Assessment of feedback on proposed changes to Vetboard fees for 2023-24
The Veterinary Practitioners Registration Board of Victoria (the Vetboard) extends its thanks to all veterinary practitioners and veterinary students who recently provided feedback on proposed changes to its fee structure for the 2023-24 practising year. The assessment of this information is expected to be completed in May 2023, and veterinary practitioners and students will be advised of the outcomes at that time.
Introduction and summary of proposed changes
The Veterinary Practitioners Registration Board of Victoria (the Vetboard) recently sought feedback on the following proposed changes to its fee structure for the 2023-24 practising year:
- an increase of 15 per cent for most regulatory fees including professional fees payable for registration and renewal of registration
- new fees to recover the cost of processing applications to vary registration conditions, convert general registration to non-practising registration, and refund registration fees
- a reduced administration fee for non-practising veterinary practitioners converting back to general registration
- an increased administration fee for applications involving complex issues
- revocation of the Board’s policy to waive general registration fees of “honorary” veterinary practitioners who have practised for 50 years or more. While honorary practitioners holding general registration will be required to pay full general registration fees, the fees of honorary practitioners who hold non-practising registration will continue to be waived.
Click here to view the complete proposed regulatory fee schedule
Background to proposed changes
The Vetboard is a non-profit self-funding statutory authority whose mission is to protect the public and the health and welfare of animals through the regulation of the veterinary profession.
Approximately 95 per cent of the Vetboard’s revenue is derived from registration and associated professional fees paid by veterinary practitioners.
An increase in the Vetboard’s regulatory fees is needed to provide for the sustainable regulation of veterinary practitioners in Victoria. The proposed changes will enable the Vetboard to:
- meet the growing cost of administering regulation and delivering its services
- continue to provide timely, high-quality services to the veterinary profession and community
- achieve its strategic objectives and meet the expectations of the Minister for Agriculture and other stakeholders, and
- ensure its future financial sustainability.
The revenue raised from fees enables the Vetboard to maintain a small staff and undertake its primary functions, which include:
- registering persons as veterinary practitioners and veterinary specialists in Victoria
- investigating the professional conduct or fitness to practise of registered veterinary practitioners and imposing sanctions where necessary, and
- issuing guidelines about appropriate standards of veterinary practice and veterinary facilities.
Registration and service fees paid by individual veterinary practitioners support the regulation of the Victorian veterinary profession as a whole. The work of the Board provides assurance that persons practising in the veterinary profession in Victoria have the competencies to provide veterinary services in Victoria. This helps to protect the health and welfare of animals in Victoria and, by extension, the Victorian community.
Another of the Vetboard’s functions is to recognise qualifications and accredit courses of training which provide qualifications for registration as veterinary practitioners and specialists. For this purpose, a portion of the registration fees paid by each registered veterinary practitioner is allocated to the Australasian Veterinary Boards Council (AVBC), of which the Victorian Board is a standing member, to support that body's essential work in assuring and promoting uniform educational standards through accrediting veterinary schools, administering the Australasian Veterinary Examination, assessing veterinary qualifications for migration and assessing specialist qualifications.
Board revenue is also used to meet general government compliance requirements, including the Standing Directions 2018 under the Financial Management Act 1994 (2018 Directions), which set the standard for financial management by Victorian Government agencies.
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The increasing cost of regulating the veterinary profession
For many years, the cost of regulating the veterinary profession was covered by minimal yearly increases to registration fees. Over the past 3 years, the cost of regulating the veterinary profession has increased. This increase has meant that, in the past 2 financial years, the Vetboard’s expenditure has exceeded its income resulting in a net deficit. As a result, the balance of the Board’s equity decreased from $953,294 to $383,708.
The increase in the cost of regulating the veterinary profession has resulted from:
- An increase in the number of complaints about veterinary practitioners received by the Vetboard
In 2018-19, the Vetboard received a total of 82 complaints about veterinary practitioners. In 2021-22, the Vetboard received 162 complaints; and it is estimated that it will receive about 168 complaints by the end of the current financial year. Complaints have more than doubled over a 3-year period.
