Which registration do I need to bill NDIS, Medicare or workers compensation?

NDIS's counselling line item needs no AHPRA registration. Medicare Better Access requires an AHPRA-registered psychologist or AASW-accredited social worker — PACFA or ACA alone isn't eligible. NSW workers compensation recognises PACFA clinical membership, AASW mental-health accreditation, or ACA level 3/4.

Registration and funder billing

PACFA vs ACA vs AHPRA: which registration lets you bill which funder

Q: Does AHPRA register counsellors in Australia?

No. AHPRA, the Australian Health Practitioner Regulation Agency, does not register counsellors or psychotherapists — counselling isn't one of the professions covered by the National Registration and Accreditation Scheme.

Q: What is PACFA Clinical Registration?

PACFA (the Psychotherapy and Counselling Federation of Australia) is a self-regulating professional body with membership tiers, including a higher Clinical Registration tier above general or provisional membership. Several funders specifically recognise Clinical Registration, not just general membership.

Q: What is ACA level 3 or 4 membership?

ACA (the Australian Counselling Association) has membership levels 1 through 4. Level 3 and 4 are the tiers most funders that recognise ACA actually require.

Every funder we've written about — Medicare, NDIS, DVA, workers comp, Victims Services, private health funds — gates eligibility on a specific registration or membership tier. Here's what PACFA, ACA and AHPRA actually are, and a straight answer on what each one unlocks.

Written by Steve Daniel, founder of Zenvia — GAICD · MBA · Master of IT · Author, Cybersecurity for Australian Not-for-Profits · Last reviewed October 2026

The bit most explainers get vague about

AHPRA doesn't register counsellors at all

This is the single most common confusion: AHPRA (the Australian Health Practitioner Regulation Agency) does not register counsellors or psychotherapists. Counselling isn't one of the professions covered by the National Registration and Accreditation Scheme. So "do I need AHPRA registration?" isn't really the right question for a counsellor — you can't add it the way you'd add a certificate. What actually happens is that some funders (Medicare, general DVA treatment) are gated to other professions that AHPRA does register — psychologists, specifically — plus AASW-accredited mental health social workers. If you're a counsellor registered with PACFA or ACA, those funders aren't a path open to you by getting "more registered" — they require being a different, separately-regulated profession.

The three bodies

What PACFA, ACA and AHPRA each are

PACFA

The Psychotherapy and Counselling Federation of Australia — a self-regulating professional body, not a government scheme. Has membership tiers, including a higher Clinical Registration tier above general/provisional membership. Several funders specifically recognise Clinical Registration, not just membership.

ACA

The Australian Counselling Association — the other main self-regulating body for counsellors, with membership levels 1 through 4. Level 3 and 4 are the tiers most funders that recognise ACA actually require.

AHPRA

The government National Registration Scheme, covering professions like psychology and medicine. Social work isn't part of it — AASW's own position is explicit that social workers aren't currently registered under the National Scheme; AASW accreditation is a separate, non-government system. Several funders recognise AASW-accredited social workers alongside AHPRA-registered professions anyway — see the table below. Doesn't cover counselling or psychotherapy as a profession at all.

The straight answer

What each funder actually requires

As at October 2026 — registration tiers and funder gates do change, so treat this as a starting point and confirm anything binding directly with the funder or with PACFA/ACA.

Registration requirements by funder
Funder	What's actually required
Medicare Better Access	AHPRA-registered psychologist (or other eligible AHPRA profession), or AASW-accredited mental health social worker. PACFA/ACA alone: not eligible.
NDIS — Counselling line item	No AHPRA registration required for this specific support item.
DVA — general treatment	Same gate as Medicare — AHPRA-registered psychologist or AASW-accredited social worker.
DVA — Open Arms	Panel entry via a tender process, not a registration-tier gate the way the others are.
Workers comp (NSW SIRA)	PACFA clinical membership, AASW mental-health accreditation, or ACA level 3/4.
Victims Services NSW	AHPRA psychologist, RANZCP, AASW, ACA level 3/4, PACFA clinical membership, or ANZACATA — plus 3+ years' full registration.
EAP providers	No government registration required — each company sets its own bar, typically PACFA or ACA (general) registration, AHPRA for psychologists.
Private health funds	PACFA or ACA Clinical Registration specifically — a higher bar than general membership, set by each fund.

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