PEP Standard – Extenuating and unforeseen circumstances guide

1. Introduction

This guide provides information on extenuating and unforeseen circumstances for participants of the Practice Experience Program – Standard Stream (PEP Standard).

2. Context

This document provides guidance to current participants of PEP Standard (hereafter 'participants'), the circumstances which may qualify under extenuating and unforeseen circumstances. It details evidence the RACGP requires to make an accurate assessment of the circumstances. The RACGP uses the evidence a participant submits to determine the options available for a participant experiencing such circumstances.

3. Definition

Extenuating and unforeseen circumstances are defined as 'circumstances which are outside the participant's control and can reasonably be considered to be unforeseen, and can be shown to have a direct and significant impact on the participant. The RACGP considers extenuating and unforeseen circumstances on a case-by-case basis'.

4. Communication with the RACGP

Participants can apply for consideration of extenuating and unforeseen circumstances if either the participant themselves or a first-degree relative experiences extenuating and unforeseen circumstances outlined in this guide.

To apply for consideration of extenuating and unforeseen circumstances, participants should apply to the RACGP as soon as possible by submitting the Change in Circumstances form with supporting evidence. This form can be accessed by emailing postedadmin@racgp.org.au.

Applications must be made via email to postedadmin@racgp.org.au with the following naming convention:

Change in Circumstance (extenuating and unforeseen circumstances) – Dr [LAST NAME] – [RACGP ID]

The participant must inform the RACGP of leave taken during any phase of the program due to extenuating and unforeseen circumstances as soon as possible. The RACGP recognises that the nature of some extenuating and unforeseen circumstances will prevent the participant from making a timely application. However, where possible, the application should be made within one calendar month of the circumstances arising. This will allow the RACGP to accurately assess timely fulfilment of program requirements and ongoing access to a PEP provider number, including for the purposes of extension. Information about application processing timeframes can be found in the section regarding application outcomes.

The RACGP will not accept applications for recognition of extenuating and unforeseen circumstances if the application is received more than 6 calendar months after the circumstances have arisen, or the application is supported by evidence that is dated more than 6 calendar months prior to the application.

If a participant is unable to personally communicate with the RACGP, third party requests for recognition of extenuating circumstances may be made. In such cases, evidence must be provided as to why the participant cannot personally make the request, and where possible consent must be given for third party communication to take place.

5. Examples of extenuating and unforeseen circumstances

Extenuating and unforeseen circumstances may include, but are not limited to:

Ill health

• Life-threatening illness
• Serious accident
• Hospitalisation
• Illness that could become life-threatening if not treated correctly
• Diagnosed mental health condition
• Unforeseen pregnancy complications
• A chronic illness or disabling condition that if not treated correctly will prevent the person from performing their normal occupation (minimum 14.5 hours over 2 days a week of general practice)
• Inability to receive necessary medical care in an MM 2-7 location (for example, radiotherapy treatment or treatment requiring frequent attendance at a MM 1 medical facility)

Acute adverse life circumstances

• Bereavement
• Significant personal / family circumstances being encountered by the participant (for example, a spouse's mandatory employment move)
• Unusually severe stress in response to work and life circumstances preventing the participant from working the minimum part time program requirements of 14.5 hours over two days per week
• Illness of a first-degree family member

Employment conditions

• Loss of Ahpra registration
• Ahpra process difficulty or delay in obtaining registration due to circumstances beyond the participant's control, such as Health Complaints Commissioner (HCC) proceedings
• Loss of employment due to factors beyond the participant's control (such as a practice closing down)
• Loss of employment due to factors relating to the participant's work environment (such as a dispute with staff, patient complaint, undergoing investigation by Ahpra)
• Loss of Supervisor, where the participant is subject to Ahpra supervision levels 1-4
• Change in immigration status affecting the ability to continue working

Other circumstances

• Emergency or disaster
• The onset of a Pandemic
• Attendance at legal proceedings
• Australian Defence Force (ADF) deployment or other military service

If a participant experiences any extenuating and unforeseen circumstances not listed in this document that have a significant impact on their ability to continue with program requirements, they should submit a Change in Circumstances form so that their application can be assessed and appropriate support and guidance can be offered by the RACGP. The examples above are not exhaustive, and any submitted to the RACGP will be assessed on a case-by-case basis.

6. Submitting evidence

This section provides guidance regarding the type of evidence required to demonstrate the presence and impact of extenuating and unforeseen circumstances for the purposes of an application for leave, extensions or transfer.

Ill health

If the participant or a first-degree relative experiences ill health, including ill mental health, the evidence submitted should include the following information (where appropriate):

Details of diagnosis:

• Where possible, this should be a recognisable diagnosis using objective criteria. Where the issue pertains to mental health, the diagnosis should reference a tool such as the DSM-5; and
• Date of first diagnosis.

Impact of diagnosis:

• How long the relevant specialist has been providing treatment;
• Frequency of treatment (for example, how many visits in the past month). Visits less frequent than once every two months will not be considered sufficiently impactful without the presence of other mitigating factors;
• The reasons why treatment prevents the participant from meeting the program's minimum part time requirements in a MM 2-7 location (for example, if specialist services such as radiotherapy are required);
• Expected duration of illness; and
• The estimated time for which the participant will be unable to meet the program's minimum part time requirements.

