THE BLUEPRINT: How Health Regulatory Bodies Can Move From Cultural Safety Commitment to Structural Transformation
By Jayde Fuller - Indigenous Regulatory Practice
Suggested citation
Fuller, J. (2026, June 8). The Blueprint: How health regulatory bodies can move from cultural safety commitment to structural transformation. Indigenous Regulatory Practice. https://doi.org/10.5281/zenodo.20586944
The Gap Nobody Names
Most health regulatory bodies have committed to cultural safety. Almost none have achieved it. This article is about why - and what crossing that threshold actually requires. Spoiler: it is not more culturally themed morning teas. Nor is it pulling Indigenous practitioners away from caring for our people to brief non-Indigenous staff on days of cultural significance.
Though written for regulators, this applies to any health institution that holds power over Indigenous Peoples.
The gap between commitment and structural transformation has two threshold conditions. They must happen in this order:
rescinding white and institutional power (power over Indigenous Peoples); and
respecting and supporting the self-determination, leadership, knowledges and governance of Indigenous Peoples.
First Nations and Indigenous Peoples know this gap intimately. We feel it in our bodies, minds and spirits. It hits us when non-Indigenous staff, leaders or Board members minimise us. They minimise our ways of being, our ideas and our experiences, or deem them invalid.
This impact shows up as:
racism (the impact on us matters more than your label or your intentions);
reinforcement of white supremacy culture and the colonial project;
mis-deployment of Indigenous staff;
deterioration of our psychosocial wellbeing [1];
disengagement, silencing and self-censorship;
resignation from the workplace;
tokenistic representation mistaken for governance;
erosion of trust with Aboriginal and Torres Strait Islander / First Nations communities.
What Transformation Is Not
Many interventions in health regulation feel like progress. But they do not change the structure that should prioritise cultural safety. On the surface, some look promising to insiders and stakeholders. They read as markers of transformation. Yet they fall short of both threshold conditions above.
Here are some typical examples from health regulation.
Cultural safety training
It seems reasonable to believe that training produces a culturally safe workplace. Educate the practitioners, the non-Indigenous staff and the Board members - and surely behaviour changes? After all, registered practitioners earn the privilege of treating our populations through rigorous education, testing and practice. Right?
Training has its place. At an individual level, it can shift awareness and build a foundation. But we must be honest about who avoids change here. The regulatory body. The institution. The system.
What this belief fails to acknowledge:
Cultural safety is a lifelong commitment, not a competency you pass or fail. A training session is not the finish line. There is no finish line.
Health regulatory bodies exist because practitioners sometimes fail their obligations. So why assume training works differently? Why assume attendance alone guarantees changed behaviour?
Training frames cultural safety as a knowledge deficit. It implies that if non-Indigenous people knew more, they would act differently. This misdiagnoses the problem. Racism in healthcare is not mainly a knowledge gap. It is a power-and-accountability gap. Training addresses the wrong variable.
Training locates the problem in individuals, not the system. That lets the institution off the hook. When someone acts unsafely after training, the story becomes “that individual failed”. It does not become “this system has no structural accountability”. The institution stays blameless.
Centuries of colonisation and white supremacist culture have shaped every institution we work within. The racist beliefs they produced are not undone in one session. Indoctrination built over lifetimes does not unravel in a morning.
Showing up gets treated as enough. Training becomes a compliance box ticked, not a practice changed. Without accountability designed by and answerable to Indigenous Peoples, patients and staff, neither threshold is met.
Training without consequence is optional in practice. Even when attendance is mandated, application is not. Nothing connects what someone learned on Tuesday to how they treat an Aboriginal patient on Wednesday. The transfer gap is structurally guaranteed.
It places the burden of proof on Indigenous Peoples. We are implicitly required to prove that harm occurred. Meanwhile the practitioner’s good intentions and attendance count as mitigating evidence. The accountability architecture is inverted.
Institutional KPIs measure the wrong things - attendance numbers and the sentiment of non-Indigenous participants. “Do you feel more culturally safe?” is not asked of Aboriginal and Torres Strait Islander Peoples. It is asked of the people whose behaviour needs to change.
Indigenous ‘advisory’ committees
I have heard this many times. “We don’t know what we don’t know. Indigenous Peoples just need to tell us what they want.” “But Jayde,” I hear you say, “isn’t that threshold condition two? Respecting Indigenous leadership?” Asking is not the same as ceding. The power to ignore what you have been told stays entirely intact.
