Practice Experience Program Specialist – Comparability Assessment Policy


Policy

Page last updated 5 June 2024

1. Purpose

1.1 The purpose of this policy is to define the principles and requirements for Comparability Assessments.

2. Scope

2.1 This policy applies to:

    1. Specialist International Medical Graduates (SIMGs) who wish to pursue Fellowship of the RACGP via the Medical Board of Australia’s (MBA) Specialist Pathway – specialist recognition, and who:

      1. hold a primary qualification in medicine and surgery awarded by a training institution recognised by both the Australian Medical Council (AMC) and the World Directory of Medical Schools (WDOMS),

      2. have satisfied all the training and examination requirements to practise as a specialist general practitioner and have been awarded their specialist general practice qualification in their country of training, and

      3. have had their specialist general qualification’s curriculum assessed by the RACGP as substantially comparable or partially comparable to the RACGP curriculum and syllabus for Australian general practice as per clause 5.1.i of this policy.

    2. RACGP Assessors

    3. RACGP Staff.

2.2 This policy does not facilitate the assessment of SIMGs in a limited scope of practice or who wish to enter the MBA’s Specialist Pathway – Area of Need.

2.3 This policy is to be read in conjunction with the PEP SP Application Handbook and the PEP SP Entry Policy.

2.4 This policy will come into effect as of 01 July 2024.

3. General principles

3.1 The RACGP is appointed to conduct Comparability Assessments by the Australian Health Practitioner Regulation Agency (AHPRA).

3.2 The RACGP SIMG Subcommittee is responsible to oversee the assessment of SIMGs, including Comparability Assessment.

    1. Members of the Subcommittee must identify and appropriately manage Conflicts of Interest (actual, potential or perceived). In some circumstances this may include a declaration, as detailed in the Conflicts of Interest Guidance

      1. The RACGP will manage each declaration on a case-by-case basis.

3.3 The RACGP conducts Comparability Assessments in a way that is:

    1. rigorous, fair, transparent and accountable; and

    2. consistent with the MBA's Standards: Specialist medical college assessment of specialist medical graduates.

4. Purpose of the Comparability Assessment

4.1 Comparability Assessments determine the extent to which an SIMG is comparable to an Australian trained general practitioner at the point of admission to Fellowship.

4.2 There are three possible outcomes to a Comparability Assessment; an SIMG is assessed to be:

    1. Substantially Comparable,

    2. Partially Comparable, or

    3. Not Comparable.

4.3 The outcome of a Comparability Assessment:

    1. defines the further requirements to be met by an SIMG before the RACGP recommends to the MBA that the SIMG be granted recognition as a specialist general practitioner, and

    2. determines which stream of the Practice Experience Program Specialist (PEP SP) an SIMG may apply for, as per the PEP SP Entry Policy.

5. Conditions to be met before applying for a Comparability Assessment

5.1 Prior to applying for a Comparability Assessment, SIMGs must:

    1. confirm that their specialist general practice qualification’s curriculum has been assessed by the RACGP as substantially comparable or partially comparable to the RACGP curriculum and syllabus for Australian general practice.

      1. Curricula already assessed by the RACGP are listed in the Curricula classification.

      2. Applicants whose curriculum is not listed in the Curricula classification must have their curriculum assessed by the RACGP before they can apply for a Comparability Assessment, as per the PEP SP Application Handbook.

    2. apply for primary source verification of their overseas specialist general practice qualification by the AMC.

      1. Applicants must apply through the Educational Commission for Foreign Medical Graduates’ (ECFMG) Electronic Portfolio of International Credentials (EPIC), as per the PEP SP Application Handbook.

        1. Comparability Assessment applications that do not include an EPIC number will not proceed.

6. Comparability Assessment application

6.1 Applicants must submit their Comparability Assessment application through the RACGP website and provide information and documentary evidence as detailed in the PEP SP Application Handbook.

    1. Applications must contain information that is current, complete and verifiable.

      1. The RACGP will take reasonable steps to verify the information provided.

6.2 During the application process and while the outcome of the Comparability Assessment is valid, the Applicant must promptly disclose to the RACGP details of any:

    1. Addenda on the Applicant’s medical registration, whether in Australia or overseas, and/or

    2. regulatory authority activity, whether in Australia or overseas, that:

      1. has led or may lead to a change in registration status, or

      2. has led to an adverse finding for the Applicant or forms part of an ongoing investigation; and/or

    3. other Notifiable Conduct.

