This is one of the most frequently asked questions by our audience. Contrary to popular belief, the answer does not depend on whether a person is a “therapist” or “clinician.” In this article, Negin Safaee, Registered Migration Agent (MARA 1791573), explains the legal definition of a “healthcare occupation” as set out in Ministerial Directions 121 and 122, breaking it down code by code. The goal is to ensure every reader can confidently determine whether their nominated occupation falls within the top priority or outside of it.
Short Answer
No. “Healthcare” in Directions 121 and 122 is defined by a list of ANZSCO groups, not by whether an individual treats patients. Doctors, nurses, midwives, pharmacists, and other Health Professionals (Group 25), medical scientists (2346), counsellors (2721), psychologists (2723), social workers (2725), medical technicians (3112), and aged care workers are within this definition; however, health services managers in group 1342 remain outside the definition of “health.” Note that this only concerns processing order, not eligibility or a guarantee of approval.
What the Law Says
The current framework operates under two documents: Direction 121 for temporary skilled visas (subclass 482) and Direction 122 for provisional and permanent skilled visas. Direction 122 was signed on 18 September 2026 and took effect the following day, 19 September 2026; Directions 121 and 122 replace the processing priorities of Direction 119. This direction is issued under section 499 of the Migration Act 1958 and is officially titled “Order of consideration and priority for certain skilled visa applications”.
The key point for the health sector is that the criterion is the occupational classification, not the clinical nature of the work or the industry of the employer. Section 5 of the direction defines each priority group, uses ANZSCO codes for most groups, and where ANZSCO occupations are listed, treats all listed occupations as having the same priority. Both directions define healthcare occupations using ANZSCO groups and codes; to check this category, the nominated occupation code must be matched against the definition in the direction. For this reason, although titles such as “construction,” “health,” and “education” seem broad, the directions themselves define these categories, and the highest priority is given to eligible primary applicants in these specific sectors.
Another significant change is the removal of the requirement to be present in Australia. Under the previous structure of Direction 119, special priority for sectors such as construction, health, and education was tied to the applicant’s presence in Australia at the time of lodgement; however, the top occupational priority in Direction 122 is not explicitly restricted to applicants in Australia, and an eligible applicant in a top-priority occupation can receive the highest processing priority even if they lodge their application from outside Australia. In other words, the distinction that previously placed overseas applicants in construction, health, and education in a lower category has been removed.
And a legal boundary that must never be forgotten: Priority of processing does not mean eligibility or visa approval; these directions only set the order for the Department of Home Affairs to process applications, and the applicant must still meet all legal requirements for the visa in question. The direction itself clarifies that it does not change the composition of the Australian skilled occupation lists, and visa requirements under the Migration Act 1958 and Migration Regulations 1994 must be met before a visa is granted.
Which healthcare occupations are truly in the top priority?
The definition of “health” in this framework includes the following groups: Health Professionals in Sub-Major Group 25, Health and Welfare Support Workers in Minor Group 411, and unit groups 2346 Medical Scientists, 2721 Counsellors, 2723 Psychologists, 2725 Social Workers, and 3112 Medical Technicians, plus 423111 Aged or Disabled Carer, 423312 Nursing Support Worker, and 423313 Personal Care Assistant. This same list appears in the text of both Direction 121 and 122.
| Occupational Category | ANZSCO Code | Priority Status |
|---|---|---|
| Health Professionals (Doctors, Registered Nurses, Midwives, Pharmacists, Occupational Therapists, Speech Pathologists, Audiologists, etc.) | Sub-Major Group 25 | Included |
| Health and Welfare Support Workers | Minor Group 411 | Included |
| Medical / Laboratory Scientists | 2346 | Included |
| Counsellors | 2721 | Included |
| Psychologists | 2723 | Included |
| Social Workers | 2725 | Included |
| Medical Technicians (Laboratory, Operating Theatre, etc.) | 3112 | Included |
| Aged or Disabled Carer | 423111 | Included |
| Nursing Support Worker | 423312 | Included |
| Personal Care Assistant | 423313 | Included |
| Health and Welfare Services Managers (Medical Administrator, Nursing Clinical Director, Primary Health Organisation Manager, Welfare Centre Manager, etc.) | Unit Group 1342 | Excluded from health definition |
The takeaways from this table that are decisive in practice:
- Doctors, nurses, midwives, and health professionals are all within Sub-Major Group 25 and are in the top priority. Health Professionals within Sub-Major Group 25 are included in the definition of “health,” provided the application meets other relevant requirements of the direction.
- Laboratory specialists and medical technicians are covered via two pathways: Medical Scientists (2346) and Medical Technicians (3112). The reason for their priority status is simply the inclusion of their occupational code in the direction’s list; professional registration status or lack thereof plays no role in this metric.
- Counsellors, psychologists, and social workers are also within the “health” category, even though they are not “treating physicians” in the conventional sense. This is the best evidence that the criterion is the classification, not direct patient treatment.
- Health services managers remain outside the definition of “health” because group 1342 is not included in this list. Unit group 1342 includes 134211 Medical Administrator, 134212 Nursing Clinical Director, 134213 Primary Health Organisation Manager, 134214 Welfare Centre Manager, and 134299 Health and Welfare Services Managers nec. This means a “Nursing Clinical Director” is not placed in the top priority via the health definition, unlike a “Nursing Manager” (see below). Eligibility for another priority category must be checked separately.
