RACGP Short-term Training in a Medical Specialty Policy

1. Purpose

The purpose of this policy is to define the principles and requirements for assessing the suitability of 

• International Medical Graduates (IMGs) to undertake the Short-term Training in a Medical Specialty (STTMS) Pathway, and 

• their proposed training positions. 

The Royal Australian College of General Practitioners (RACGP), as the accredited specialist medical college for general practice, is responsible for assessments in the specialty of general practice for the purpose of Limited Registration only.

2. Scope

2.1 This policy applies to IMGs applying for Limited Registration with the Medical Board of Australia (MBA) in order to undertake postgraduate training under the STTMS pathway in general practice, who are:

1. 1. recognised as a qualified specialist general practitioner in another country of training (outside Australia), or

   2. recognised as a specialist-in-training in another country of training (outside Australia) who:

      1. are likely to be no more than two years away from completing their specialist training, and

      2. have passed a basic specialist examination or have satisfactorily completed substantial training (generally three or more years of Full-time Training, usually achievement of postgraduate year 5 or above).

2.2 This policy should be read in conjunction with the MBA’s:

1. 1. Guidelines: Short-term training in a medical specialty for international medical graduates who are not qualified for general or specialist registration (MBA Guidelines),

   2. Supervised practice for international medical graduates guidelines and

   3. Registration standard: Limited registration for postgraduate training or supervised practice.

3. General principles

3.1 This pathway is appropriate for IMGs who intend to complete a period of short-term training (24 calendar months or less) in Australia and return to their country of training following completion of the STTMS pathway.

3.2 The role of the RACGP in the STTMS pathway is to provide advice to the MBA on the suitability of IMG applications for short-term training in general practice.

3.3 The RACGP does not:

1. 1. grant medical registration in Australia. Under the Health Practitioner Regulation National Law Act 2009, the MBA is responsible for granting medical registration in Australia.

   2. accredit the STTMS pathway for the purposes of specialist training in Australia.

   3. recognise time undertaken while participating in the STTMS pathway for the purposes of Recognition of Prior Learning and Experience (RPLE) or advanced standing in any RACGP-Approved Program.

   4. find employment for an IMG. This is a responsibility of the IMG.

   5. make decisions related to the employment of an IMG in an STTMS pathway training position, including industrial matters. This is the responsibility of the employer.

   6. issue IMGs with a certificate of satisfactory completion for a period of practice. This is the responsibility of the employer or Supervisor.

   7. apply for a Medicare provider number for the period of practice on the STTMS pathway. This is the responsibility of the employer and the IMG.

   8. assess applications for Medicare provider numbers or issue IMGs with Medicare provider numbers. These are the responsibilities of Services Australia.

   9. monitor IMGs on the STTMS pathway after support for a position is provided. This is the responsibility of the Australian Medical Council (AMC).

   10. provide assistance with immigration or visa requirements. This is a responsibility of the IMG.

   11. complete primary course verification of overseas qualifications. This is a responsibility of the MBA.

   12. complete an assessment of the IMG’s training and experience for comparability against the training and experience of an Australian-trained specialist in the same field of practice.

3.4 Support for an STTMS pathway position by the RACGP does not contribute to meeting entry requirements for any RACGP-Approved Program.

3.5 The RACGP does not provide training and does not certify the quality of training received by the IMG.

3.6 Participation in the STTMS pathway does not lead to Fellowship of the Royal Australian College of General Practitioners (FRACGP) or to specialist recognition as a GP in Australia.

4. Maximum time permitted to practise on the STTMS pathway

4.1 The maximum period of practice permitted on this pathway is 24 calendar months, as stipulated by the MBA. 

1. 1. IMGs who intend to practise in Australia for more than 24 calendar months must meet the requirements of the AMC Competent Authority pathway, Standard pathway (AMC Certificate) or Specialist pathway (specialist recognition or area of need). 

5. Characteristics of a genuine training position 

5.1 A Genuine Training Position must: 

1. 1. be appropriate to the applicant’s level of training and experience,

   2. be in Comprehensive Australian General Practice,

   3. comply with the MBA Guidelines and be accredited to the Standards for general practice training (4th edition) by the RACGP, and

   4. be specific to the IMG’s training requirements and provide clinical and educational supervision, assessment and feedback, as well as formal assessments to be administered by the IMG’s Supervisors to monitor the IMG’s progress. These activities must be outlined in a weekly timetable.

5.2 The RACGP will assess the extent to which the position will provide the IMG with experience not available in their country of training. 

5.3 The RACGP will not support applications including for, but not limited to:

1. 1. service roles with the purpose of filling a workforce shortage,

   2. a STTMS pathway position that disadvantages any GP in Training in an RACGP-Approved Program.

6. Supervision requirements of the training position

6.1 For each training site, the IMG must have an onsite Supervisor who:

1. 1. holds Fellowship of the RACGP (FRACGP),

   2. holds Fellowship of the Australian College of Rural and Remote Medicine (FACCRM), or

   3. has vocational recognition as a specialist general practitioner.

6.2 Supervisors must:

1. 1. meet the MBA’s Supervised practice for international medical graduates guidelines, and

   2. hold full and unrestricted specialist medical registration at all times while providing supervision.

