The NRL is ready to deduct competition points and suspend the accreditation of football club staff to ensure clubs abide by the concussion rules after expressing concerns about incidents in the first three weeks of matches this season.
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Parramatta and South Sydney are under investigation for allowing Nathan Peats and Adam Reynolds to return to the field after both had appeared to be heavily concussed in incidents which have polarised NRL club doctors and increased calls for independent doctors to oversee matches.
NRL head of football Todd Greenberg said he was "concerned about several serious head injury incidents" in matches this season and vowed that tough action would be taken against any club which has breached the concussion rules.
While docking competition points and suspending accreditation of staff have been options since the concussion rules were introduced last season, the NRL has never considered any penalty heavier than a fine until now.
However, action against clubs has only previously been for failing to remove a player from the field for a concussion assessment, whereas the incidents involving Peats and Reynolds revolve around whether they should have been cleared to return.
"Rugby league led the way in implementing a policy to deal with head knocks and concussion last year – and the initial club support was encouraging," Greenberg said. "We are determined to maintain our leadership position in this area because we have a duty to protect our players.
"The last thing anyone wants to see is players put at risk by being sent back on the field when they should be taken out of the game, assessed and treated. So, if we need to change our policy relating to concussion to make it stronger then that is what we will do."
Sydney Roosters doctor Ameer Ibrahim told Fairfax Media last week that the Reynolds incident highlighted the need for independent doctors at NRL matches as he did not believe the Rabbitohs should have even considered allowing their playmaker back on the field, while commentators reported that Warriors doctor John Mayhew had objected to Peats returning for Parramatta last Saturday night after he had been prone in the ruck following an attempted tackle on Jacob Lillyman.
Former NRL chief medical officer Ron Muratore also believes there should be independent doctors at games and said there was confusion over how it was determined whether a player was fit to return or not, saying: "The SCAT3 is not a test, it's a tool".
International Rugby Board chief medical officer Martin Raftery, a former Cronulla player and St George team doctor, suggested the NRL may need clearer guidelines for assessing whether a player was concussed.
"Since 2011 we have identified and matured our criteria for permanent removal, which is where you don't have an off-field assesment," Raftery said. "I don't think it is as clear cut in the NRL.
"I would think the easist thing for the NRL to do would be to clarify what is the criteria for permanent removal from the field. If someone is ataxic, which means they get up and they stumle all around the field of play, they don't need an assesment, they should just be removed.
"Some people might say he got up and he took one step and he was ataxic so you then have to define what you mean by ataxic. We have a definition of ataxic."
Elite rugby union also has independent doctors who have the power to remove a player from a match but Raftery said they were encouraged to work with the team doctors to assist them to make the right assesment.
The IRB has recently introduced concussion "spotters" and sideline monitors after the match day doctor and the Wales team doctor both missed an incident in a Six Nations game in which George North was momentarily knocked out and should have been permanently removed from the field.
