Amid increasing pressure to recruit sufficient numbers of non-consultant hospital doctors (NCHDs), especially in accident and emergency departments, the Government has been required to introduce amending legislation to ease the requirements for registration with the Medical Council. Up until now, doctors from non-EU countries who have traditionally filled the majority of NCHD posts, especially in smaller hospitals, have had to pass a rigorous examination before being registered to practise. Commentators have pointed out that a combination of this exam and stricter visa requirements have made Ireland increasingly unattractive for prospective recruits. In January 2011 the Irish Examiner reported a Consultant in Emergency Medicine describing the shortage of non-consultant doctors as the “greatest challenge on modern Irish medicine”. By May, the Irish Times was reporting that the shortage was estimated at up to 400 doctors.

The response to this difficulty is the Medical Practitioners (Amendment) Act 2011 which adds a new division to the Register of Medical Practitioners known as the Supervised Division. The Medical Council recently published rules for entry to this division. Only doctors who have been offered a publicly funded, individually numbered, identifiable post certified by the HSE may apply for registration in the Supervised Division. The division is focused on alleviating staffing shortages in public sector facilities only.

The application process involves two steps known as Levels 1 and 2. If successful a doctor may be granted registration in the division for a maximum aggregate period of two years.  

Level 1 involves a verification process and the submission of a declaration. The applicant doctor must provide documentary evidence in relation to his/her qualifications and good standing with equivalent regulatory bodies abroad. There does not appear to be any departure from the standard Medical Council verification process which can take a number of weeks to complete depending on the applicant’s country of origin and the extent of their work history in other host countries. The declaration however is a new development and places an onus on the chief executive officer of the employing hospital to confirm that the doctor employed will satisfy the requirements of the legislation. The declaration is lengthy and requires the employing hospital, among other things, to provide:

  • The doctor’s terms and conditions of employment;
  • The reason why the doctor’s services are required;
  • The duties that the doctor will perform;
  • The arrangements in place to supervise the doctor’s practice;
  • Confirmation that the duties to be performed will be commensurate with the doctor’s experience and the seniority of the post;
  • Confirmation that the clinical setting is subject to effective clinical governance, leadership and management systems, and
  • Confirmation that systems are in place to address any concerns about a doctor’s fitness to practise and to facilitate and maintain the doctor’s professional competence as is now required by law.

The Council has stated that Level 1 “must normally be completed before an applicant can attempt Level 2”. This appears to leave some wriggle room for doctors bogged down by verification difficulties but the rules

are clear that an applicant must pass Levels 1 and 2 before being registered. The most significant change comes with the Level 2 assessment. Described as a “summative assessment of learning to date,” its purpose is to assure the Medical Council, as the professional regulator, that the practitioner is competent to practice in the post that they have applied for. Level 2 assessments will, as far as practical, be speciality-specific but may also include generic skills. Both generic and speciality skills can be assessed in a single examination setting and will involve three principal areas: clinical judgment, communication skills and data interpretation skills. The components to be assessed within each area include:

Click here to see table.

Where appropriate, Level 2 assessments will also examine competence in speciality-specific clinical procedures and techniques. Guidelines approved by the Council on 18 July 2011 state that Level 2 assessments will utilise one or more examination methodologies approved by the Council but not detail is provided. The pass mark is 50% and candidates will be all owed a maximum of three attempts to pass Level 2. An appeal process is available for unsuccessful applicants.

It has recently been reported that the HSE has commenced submitting the necessary declarations to the Medical Council and the Council hopes that this important part of the process can be conducted in parallel with the level one verification process and the level two assessments, particularly in circumstances where a significant number of junior doctors who arrived in Ireland last July have not yet been registered to work.