- An increase in the number and complexity of the complaints investigated by the Vetboard
The increase in complaints to the Vetboard resulted in an increase in the number of investigations conducted by the Board. The complexity of the matters investigated has also increased. To ensure timely investigation, the Vetboard has delegated its power to investigate several complex complaints to external investigators.
- An increase in the number of formal hearings held by the Vetboard
Before the last financial year, the Vetboard conducted an average of 3 to 4 formal hearings per year. By contrast, 6 formal hearings were held in 2021-22, 3 have been heard in the current financial year to date, and 11 are pending hearing (an exceptional and unprecedented number). The Vetboard engages lawyers and barristers to assist in the preparation and conduct of formal hearings.
- An increase in employment costs
In 2020-21, the increasing number and complexity of complaints investigated by the Vetboard necessitated a restructure of its investigations team. Several vacant positions were temporarily filled by agency staff during 2021-22 while the Vetboard finalised the engagement of ongoing staff. To meet the demands arising from the increased number and complexity of complaints and investigations, the Vetboard employed legally qualified investigations staff and a veterinary practitioner to provide technical direction and guidance to the compliance and investigations team. While the Vetboard workforce has now stabilised, a further increase in the Vetboard's investigation staff (currently 3.5 FTE) is required to meet demand to ensure timely and high-quality investigations.
The Vetboard will continue to ensure that its services are provided efficiently and it will spend its funds responsibly. However, it is vital that the Vetboard addresses the imbalance between the cost of regulating the veterinary profession and its revenue by ensuring it recovers the cost of providing its services. Further, to ensure its fiscal sustainability, the Vetboard must rebuild its equity by achieving a surplus position over the next three to four years. This means an increase in fees above cost recovery for FY24.
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Pricing for Value principles
The proposed changes to the Vetboard’s fee structure have been informed by the Department of Treasury and Finance’s Pricing for Value pricing principles. The purpose of the pricing principles is to promote efficiency, equitable access and fiscal sustainability for Victorian Government agencies. Specific examples of how the Vetboard’s proposed fee structure align with these principles are set out below:
- Pricing Principle 1 - Agencies should aim to recover the full cost of service provision to promote efficient consumption. The Vetboard’s fee structure is based on cost recovery (as a minimum). New or higher fees have been proposed for assessing complex applications, reviewing registration conditions, converting registration and processing refunds, to ensure that the Vetboard recovers, at a minimum, the cost of those services.
- Pricing Principle 2 - The cost of service provision should be borne by those who benefit from the service.
The Vetboard’s role is to ensure acceptable standards of veterinary practice are met in Victoria, i.e., by registering qualified and suitable people and taking regulatory action when these standards are not met. This promotes community trust in the veterinary profession. Veterinary practitioners directly derive benefit from these services and it is appropriate that they bear the cost of the services.
- Pricing Principle 5 - The price of services should not limit access to those with a lower ability to pay.
Fees for registration for graduates continue to be discounted. On an applicant's request, the Vetboard may agree to reduce registration fees in special circumstances, where a person has demonstrated that they are in financial or personal hardship.
- Pricing Principle 6 - Users should pay for differentiated service based on the value created by that differentiation
The Vetboard offers a fast-track service for registration approvals and expedited applications.
- Pricing Principle 8 - Pricing should support positive behaviours
Veterinary practitioners who have practised for over 50 years and effectively retired will have the option to convert to free honorary non-practising registration. Fees for honorary non-practising registration will continue to be waived.
- Pricing Principle 12 - Pricing arrangements should be monitored annually and reviewed periodically
The Vetboard applies indexation to fees annually but will additionally monitor and review its fees each year to ensure that pricing arrangements are sufficient to promote efficiency, equity and fiscal sustainability.
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