- A subtle distinction often overlooked: Nurse Managers are excluded from group 1342 and are instead placed in unit group 2543 Nurse Managers — meaning they are within Group 25 and thus in the top priority, unlike a “Nursing Clinical Director.”
Regarding the scope of implementation: Priority occupations are in the top category, whether the primary applicant lodged the application in Australia or offshore; the direction applies to both applications lodged before 19 September 2026 that have not yet been finalised and applications made after that date; and it does not change the occupation lists or visa requirements.
What this means for you
As Negin Safaee, Registered Migration Agent (MARA 1791573), explains, the first thing any healthcare applicant must do is set aside job titles or workplace names and place their nominated ANZSCO code against the direction list. If your code is in group 25, 411, 2346, 2721, 2723, 2725, 3112, or one of the three 423 care codes, your application falls into the first category of processing via the health pathway; if it is in 1342, it does not. In that case, the practical solution is usually a precise review of duty statements and correct code selection during skills assessment and nomination, rather than changing a job title on paper.
Two other points should be viewed together. First, federal priority sets processing speed, not the chance of receiving an invitation: In federal invitation rounds for the 189 visa and family-sponsored 491 visa, Expressions of Interest (EOI) are ranked by points and occupational ceilings may be applied; state nominations are managed separately. Second, state prioritisation is a completely separate mechanism; for example, Victoria has prioritised four industries in 2026-27: health, social services, education, and construction, but only occupations listed within each industry receive priority, and priority does not guarantee an invitation.
A note of honesty: any statement about “eternal demand” or the “irreplaceability of these jobs against AI” is a personal opinion about the future of the labour market, not a legal ruling. What is currently actionable and predictable is the text of the direction and its occupational codes. With a precise assessment of your occupation code, visa pathway, and application timeline, you can make decisions with peace of mind and based on legal reality — which is exactly what I do alongside you.
Resources
- Ministerial Direction 122 — Department of Home Affairs
- Ministerial Direction 121 — Department of Home Affairs
- Ministerial Direction 119 — Department of Home Affairs
- Skilled visa processing priorities — Department of Home Affairs
- Invitation rounds — Department of Home Affairs
- ANZSCO Unit Group 1342 Health and Welfare Services Managers — Australian Bureau of Statistics
- Unit Group 2543 Nurse Managers — Australian Bureau of Statistics
- Victorian Points Test — State Government of Victoria
Let’s review your occupation code together
If you work in healthcare and are unsure whether your nominated occupation falls within the top priority — especially if your job title fluctuates between “Senior Nurse,” “Clinical Manager,” or “Technician” — that small difference in the ANZSCO code can affect your processing time by months. Negin Safaee, Registered Migration Agent (MARA 1791573), will match your actual duties with the text of the direction and occupation lists in a consultation, providing a clear and realistic path forward. Send your inquiry or book a consultation to make decisions with confidence before lodging your skills assessment and application.
Frequently asked questions
Are all healthcare occupations in Direction 122’s top priority?
No. The direction defines the “health” category via specific ANZSCO groups: Sub-Major Group 25 (Health Professionals), Minor Group 411, and unit groups 2346, 2721, 2723, 2725, 3112, plus codes 423111, 423312, and 423313. Any occupation not in these groups — even if performed in a hospital — is not in the top priority via the health pathway; other priority categories must be checked separately.
Why are health services managers not in the top priority, even if their work is clinical?
Because these occupations fall under unit group 1342 Health and Welfare Services Managers, which is not included in the direction’s “health” list. For this reason, a “Nursing Clinical Director” (134212) and “Primary Health Organisation Manager” (134213) both fall outside the health definition; the possibility of being in another priority category must be checked separately.
Are psychologists and social workers counted as part of the health sector?
Yes. Unit groups 2721 (Counsellors), 2723 (Psychologists), and 2725 (Social Workers) are explicitly included in the definition of “health,” even though these individuals are not “treating physicians” in the conventional sense.
Are medical technicians prioritised because they don’t require professional registration?
No. Medical technicians (unit group 3112) are in the top priority simply because their code is in the direction’s list. AHPRA or other professional registration status plays no role in this metric; professional registration requirements and state nomination must be checked separately for your application.
Does being in the top priority mean my visa will be approved?
No. Priority only determines the order of processing. The direction does not change the occupation lists or visa conditions, and the applicant must still meet all requirements of the Migration Act 1958 and Migration Regulations 1994. In federal invitation rounds for the 189 and 491 visas, point ranking is applied and occupational ceilings may be invoked; state nomination is managed separately.
Do applicants outside Australia also get top priority?
Yes. As of 19 September 2026, eligible healthcare occupations are in the top category, whether the application was lodged in Australia or offshore; this differs from the previous status under Direction 119, where health priority was dependent on the applicant’s presence in Australia.
This answer reflects the law and policy as verified on October 28, 2026. Immigration rules change frequently — confirm the current position before acting.
Mrs. Negin Safaee Registered Migration Agent 1791573
This article is general information only, current at the date shown, and is not legal advice. Do not rely on it for your own situation — immigration law and policy change frequently. Seek advice from a registered migration agent or immigration lawyer about your circumstances.