Different from doctors, nurses and pharmacists, some healthcare professions such as clinical psychologists are not subject to statutory regulation in Hong Kong. They usually have to rely on a “self-regulation” mode—mostly through voluntary, society-based registration.

Yet, there seem to have loopholes under this practice. For a start, there are no legal consequences for any individual not enrolled in a society. Hence, any individual can call themselves a clinical psychologist—and the general public would have no reliable information to distinguish if these individuals are indeed qualified to provide professional service.

To address this issue, the government has introduced a voluntary accredited registers scheme (AR Scheme) in 2016 to cover the existing 15 non-statutorily regulated healthcare professions. For each profession, the Accreditation Agent appointed by the Department of Health (DH) will accredit one professional body that has met the prescribed standards under the Scheme.

In the first part of this exclusive interview, Dr Charles Wai-Ho Pau, Vice Chair (Membership & Professional Standard) of Division of Clinical Psychology (DCP) at Hong Kong Psychological Society (HKPS) and Dr Kitty Wu, Chair of the Subcommittee on Accredited Clinical Psychology Training of DCP, HKPS, share with MIMS the significance of AR Scheme to clinical psychologists and allied health professionals—and more importantly, how they utilise this opportunity to help protect public’s interest.

Assuring the protection of the vulnerable public

“One of the reasons why we have been practising a society-based registration is to uphold our professional standard of practice,” says Pau. “In order to become our member, every applicant has to fulfill certain criteria. This way, the public and patients are confident of the treatment provided by the clinical psychologists; when they know the clinical psychologists are our members,” he explains.

“Another reason is to assure the protection of the public,” continues Pau. “When we receive complaints, we have a proper complaint-handling procedure to investigate if our members infringe our Code of Professional Conduct.”

Due to the long history and reputation of the DCP, HKPS, Wu points out that they occasionally receive complaints against clinical psychologists. Yet, there are multiple loopholes under such mechanism, rendering their efforts worthless.

“First of all, the accused defendant is not necessarily our member. Since society-based registration is entirely voluntary, any clinical psychologist can operate without first becoming a member of any society. In this case, we cannot take any further actions,” elaborates Wu.

“If it turns out the defendant is one of our members, then we will form a disciplinary panel to initiate an investigation, similar to how the Medical Council of Hong Kong (MCHK) handles disciplinary inquiries and complaints against doctors. Every of our disciplinary panel consists of a group of legal advisors and fellows, who demonstrate significant contribution to the society. From 2010 to 2017, HKPS has received more than 20 complaints. Of these cases, we identified some of them as our members. Two of them were adjudicated and their names were removed from our Members’ Directory, which can be publicly accessed online,” recalls Wu.

“Even so, the disciplinary action cannot really execute the ‘punishment’. They can still continue to operate as clinical psychologists,” echoes Wu. “That having said, even the public is well aware that our disciplinary powers bear no legal implications, they still file their complaints. Hence, it shows there is a need for statutory regulation of the profession for protection of the public,” she remarks.

Wu emphasises Clinical Psychology is a high-risk profession, since most of the service recipients are vulnerable individuals (e.g. in emotional distress, with mental health difficulties, with developmental problems). Without proper training and regulation, the service provided by the clinical psychologists may pose psychological risks to the service recipients.

Certificate of Commendation was awarded to DCP in recognition of meritorious service by the Hong Kong Red Cross in 2015. Photo credit: DCP
Certificate of Commendation was awarded to DCP in recognition of meritorious service by the Hong Kong Red Cross in 2015. Photo credit: DCP

“The harm may not surface readily. However, it may jeopardise benefits from further service and development of the affected individuals. Therefore, we cannot afford to compromise the professional and training standards of clinical psychologists in the launching of the AR Scheme,” asserts Wu.

The long-awaited AR Scheme

Although loopholes remain, as it is voluntary to apply for the AR scheme, Wu and Pau are fully supportive of the initiative.

According to Department of Health’s document to Legislative Council, the government will provide financial resources for the implementation of the scheme—including operational and assessment costs of the accreditation agent, and other related expenses. However, these professional bodies will need to operate on a self-financing basis and be responsible for their daily operating costs.

“Some professions have given up applying for the scheme, due to the voluntary nature of the scheme and the difficulties they encounter in shouldering the developmental costs for attaining the standards under the scheme,” expresses Wu. “But, we have been waiting for years to get accredited. We are very determined in applying for this scheme.”

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For years, DCP has been lobbying with the government for a statutory regulation. They have even set up a Registration Board for society-based registration since 1994. Nevertheless, the government has not realised the need to set up a board to supervise these unregulated professions.

“Ironically, a majority of these 15 professions are providing their services in the public sector. Yet, unlike the medical and pharmaceutical professions, the government doesn’t recognise the need of statutory regulation or accreditation of our profession, until very recently,” laments Pau.



In 2007, former LegCo councilor Mr Yok-sing Tsang enquired the Secretary for Food and Health at that time, Dr York Chow, regarding the question on whether the government will set up regulation to supervise the professional qualifications of people providing Clinical Psychology consultation services and Clinical Psychology courses. However, Chow merely replied that clinical psychologists could register with the society-based system, and the government would place a higher priority to health care professions with a larger proportion of practitioners working mainly in the private sector and having more frequent contact with patients.

It was until October 2013 when the Office of The Ombudsman published a Direct Investigation Report regarding the statutory regulation of healthcare professions. In the report, The Ombudsman urged the DH to “to strengthen regulatory control of unregulated health care personnel and also the need for putting them under statutory control”.

Three years later in December 2016, the pilot scheme of the Accredited Registers for healthcare professions was officially launched.

“We see this as a big step forward. Of course, in the future, we do hope our profession can be subject to statutory regulation,” reveals Wu.

In the second part of this interview, Wu and Pau dive into the details of their proposal for AR Scheme—including an inclusive approach on the transitional arrangement of the AR for all clinical psychologists. MIMS

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DCP organised press conference on epidemiology study of Posttraumatic Stress Disorder in Hong Kong in 2015. Photo credit: DCP
DCP organised press conference on epidemiology study of Posttraumatic Stress Disorder in Hong Kong in 2015. Photo credit: DCP

Read more:
An inclusive approach to uphold professional standard—ensuring fair access to the Accredited Registers
The Accredited Registers Scheme for Healthcare Professions (AR Scheme) in Hong Kong: Debates and controversies
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