The unsupervised psychometrist in a school post

Work act by act, because the disciplinary charge will be framed act by act.

• Practising without supervision. Her registration category is conditional on supervision. When the supervisor left, the condition could no longer be met. Continuing for fourteen months is not a technicality - it means every act in that period was performed outside the conditions of her registration.
• The cognitive test. The Board classifies psychological tests and restricts particular tests to particular categories. Administering, scoring and interpreting a test listed for psychologists only is outside a psychometrist's scope, regardless of how well she scores it.
• "Diagnosis of ADHD and dyslexia." Formulating a diagnosis and committing it to a report is a psychological act reserved for registered psychologists. A psychometrist may report test findings and observations; she may not present a diagnostic conclusion. The school's reliance on the label makes this more serious, not less.
• Recommending methylphenidate. Prescribing is a medical act under medicines legislation. No psychology category - including clinical psychology - may prescribe or direct that a named medicine be started. She may write to the family doctor recommending a medical assessment.
• The six "therapy sessions". Psychotherapy is outside the psychometrist scope. If the child needed therapy she should have referred.
• "Our in-house psychologist". Holding herself out as a psychologist when she is not registered as one is a misrepresentation and exposes her (and arguably the school) to action.

The unifying principle: registration category defines the outer boundary of lawful practice, and supervision conditions are part of that boundary, not an administrative preference.

Screening. The complaint is recorded and placed before the Professional Board for Psychology, which screens it through its preliminary committee of inquiry. Her written explanation within the stated period is the first substantive step; failing to respond is itself a separate charge.

Possible preliminary outcomes. The committee may dismiss the matter, ask for further information, refer it for a professional conduct inquiry before a disciplinary committee, or - if impairment rather than misconduct appears to be the issue - refer it to the Board's health committee process.

At the inquiry. She must be given the charges in writing and a proper opportunity to answer. She may be legally represented, be present, call and cross-examine witnesses, and use an interpreter. The proceedings are recorded.

Findings and sanctions. If professional misconduct is found, the committee's options run from a caution and reprimand, through a fine and/or suspension (itself often suspended on conditions such as supervision and further training), to removal from the register in the worst cases, plus costs. Aggravating features here: a vulnerable child population, persistence after the supervisor left, diagnostic and prescribing overreach, and the public holding-out. Mitigating features: cooperation, insight, no prior complaints, and evidence of remediation started before the hearing.

Afterwards. There is an internal appeal to the HPCSA and, ultimately, review by the High Court. Separate exposure exists under the Health Professions Act for practising without registration or holding out, and a civil claim by the parent is possible. Advise her to obtain her own legal representation before she writes the explanation.

Immediate cessation. Stop every act outside the psychometrist scope: no psychologist-classified tests, no diagnostic reports, no therapy, and no written medicine recommendations. Cancel the outstanding sessions and tell the school in writing that she cannot lawfully continue those functions.

Correct the record. Ask the school to remove "in-house psychologist" from its website and materials. Where reports with diagnostic conclusions have gone out, write to the recipients correcting the status of the author and the nature of the findings - this is painful but it is the difference between an error and a cover-up.

Repair the registration position. Notify the Board of the supervision lapse and apply for an approved supervisor, or investigate whether she now meets the criteria for a category permitting independent practice. Until the Board confirms, she should not practise unsupervised.

Respond properly. Answer the Registrar within the deadline, factually and without excuses, attaching the documents. Instruct a legal representative first. Do not alter, backdate or destroy any record - that converts a conduct complaint into an integrity case.

Downstream duties. Notify her indemnity insurer. Write to the referring doctors and the affected families, arrange reassessment by an appropriately registered psychologist where indicated, and document every step.

The risk of inaction is cumulative: continued unlawful practice after the Registrar's letter is an aggravating factor that can move the outcome from a suspended sanction to actual suspension, and it exposes her to a damages claim from a family who relied on a report she was not registered to produce.