6.3 Applications containing plagiarised, false or misleading information, or failing to disclose information listed in 6.2 will be handled as per the Academic Misconduct Policy.

6.4 The RACGP will only assess Complete Applications for which the application fee has been paid.

7. Comparability Assessment

7.1 The Assessors will conduct a preliminary review of the Applicant’s Comparability by:

    1. systematically reviewing the documentation provided in the application against the following criteria, as per the PEP SP Comparability Assessment Guide:

      1. recency and context of practice,

      2. continuity of practice,

      3. continuing professional development (CPD),

      4. assessment type,

      5. training route, and

      6. curriculum.

    2. identifying any gaps or deficiencies compared with Australian specialist generalist practice training.

    3. taking into consideration the Applicant’s intended scope of practice.

7.2 The Assessors may request additional information or clarification from the Applicant during the preliminary review.

    1. Where the RACGP receives publicly available information about an Applicant that may inform the assessment decision, the Applicants will be provided with the information received and be given an opportunity to make a submission before a final assessment decision is made.

7.3 At the conclusion of the preliminary review, the Assessors will record their findings in a Summary of Preliminary Review (SPR), including their decision as to whether the SIMG is Substantially Comparable, Partially Comparable, or Not Comparable.

    1. The RACGP must provide a copy of the SPR to the Applicant by email within 21 calendar days of completing the SPR.

7.4 The Applicant must respond to the RACGP in writing to confirm their acceptance of the SPR findings.

    1. Where the Applicant believes there are errors of fact, perceived gaps or omissions in the information assessed in the SPR, they will be given at least 21 calendar days from the date of the SPR to provide clarification or additional evidence.

      1. Where the Applicant fails to provide clarification or additional information within the designated timeframe, the initial SPR findings will be upheld.

7.5 When the SPR findings are confirmed, the RACGP will provide the Applicant with:

    1. A Comparability Assessment outcome letter, and

    2. A copy of the MBA’s Report 1 – Assessment of international medical graduates.

      1. The RACGP will upload a copy of MBA’s Report 1 – Assessment of international medical graduates to the AMC secure portal, for use by AHPRA for registration purposes.

7.6 The Comparability Assessment outcome is valid for 12 calendar months from the date of the Comparability Assessment outcome letter.

7.7 Applicants assessed as Partially Comparable or Not Comparable may re-apply for a Comparability Assessment if there has been a material change to their training and experience since they were initially assessed by the RACGP.

8. Amendment of this policy

The Censor-in-Chief (CiC) may, without the consent of the RACGP Board, make Minor, Moderate and Consequential Amendments to this policy at any time.

If the CiC makes amendments, they must advise the RACGP Board of those amendments as soon as practicable.

The RACGP Board may make amendments to this policy at any time.

9. Responsibilities

9.1 Applicant

  1. Submitting a complete Comparability Assessment application

  2. Paying Comparability Assessment application fees

  3. Responding to requests for supplementary information

  4. Accepting findings of Summary Preliminary Review within 21 calendar days of the SPR date

9.2 Censor-in-Chief

  1. Approving Minor Amendments

  2. Approving Moderate Amendments

  3. Approving Consequential Amendments
9.3 RACGP
  1. Assessing Comparability Assessment applications

  2. Providing the Applicant with a Summary of Preliminary Review within 21 calendar days of completing the SPR

  3. Providing the Applicant with an outcome letter and MBA’s Report 1 – Assessment of international medical graduates

  4. Uploading MBA’s Report 1 – Assessment of international medical graduates to AMC secure portal

  5. Managing declared conflicts of interest
9.4 RACGP Board
  1. Approving Major Amendments


10. Glossary

10.1 Addenda

Includes, but is not limited to, restrictions, conditions, limitations, reprimands, supervision requirements, tribunal outcomes, suspensions, undertakings and/or any other remarks or changes on a Participant’s medical registration.

Refer to AHPRA’s website for more information.

10.2 Applicant

The SIMG applying for entry into the PEP SP.