I hate to break it to you. If you have not enacted condition one first - rescinding white and institutional power - you are reproducing ‘colonial load’.[2] Weenthunga Health Network defines it as:
the load placed knowingly and unknowingly on First Nations people by settlers and institutions. It includes biases, assumptions, expectations and entitlement held by Settlers. Settlers are often ignorant and in denial of the load’s existence. The load is highly visible to us as First Nations people. When the burden to carry the load is placed on us, it causes harm. It can lead to burnout and impact our ability to maintain our cultural responsibility.
You are essentially telling First Nations Peoples something stark. Their intellectual labour, experiences and knowledge can be extracted at any time. But you are under no obligation to act on it, because the power structure stays unchanged.
So what does the institution do with that expertise? It filters the knowledge through existing power structures. It reinterprets it to fit what it was always going to do. Then it cites it as evidence of Indigenous consultation. The knowledge gets laundered. That is the colonial mechanism operating in plain sight.
Look at the word naming the committee: ‘advisory’. This is not phoning a friend about your Friday-night outfit, advice you can take or leave. The Indigenous people on that committee need real power. They need decision-making and authorising power to effect structural change, independent of the regulatory body’s hierarchy. Without it, you will burn out those staff, Board members and practitioners - or erode their trust fast.
It also carries an unwanted cost to the institution. It signals to Indigenous communities that this body does not listen to or care about our people. Our communities are small and deeply relational. Relationships are the infrastructure through which knowledge, trust and accountability move. This is not incidental to how we operate. It is the governance mechanism itself.
Western institutions tend toward transactional relationships. So they underestimate how fast reputational damage travels through Indigenous networks. They also underestimate how hard it is to repair. That is especially true when it affects our safety, our access to care, or our ability to advocate for our communities.
Indigenous staff in roles without authority
You may have Indigenous Peoples on your payroll, appointed to improve cultural safety and access. But without real authority to enact structural change, this is window dressing. It is a photo opportunity for an employment strategy. And it is deeply disempowering for those staff.
Then there is the role design problem. These positions are often created without a clear mandate. They lack reporting lines that give genuine influence. They lack resourcing matched to the scope of change required. The disempowerment is baked into the job description before the person starts. That is not an individual failure. It is an architectural one.
An anti-racism policy where non-Indigenous HR staff decide complaint outcomes
Picture an anti-racism policy where non-Indigenous HR staff control the process and outcome of harm declared by Indigenous Peoples. That is not accountability. It is the institution investigating itself. The power to define racism, and to decide a proportionate remedy, stays with the people least positioned to judge it.
The Two Thresholds
A threshold is not a milestone. Milestones can be reported against, celebrated and filed away. A threshold is a structural shift. It is the moment the architecture of power changes irreversibly. The next board cannot undo it. Neither can the next budget cycle, nor the next executive who downgrades cultural safety.
There are two thresholds. They must happen in order.
Threshold One: The Rescinding of White and Institutional Power
This is the one nobody wants to name directly. It requires the institution to make a genuine transfer. Not a consultation. Not a partnership. Not a seat at a table it still controls. It means an actual relinquishment of decision-making authority over the lives, care and futures of Indigenous Peoples.
We have seen it happen. In 2013, the First Nations Health Authority (FNHA) became the first province-wide First Nations health authority in Canada.[3] Health Canada did not partner with FNHA. It ceded jurisdictional authority to it. The federal government transferred responsibility for the design, delivery and governance of health services to an Indigenous-led body. That body is accountable to First Nations Peoples and governed by First Nations Peoples, on First Nations terms. That is Threshold One in practice. It is not symbolic. It is architectural.
Most health regulatory bodies have not come close.
Threshold Two: Respecting and Supporting Self-Determination, Leadership, Knowledges and Governance
The second threshold is not softer than the first. But it is more specific. It requires the institution to actively support Indigenous Peoples’ authority to determine outcomes that affect them. Not to consult. Not to advise. To determine.
British Columbia is instructive here too, and not by accident. The province has built a layered architecture. The sequence in which it was built is precisely what gives it force.
