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Tackling the acute shortage of non-consultant hospital docotors (NCHDs)

PRACTICE AREA GROUP: Healthcare
DATE: 03.10.2011

There has been a reported shortage of Non-Consultant Hospital Doctors (NCHDs) in Irish Hospitals. These non-training positions are perceived to be unattractive to young graduates, who typically seek to further their training and become specialists.  In May the HSE engaged in a recruitment drive in India and Pakistan to address the shortage. Reportedly two hundred and seventy doctors  were offered positions as NCHDs, but it became clear that the existing registration procedures were inadequate to speedily register and deploy the new recruits.

The registration procedure set out under the Medical Practitioners Act 2007 required non-EU doctors to complete a pre-registration exam prior to taking up a doctor’s post. As debated in the Dáil on 7 July this exam reportedly deterred many prospective applicants as it had a high failure rate and was perceived as being more appropriate for recent college graduates than for experienced doctors. Strict visa requirements also made it difficult for doctors to travel to Ireland to complete the exam. Political pressure forced the Minister for Health to amend the legislation so that the newly recruited doctors could begin work quickly.

The Medical Practitioners Amendment Act 2011

The Medical Practitioners Amendment Act 2011 (the “2011 Act”) came into effect in July. It introduced a new division to the Medical Practitioners Register, namely the Supervised Division. The new division facilitates the registration of non-EU doctors, without diminishing stringent patient safety regulations.  

Under the 2011 Act, registration applications are only accepted from doctors who have been offered an identifiable post which has been certified by the HSE as a publicly funded post. CEOs of public hospitals must submit a detailed declaration confirming that the doctor will satisfy the legislative requirements by setting out the nature of the post, the doctor’s duties and also the supervisory arrangements.

The application process involves two stages. Stage 1 verifies the applicant’s education and qualifications and confirms that he or she is not subject to disciplinary proceedings in another jurisdiction (which is consistent with the standard Medical Council registration procedure and is vital to ensure patient safety). Stage 2 represents a significant change to the pre-registration exam. The new exam is designed to ensure that the applicant is competent to take up the particular post. Therefore, it  is tailored to be speciality specific. The assessment examines competence in clinical judgment, communication and data analysis. The pass mark is 50% and applicants may attempt the exam three times.

All aspects of the registration procedure must be fully complied with prior to registration. Recent figures  show that one hundred and ten doctors have successfully registered in the Supervised Division since July. One hundred and sixty doctors  are still awaiting registration but this number is decreasing daily.

Doctors awaiting registration are not permitted to work, as it is an offence to practise without registering with the Medical Council. The introduction of the Supervised Division brings the number of Divisions in place as part of the Register of Medical Practitioners to five.

An overview of the existing Divisions

The Trainee Specialist Division encompasses the Internship Division and the Trainee Specialist Division. A doctor in the Internship Division is generally a graduate of an Irish or EU medical school. A doctor may not join an internship training programme without internship registration. The Trainee Specialist Division is for doctors who have a recognised primary medical qualification, have completed an internship and have registered on an approved postgraduate training programme. 

The Specialist Division is for doctors who have completed specialist training recognised by the Medical Council. Doctors in this division may practise unsupervised as Specialists and Consultants. 

The General Division is appropriate for all doctors who are not in a training programme and have not completed specialist training.  General Division doctors may take up any post including unsupervised locum general practice positions and may work wholly in private practice, but they may not hold themselves out as specialists. 

Entry to the Trainee Specialist, the Specialist and the General Divisions is available to non-EU doctors and doctors who trained outside the EU. Eligibility criteria varies depending on an individual doctor’s training and experience. The Medical Council may require the applicant to submit verifying documentation, and to complete a pre-registration exam. This exam is unaffected by the new legislation.  

The Visiting EU Practitioners Division facilitates temporary registration for EU citizens who are fully registered and qualified to practise in another EU member state. Such doctors may practise in Ireland on a temporary and occasional basis if they apply to the Medical Council one month in advance of providing the service. These doctors may also provide services on an emergency basis, in such cases they should notify the Medical Council within 15 days of the service being provided. 

More detailed information regarding the various Divisions can be found on the Medical Council’s website.

Final comment

Ultimately it is the responsibility of each doctor to ensure that their registration with the Medical Council is current and is appropriate. Registration on the Supervised Division is available for up to two years only and it is not yet clear how members of this division will be facilitated when their registration expires. It remains to be seen whether the creation of the Supervised Division will resolve the staffing crisis in Ireland.

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