10.3 Assessor

An RACGP staff with the necessary attributes, knowledge and skills in the assessment of RACGP programs participants and who understand the RACGP’s training requirements and standards.
10.4 Business Day A day when the RACGP national office is operating.
10.5  Comparable / Comparability The extent to which an SIMG’s recency, continuity of practice, continual professional development, assessment, training, qualifications and clinical experience are assessed as equivalent to an Australian-trained specialist general practitioner at the point of admission to Fellowship:

10.6  Comparability Assessment

The process of determining the extent to which an SIMG is comparable to an Australian-trained general practitioner at the point of admission to Fellowship.

10.7 Complete Application

An application is deemed complete when all requested information and documentary evidence have been received and verified.

10.8 Conflict of Interest

A situation in which it is reasonable to conclude that an individual’s or group of individuals’ personal interests directly conflict with the best interests of the SIMG or where individuals’ actions may be influenced by their personal interests rather than education and training outcomes. A Conflict of Interest includes, but is not limited to, when:

  1. close personal friends or family members are involved,

  2. an individual or their close friends or family members may make financial gain or gain some other form of advantage, and

  3. an individual is bound by prior agreements or allegiances to other individuals or agencies that require them to act in the interests of that person or agency or to take a particular position on an issue.

10.9 Consequential Amendment

An amendment that requires urgent implementation as a necessary result of an amendment to another policy or process.

10.10 Fellowship

Admittance to either:

  1. Fellowship of the RACGP (FRACGP), or

  2. FRACGP and Rural Generalist Fellowship (FRACGP-RG).

10.11 Major Amendment 

An amendment that materially changes the operation of the policy but is not otherwise a Minor or Moderate Amendment (ie a change to one major clause or policy review).

10.12 Minor Amendment  

An amendment to style, to correct grammatical mistakes, change overall formatting, make updates that do not materially change meaning, or any other amendment, which in the opinion of the Censor-in-Chief, does not materially alter the operation of the policy. 

10.13 Moderate Amendment

An amendment that materially changes the operation of a policy by a limited amount (ie a change to one minor clause, or changes that have a limited impact on the outcome of the policy).
10.14 Not Comparable A Specialist International Medical Graduate who has been assessed as Not Comparable to an Australian trained specialist general practitioner at the point of Fellowship, as per the PEP SP Comparability Assessment Guide.
10.15 Notifiable Conduct Notifiable conduct holds the same definition as the Medical Board of Australia’s Guidelines for mandatory notifications about registered health practitioners.
10.16 Partially Comparable Participant

A Specialist International Medical Graduate who has been assessed as Partially Comparable to an Australian trained specialist general practitioner at the point of Fellowship, as per the PEP SP Comparability Assessment Guide.

10.17 Practice Experience Program Specialist (PEP SP)

The route to Fellowship available to Specialist International Medical Graduates who have been assessed as Substantially Comparable or Partially Comparable to an Australian-trained specialist general practitioner at the point of Fellowship.

10.18 RACGP Staff

Anyone who is an employee or contractor of the RACGP.

10.19 Specialist International Medical Graduate (SIMG)

An overseas-trained medical practitioner who:

  1. holds a primary qualification in medicine and surgery awarded by a training institution recognised by both the Australian Medical Council (AMC) and the World Directory of Medical Schools (WDOMS),

  2. has satisfied all the training and examination requirements to practise as a specialist general practitioner and has been awarded a specialist general practice qualification in their country of origin, and

  3. had their specialist general practice qualification’s curriculum assessed by the RACGP as comparable or partially comparable to the RACGP curriculum and syllabus for Australian general practice.

10.20 SIMG Sub-committee

The sub-committee established by the RACGP Council of Censors as an advisory body to oversee the assessment of SIMGs as they work towards Fellowship of the RACGP.

10.21 Substantially Comparable Participant

A Specialist International Medical Graduate who has been assessed as Substantially Comparable to an Australian trained specialist general practitioner at the point of Fellowship, as per the PEP SP Comparability Assessment Guide

11. Related Documents, Legislation and Policies

12. Policy Review and Currency

This policy will be reviewed every three calendar years from the last approval date, or when there is a significant change in the intent of the policy. This policy remains valid and applicable notwithstanding if it is overdue for review.

 

Version

Date of effect

Amended by

1

01/07/2024

Education Policy and Guidance Lead

Amendment details

  • Development of policy based on previous Practice Experience Program Specialist Stream Policies.

Policy owner:

RACGP Board

Approved by:

RACGP Board

Approved on:

15/09/2023

Next Review Due:

09/2026

   

Enquiries

 1800 626 901

 racgpeducation@racgp.org.au

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