Indigenous governance authority was established at the apex through FNHA. So the practitioner and organisational layers that followed had something real to answer to. In 2022, the British Columbia College of Nurses and Midwives (BCCNM) brought a new practice standard into force.[4] It made cultural safety a regulatory obligation for every nurse and midwife in the province. Not an aspiration. A condition of practice. Developed with Indigenous authority behind it, the standard creates enforceable individual accountability.
Alongside this, the Health Standards Organization developed a standalone BC Cultural Safety and Humility Standard.[5] Its structure matters as much as its content. It is not absorbed into patient safety frameworks. It is not embedded as a sub-criterion of quality care. That absorption is how cultural safety is quietly diluted elsewhere. This standard exists independently. Organisations cannot cross-reference their way out of it. They must demonstrate it on its own terms.
The result is three distinct layers of accountability working in concert. Indigenous governance authority sits at the apex, in FNHA. Practitioner-level accountability runs through the BCCNM standard. Organisational accountability runs through a standalone accreditation standard that other criteria cannot satisfy. No single layer can be gamed in isolation. An organisation cannot demonstrate cultural safety at accreditation while its practitioners stay unaccountable to the practice standard. And both layers sit where Indigenous governance authority exists and holds real power.
Critically, the standards came after the governance architecture, not before it. That sequencing is not incidental. The BCCNM and HSO standards have teeth because the FNHA exists to give them teeth. Where standards are built without that governance foundation, they tend to become documents. Organisations perform compliance with them rather than transform toward real accountability.
In Australia, the framework governing health practitioner regulation has changed by law. The Aboriginal and Torres Strait Islander National Special Issues Committees now help determine the outcome of culturally unsafe care.[6] This represents meaningful movement toward Threshold Two. Indigenous Peoples are not being asked to advise on what should happen to a practitioner who caused harm. They are making that determination. That is structurally different.
It is worth being honest about what this example also shows. Accountability mechanisms can move toward Threshold Two before Threshold One is enacted. Has institutional power genuinely been rescinded? Or can the institution still wind these mechanisms back? That is a different and still-open question.
Most regulatory bodies have enacted neither threshold. Many are nowhere near Threshold One. In most cases, the gap between what is achieved and what strategy documents claim is significant. That gap is not accidental. It is structurally produced - by the same architectures that cultural safety transformation is meant to dismantle.
What It Actually Feels Like
Are you a non-Indigenous executive, leader or board member? Then I want to be honest about what this work will ask of you. Not to frighten you. I want to stop you misreading what comes next as failure. It is, in fact, evidence that something real is happening.
You will need epistemic humility. That is not a soft ask. It means genuinely recognising that your ways of knowing, doing and being are not the only ones that exist. The frameworks through which you understand governance, accountability, evidence and leadership are one set. Not the set. One.
Indigenous knowledges have sustained peoples and communities for more than sixty thousand years. They are not primitive, not pre-scientific, not in need of translation into Western frameworks to become valid. They are complex, relational and deeply nuanced. And they do not operate through the zero-sum logic that whiteness typically defaults to.
Zero-sum logic holds that for one group to gain, another must lose. It is a scarcity framework. It treats power, authority and legitimacy as finite resources to compete over, not capacities that can be structured differently. Ibram X. Kendi traces how this logic underpins some of today’s most dangerous ideologies.[7] These include Great Replacement Theory - the belief that one group’s advancement is an existential threat to another. The same logic operates, often unnamed, in institutional resistance to Indigenous governance. The assumption is that if Indigenous peoples gain authority, white institutions must be losing something. That if Indigenous knowledges are validated, Western frameworks are diminished. That power shared is power lost.
This is a false frame. But it is a persistent one. It is embedded in the epistemological architecture of the very institutions we are asking to change.
Indigenous relational epistemologies do not begin from scarcity. Right or wrong, compliant or non-compliant, inside or outside the standard - these categories are not universal. They are design features of systems built to serve white institutional interests. And they consistently fail to account for the sophistication of Indigenous governance, knowledge and community. When you feel the pull to resist relinquishing power, ask which framework is generating that feeling. The zero-sum lens is not revealing a truth about power. It is obscuring one.
Here is the harder thing. Systems and institutions are built around white comfort. That is not an accusation. It is a structural diagnosis. So genuinely supporting cultural safety for Aboriginal and Torres Strait Islander / First Nations Peoples will require something of you. You will need to become uncomfortable. And stay there.
