Australian Medical Association

The AMA has made a submission to the Medical Board of Australia on its Proposed Registration Standard – Granting registration as a medical practitioner on completion of intern training. The Board's proposed standard includes the option for health services to provide interns with exposure to emergency medicine (EM) in a general practice context. Of utmost concern to the AMA is the absence of clear criteria about what would constitute appropriate exposure to EM under this type of arrangement. As a result, the AMA has offered to be part of the team that will prepare guidelines to better define the Board’s requirements. In the mean time, the AMA maintains that all interns should have access to a term in an Emergency Department.

It has become increasingly common for health practitioners not holding a medical degree or professional doctorate qualifications, to adopt the title ‘Doctor’ (Dr). The AMA opposes the use of the title ‘Dr’  by health practitioners in a way that misleads people into believing they are consulting or receiving treatment from a medical practitioner.

The AMA submission to the Senate Finance and Public Administration Committee inquiry into AHPRA highlights that the administrative failure by AHPRA to properly plan for and coordinate the transition to national registration has had a detrimental effect on individual medical practitioners, and on services to patients.  In failing to ensure that every medical practitioner transitioned smoothly to national registration, AHPRA failed to act in the public interest.  Patient care was put at risk because medical practitioners could not work.

The AMA responded to an invitation from the Australian Register of Naturopaths and Herbalists to comment on the development of practice, registration and accreditation standards for naturopathy and western herbal medicine in Australia. The AMA advised that it could not provide comments until the proposals had legal standing and a board for naturopaths and herbal medicine practitioners is established under the Health Practitioner Regulation National Law Act 2009.

The AMA has made a submission to the Optometry Board of Australia in response to a proposal that all optometrists applying for general registration should be required to meet additional therapeutics qualifications. The AMA's view is that registration standards for all prescribers should be equal to those required for the medical profession.

In its submission to the House of Representatives Standing Committee on Health and Ageing Inquiry into registration processes and support for Overseas Trained Doctors, the AMA calls for removal of the 10 year International Medical Graduates (IMG) moratorium and greater support for IMGs trying to achieve specialist registration through access to other GP training, courses.

The AMA has made a submission to the Podiatry Board of Australia's consultation process on proposed revisions to their prescribing standards for podiatrists.  This submission, which is consistent with previous AMA submissions on this issue to the Podiatry Board, highlights the deficiencies in the Guidelines with respect to course content and accreditation, shared care arrangements and expansion of the national drugs list.

The AMA has lobbied very strongly to secure a number of important changes to the scheme.  The AMA's concerns about elements of the scheme that have been addressed by government and incorporated into the scheme are set out below:

The AMA Joint submission highlights the real risk that the new scheme will erode the medical board’s ability to protect patient safety, and addresses four major concerns with the proposed registration arrangements:

1. There is no recognition or guarantee of the continued role of medical colleges in determining specialist qualifications for, and conferring them on, medical practitioners;
2. The scope of practice for the other health professions will be able to be expanded without any obligation for one health profession board to consult with other boards, particularly the medical profession board;
3. The scheme seeks to introduce new onerous continuing competence/CPD requirements, which will effectively create a new scheme for the medical profession, and does not recognise the role of the colleges in continuing competence and professional development for the medical profession;
4. The medical board will be able to register a person who does not meet the requirements for registration in certain circumstances.

The AMA has also made a Joint Submission on the exposure draft to the Project Implementation Team.

This submission notes that the Ministerial Council has forfeited the power to approve accreditation standards, but has retained a power to give the national board policy directions on accreditation standards. The submission calls for additional provisions to be added to the legislation that:

• Defines the circumstances when the Ministerial Council can issue policy directions on accreditation standards; and
• Provides mechanisms for transparency and accountability of these directions.

The submission also outlines a range of other important functional operational and administrative issues with the scheme that need to be clarified and reflected, where necessary, in revisions to the Bill.

The AMA Submission to the Senate Community Affairs Committee inquiry into the national registration and accreditation scheme encapuslates the major concerns set out in our previous submissions to government on the proposed scheme.  The submission also sets out the AMA's proposal for a simple, cost effective alternative arrangement for a national system for medical practitioner registration that:

1. maintains the nationally consistent accreditation of medical education and training through an independent medical accreditation body with specific medical expertise;
2. implements mutual recognition of registration arrangements for medical practitioners across all states and create a ‘virtual’ national register; and
3. establishes a formal process for ongoing harmonisation of registration standards.

