges, such as those arising from the cyber-attack in 2022 and costs associated with successfully defending RANZCO’s complaint to the Regulations Review Committee, it is important to note that the Board’s financial situation is not as dire as suggested. For instance, in its recent consultation on fees, the Board proposed no increase in fees for most Annual Practising Certificate (APC) applications and even put forward reductions in certain cases.