That discomfort has two faces. The first is internal. It is recognising where your instincts come from. Your default judgements and your sense of what is normal were shaped by institutions not designed with Indigenous peoples in mind. That is uncomfortable to sit with.
The second is interpersonal. Structural change requires you to challenge institutional norms in the room. Those norms are held by your peers - people who share your professional culture, your career context and often your race. That carries social and professional cost. It will not always be received well.
I am not telling you this so you retreat from it. I am telling you for a reason. If you wait for this work to feel comfortable before you commit, you will wait indefinitely. The discomfort is not the obstacle. The discomfort is the mechanism.
What Indigenous Leadership Actually Means
Not consultation. Not a seat at the table. Decision-making authority. Governance with real teeth.
Indigenous leadership is not a seat at the table. By now, I hope that is clear. Let me be precise about what it is.
Indigenous governance - the real kind - means decision-making authority. Not advisory authority. Not the authority to recommend, submit or be consulted. The authority to decide. That authority must come with the resources to act on decisions. On our terms - not contingent on institutional approval of how we use them.
It means leadership without conditions. Non-Indigenous institutions habitually support Indigenous leadership in principle while attaching conditions in practice. Conditions about process. About format. About which governance structures count as legitimate. Those conditions are how institutional power reasserts itself over Indigenous authority. Genuine support means withdrawing them.
It means accountability to community. Often Indigenous leaders and governance bodies are accountable mainly to the institution that funds or hosts them. That structure reproduces the colonial relationship. It positions the institution as the authority Indigenous leaders must answer to. Genuine Indigenous governance inverts that. Accountability runs to community. It runs to the Indigenous peoples whose health, safety and lives are at stake. If our practice or decisions are challenged, that challenge should come from the people we serve. Not from white institutions.
This is not a theoretical position. It is a practical one. Institutions that genuinely supported Indigenous governance have had to make real changes. They changed how they structure authority, how they resource it and how they understand their own role. They have had to move from centre to periphery. That shift is what Threshold One requires. Indigenous leadership is what becomes possible on the other side of it.
The Question for Every Health Regulatory Body
Every health regulatory body I have met can say yes to one question: “Are you committed to cultural safety?” The commitment is rarely the problem. Commitments are made at board level, written into strategic plans, announced at events and cited in annual reports.
The question that determines whether transformation is possible is different. It is not about commitment. It is about relinquishment. What are the institution, and the people who hold power within it, genuinely willing to give up? Decision-making authority. The comfort of familiar processes. The safety of institutional consensus. The assumption that Western frameworks are the right lens for evaluating Indigenous leadership.
What are you willing to relinquish?
Has that question landed somewhere real? Has it named something about where your organisation is, or where it is stuck? Then I would welcome a conversation.
Discovery Sessions with Indigenous Regulatory Practice begin here. To book one, email me at indigenousregulatorypractice@gmail.com.
References
Wilkes B, et al. - Embedding cultural safety to combat racism against Aboriginal and Torres Strait Islander peoples. Australian Journal of General Practice (RACGP); March 2026. https://www1.racgp.org.au/ajgp/2026/march/embedding-cultural-safety-to-combat-racism-against↩
Weenthunga Health Network - definition of 'colonial load'. https://weenthunga.com.au/↩
First Nations Health Authority - About the FNHA (Province of British Columbia / FNHA). https://www.fnha.ca/about↩
BC College of Nurses and Midwives - Indigenous Cultural Safety, Cultural Humility and Anti-Racism Practice Standard (effective 25 February 2022). https://www.bccnm.ca/RN/PracticeStandards/Pages/CulturalSafetyHumility.aspx↩
Health Standards Organization - British Columbia Cultural Safety and Humility Standard (HSO 75000:2022). https://healthstandards.org/standard/cultural-safety-and-humility-standard/↩
Australian Health Practitioner Regulation Agency - Aboriginal and Torres Strait Islander Health and Cultural Safety Strategy: Communiqués. https://www.ahpra.gov.au/About-Ahpra/Aboriginal-and-Torres-Strait-Islander-Health-Strategy/Communiques.aspx↩
Ibram X. Kendi - Chain of Ideas: The Origins of Our Authoritarian Age (2026). https://www.penguinrandomhouse.com/books/778233/chain-of-ideas-by-ibram-x-kendi/↩