Message to members and non members on the proposed National Registration and Accreditation scheme

The AMA Joint Submission on the proposed arrangements for specialists highlights concerns that the proposed scheme will be a vehicle for governments to respond to workforce challenges by:

• permitting people to be registered as medical practitioners even though they do not meet the requirements for general medical registration; and
• allowing other health providers to inappropriately undertake competencies beyond their training and scope of practice.

Further, there is no guarantee the proposed scheme will incorporate the the role of medical colleges in:

• determining specialist qualifications for, and conferring them on, medical practitioners;
• continuing professional development for the medical profession; and
• assessment of overseas medical graduates who are applying for Australian specialist qualifications.

The AMA Joint Submission on the proposed accreditation arrangements highlights concerns that, under the proposed scheme, accreditation of medical education and training will not be independent of government, providing the potential to lower standards and therefore compromise patient safety and health outcomes.

The AMA Joint Submission highlights concerns that the proposed arrangements will impose additional requirements on registrants to provide information, including workforce data, to the relevant board as a condition of registration, and extend existing arrangements for information sharing about registered medical practitioners between various government agencies.

The overarching concern of the AMA and the co-signatories is that the proposed complaints handling process, where the ‘front end’ is run through national administration in accordance with a national law and the ‘back end’ is dealt with through state-based tribunals in accordance with varying state based laws, is contrary to the objective of having a national scheme.  In this context, as individual cases are considered and handled by different entities within the scheme operating variously under commonwealth and state laws, there is a risk that decisions on their outcomes will be unduly delayed because of lack of clarity about the application of the appropriate laws.

The assessment of the “best” system must consider the confidence that patients and registrants will have in an externally imposed system.

The AMA Joint submission highlights the real risk that the new scheme will erode the medical board’s ability to protect patient safety, and addresses four major concerns with the proposed registration arrangements:

1. There is no recognition or guarantee of the continued role of medical colleges in determining specialist qualifications for, and conferring them on, medical practitioners;
2. The scope of practice for the other health professions will be able to be expanded without any obligation for one health profession board to consult with other boards, particularly the medical profession board;
3. The scheme seeks to introduce new onerous continuing competence/CPD requirements, which will effectively create a new scheme for the medical profession, and does not recognise the role of the colleges in continuing competence and professional development for the medical profession;
4. The medical board will be able to register a person who does not meet the requirements for registration in certain circumstances.

The AMA Joint Submission identifies seven major areas of concern about the overarching structure of the IGA:

1. Accreditation of medical education and training will not be independent of government, providing the potential to lower standards and therefore compromise patient safety and health outcomes.
2. Loss of the independence of accreditation of medical education and training will mean that Australia will no longer meet international guidelines.
3. The scheme will provide a vehicle to implement an unacceptable policy agenda of workforce reform, without scrutiny, evidence or public debate on changes to the roles and responsibilities of health professionals. Our fundamental concern is the potential impact on patient safety and health outcomes.
4. There is considerable risk that registration requirements and professional standards and competencies will be changed inappropriately and without public and professional scrutiny.
5. There is insufficient accountability for Ministerial decisions and policy directions, particularly when those decisions are inconsistent with advice provided by the professional board or the independent accrediting body.
6. There is a risk that the new national health professional boards will not be sufficiently resourced to adequately carry out their functions.
7. The scheme will result in significant increases in registration fees.

The purpose of this document is to inform all doctors about the scheme agreed by the Council of Australian Governments (COAG) on 26 March 2008.

In order to achieve workforce mobility, reduction of red tape and improved safety and quality the AMA proposes a structure for national recognition of registration of health professions which includes: a Health Registration Authority to advise on processes for recording registration and for maintenance of publicly accessible registers; a Medical National Professional Panel to advise Health Ministers and maintain registration standards; and a Medical State Committee to determine eligibility and category of registration. The AMA believes that the currently proposed COAG model will undermine rather than enhance the high quality standard off healthcare services available in Australia.

AMA Position Statement: General Practice Standards - 2005

AMA Position Statement: Accreditation - 2005