Medical Board of Australia
Consultations about a proposal for revalidation
of medical practitioners in Australia
AACP Response
(November 2016)
The AACP council reviewed the proposals put forward by an expert advisory group of the Medical Board. In broad terms the AACP considers that the present CPD arrangements, generally undertaken in association with one of the clinical colleges, and linked to ongoing registration provide appropriate basis for the medical profession to maintain clinical currency and to practice quality medicine in a safe manner.
The council was concerned that the proposed integrated revalidation process as set out in the consultation document did not provide a compelling case that the proposed much more complex revalidation process would deliver significant improvements. At the same time there has been concern that revalidation on the basis outlined would become unwieldy, complex, time consuming and costly. Therefore, an enhanced form of CPD that did not introduce significant additional costs would appear the more appropriate approach.
Having said that, it was noted also that many medical practitioners question the need for any revalidation process apart from the annual renewal process which is already linked to CPD and the AACP's view was that the evidence base to support the need for revalidation along the lines proposed needed to be more clearly articulated, as would the evidence to support the value of each different element.
Other concerns identified are that a comprehensive program such as that introduced in the UK have led to a high level of regulation and considerable administrative workload and significant time demands for medical practitioners. While it is understood the UK model is unlikely to be pursued, the experience of that model should convince the Medical Board that a much more practical approach should be undertaken in Australia if revalidation is to be pursued.
Medical practitioners work in a wide range of settings in Australia – in both public and private sectors – and under a range of governance arrangements. As such, any revalidation program that has reliance on audit and peer review must be adaptable to a wide range of circumstances. Much support for aspects of the proposed revalidation are based on practitioners working in settings where there are extensive clinical governance arrangements in place that can be utilised for revalidation activities; for medical practitioners in private practice the same governance structures are not available and they would potentially be disadvantaged by not having access to existing structures. Overall, there is significant potential for revalidation to become an undue financial burden on medical practitioners.
The issue of identifying “at risk” practitioners presents a range of challenges, not the least of which is that identification of medical practitioners aged 35 and older and particularly males as “at risk” has been seen as insulting by many specialists; it should be noted that at 35 a large proportion would have only recently completed their advanced training. The whole issue of how to identify an “at risk” practitioner needs to be further considered. Notifications and complaints, particularly under the mandatory reporting requirement, need to be seen in the context that only a proportion of these will subsequently be proved. The number of complaints does not provide an accurate picture of how many potentially “at risk” practitioners there are.
The AACP considers that the colleges and specialist organisations have the key role in supporting and assisting medical practitioners that are genuinely identified as having performance issues given their role in training, accreditation and credentialling.
The AACP reiterates that the proposed revalidation process appears overly complex, potentially costly and unreasonably difficult for those without ready access to hospital based governance structures or who work in non-metropolitan settings and would like to see a simpler process that acknowledges the professionalism of medical practitioners in maintaining their professional standards and builds on existing CPD arrangements.