Where the participant is providing care to a first-degree relative, evidence should also be provided regarding the:

• level of care provided – for example, the number of visits to medical services the relative requires, the number of hours spent providing care, and the forms of care and assistance provided.

Where medical services required for treatment of the participant or the first degree relative are situated in another location, applications will only be considered where the individual requires medical care that:

• The participant provides a letter of support or other evidence (from a GP or other relevant specialist) that the treatment is not available or suitable in their current location;
• Is required more than once every two months. Treatment less frequent than once every two months will not be considered sufficiently impactful without the presence of other mitigating factors; and
• The treatment is generally recognised as appropriate for the medical condition.

Acute adverse life circumstances

Accepted evidence includes, but is not limited to:

• Statutory declaration;
• Death certificate;
• Evidence of mandatory employment relocation; or
• Specialist letter of support or letter from a GP, including evidence of the participant's involvement in treatment.

Employment conditions

Accepted evidence includes, but is not limited to:

• Ahpra communications;
• Statutory declaration;
• Letter from place of work indicating circumstances; or
• Evidence from the Australian Department of Home Affairs or relevant international equivalent detailing the change in circumstances.

Other circumstances

Accepted evidence includes, but is not limited to:

• Evidence of residence in an area affected by natural disaster, emergency or the onset of a pandemic;
• Evidence of employment with an organisation managing fallout of natural disaster, emergency or the onset of a pandemic;
• Court summons/subpoena evidence; or
• Letter from ADF confirming deployment.

7. Medical practitioner requirements

Medical evidence may include a detailed letter of support from a GP or relevant specialist.

To ensure that objective medical information relating to a participant's circumstance is submitted, the RACGP requires independent medical evidence from a health professional who is free from any potential conflicts of interest. This means that evidence submitted by a medical practitioner must meet the following requirements to be recognised:

• The practitioner is not related to the participant/first-degree relative;
• The practitioner does not have other personal connection to or relationship with the participant or first-degree relative;
• The practitioner does not work within the participant's current general practice workplace and is not a prospective employer; and
• The practitioner is an Ahpra-registered GP or treating specialist directly involved with the diagnosis or treatment of the participant or first degree relative.

8. Application outcomes

Upon receipt of an application, the RACGP will assess the circumstances against the criteria outlined in this document. The RACGP may request additional information to supplement the application.

Processing times may vary depending on the type of application. The RACGP will give you an indication of the expected processing time when your application is received. Please note that if the RACGP requires further information or evidence after receiving your application, the processing time may be extended.

The RACGP will inform you of the outcome as soon as your application has been processed.

Application approved

• The outcome of the application is determined on the grounds of the severity of the medical condition, the supporting evidence provided and the impact on the participant's Ahpra registration.
• Participants are not permitted to undertake work using their PEP provider number during any period of leave, including during leave for extenuating and unforeseen circumstances, and it is expected that no other clinical work will be undertaken.

Application denied

• If the participant's conditions do not fit the criteria for extenuating and unforeseen circumstances, other options may be offered.

9. Circumstances not considered grounds for recognition

Participants are advised that the following are not on their own considered sufficient grounds for recognition of extenuating and unforeseen circumstances:

General

• Circumstances for which appropriate adjustments have already been made by the RACGP;
• Circumstances stated to be unforeseen that a reasonable person would view as foreseeable or preventable;
• The participant has previously been issued a SAPP provider number for another 3GA workforce program or a SAPP provider number under the Department of Health extenuating circumstances (the participant must also apply for the RACGP's extenuating circumstances recognition and be reassessed).

Employment

• Loss of employment that extends beyond leave allowances per the PEP Standard Post-Education Phase Policy;
• Disputes with employer or working conditions;
• Inability to complete program requirements due to working more than 38 hours per week.

Medical

• Self-certified illness or medical circumstances;
• A claim for recognition of a medical condition that relies on evidence that does not relate to the time when the illness or condition occurred, or was documented more than six months prior to application;
• A long-term health condition where there is no evidence of a sudden worsening;
• A minor illness that would not normally lead to a responsible and reasonable employed person to take sick leave;
• An uncomplicated pregnancy or where birth occurs prior to the start date.

Personal

• Holidays, including getting married, attendances at marriages, festivals and other personal events;
• Divorce or relationship breakdown;
• Financial hardship;
• General stress or emotional isolation not associated with a diagnosed mental health condition. When a participant is experiencing some degree of stress while on the program, it is recommended that they reduce their working hours (provided that they continue to work the 14.5 hour minimum) to ensure adequate time can be given to other responsibilities and self-care.

Geographical

• Geographic isolation in MM 2-7 location;
• Request for metropolitan placement based on age, religion, ethnicity or language skills;
• Request for a metropolitan location to access specific services (eg child-care, educational needs for children etc.).

10. The GP Support Program

The RACGP recognises that doctors experiencing extenuating and unforeseen circumstances may feel distressed and overwhelmed. To assist its members, the RACGP offers access to its counselling and support service, The GP Support Program. This is a free and confidential service available to all RACGP members and their immediate family members, where they can access professional advice to help cope with life stressors that can impact on wellbeing, work, and psychological health.

Contact information can be found on the GP Support Program webpage.

If you have any queries about how this service operates, please call the RACGP member helpline on 1800 331 626. Your queries will be handled discreetly.

11. Glossary