6.3 Locum doctors or Supervisors who visit the site infrequently are ineligible to supervise.

6.4 When considering whether adequate supervision is in place, the RACGP will assess the site’s capacity to provide genuine training to the IMG to meet their individual training needs and a local curriculum with learning outcomes.

1. 1. Detailed information on the supervision arrangements, the level of supervision proposed in the Australian Health Practitioner Regulation Agency (Ahpra) application for registration and a supervision plan for the IMG must be provided within the application to the RACGP.

6.5 The RACGP will not support applications for the IMG to practise under level 4 supervision.

7. Application process

7.1 Prior to submitting an application to the RACGP the IMG must:

1. 1. hold an offer for a short-term training position in Australia, and

   2. apply to the Australian Medical Council (AMC) for primary course verification of their medical qualifications.

      1. IMGS who are Internationally Qualified Specialist GPs must apply to the AMC for primary source verification of their primary and specialist qualifications.

      2. IMGs who are International Specialists-in-training must apply to the AMC for primary source verification of their primary qualification and provide a letter from the overseas college or state medical council. This letter must be submitted on official letterhead and confirm that the IMG is enrolled in a training program and is no more than two years from completion of specialist training.

7.2 The RACGP will only assess complete applications.

1. 1. Incomplete applications include, but are not limited to, providing uncertified documents, or incorrect documentation.

   2. The required documents are those listed in the AAMC-30 application form (Application for assessment by a medical college).

      1. The training plan must include details of cultural safety training to be undertaken.

   3. The RACGP may at its discretion request additional information or documentation aside from the required documents during the assessment. Failure to provide additional information or documentation will render the application incomplete.

   4. Any additional documents not requested by the RACGP will not be considered by the RACGP as part of the application.

   5. Upon completing the application online, the IMG will be prompted to pay the STTMS pathway application fee. This fee must be paid for the application to be assessed, or the application will expire.

   6. Where an application expires, the IMG will be required to reapply.

8. Assessment process

8.1 The RACGP will make an assessment within eight calendar weeks of the complete application and application fee being received. Ahpra and other agencies will have their own processing times.

8.2 If the RACGP determines the training position is suitable for the IMG:

1. 1. The IMG and the MBA will be notified of the RACGP’s support for the proposed position via email, with the completed AAMC-30 application form attached.

   2. The RACGP will upload the IMG’s application to the IMG’s AMC portal.

   3. The IMG must then apply to Ahpra for Limited registration for post graduate training or supervised practice.

8.3 If the RACGP determines the training position is unsuitable for the IMG:

1. 1. The IMG and the MBA will be notified of the RACGP’s non-support via email, with the completed AAMC-30 Application form attached.

   2. The RACGP will upload the IMG’s application to the IMG’s AMC portal.

8.4 IMGs who believe the RACGP has made an incorrect decision in relation to the conduct or outcome of their application for the STTMS pathway can apply for reconsideration as per the Dispute, Reconsideration and Appeals Policy.

9. Change in circumstances including extensions

9.1 Where the IMG requests a change in circumstances as per those listed in the ACCL-30 form (Request for change in circumstances for IMG with limited or provisional registration), they must apply to the MBA for an approval of change in circumstances.

1. 1. Extensions to continue practising on the STTMS pathway may be supported by the RACGP if the IMG’s complete training time on the STTMS pathway will be 24 calendar months or less.

   2. Extensions to continue practising on the STTMS pathway for more than 24 calendar months will not be supported by the RACGP.

   3. When an extension is supported, the RACGP will request a work performance report from the IMG and employer along with any other documents deemed necessary by the RACGP.

9.2 Additional fees may apply if changes are requested to an approved STTMS pathway application. This includes changes to the approved training site, Supervisors, and dates and/or details of the training position.

10. 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.

11. Responsibilities

Censor-in-Chief	Approving Minor Amendments Approving Moderate Amendments Approving Consequential Amendments
Employer	Completing the AAMC-30 form (Part A) with the IMG and Supervisor Completing the RACGP application with the IMG Responding to requests for additional information
IMG	Securing an offer of a training position Meeting the requirements of eligibility for the STTMS pathway Completing the AAMC-30 Form (Part A) with their employer Completing the RACGP application with their employer Paying the application fee Responding to requests for additional information Meeting the requirements for Limited Registration Applying for and maintaining eligibility for their own Medicare provider number
RACGP	Assessing if the applicant is a genuine specialist-in-training or Internationally Qualified Specialist Assessing if the position is a Genuine Training Position that is appropriate for the applicant’s level of training and experience Assessing if the position offers adequate supervision and support for the applicant’s level of training and experience and adheres to the MBA’s guidelines for the supervision of IMGs Providing a recommendation to the MBA for the purposes of Limited Registration only Notifying the IMG and MBA of the recommendation for the purposes of Limited Registration within eight calendar weeks of a complete application and application fee being received
RACGP Board	Approving Major Amendments
Supervisor	Completing the AAMC-30 application form (Part A) with the employer and IMG employee Providing adequate supervision and support for the applicant's level of training and experience Adhering to the MBA’s guidelines for the supervision of IMGs

12. Glossary

Comprehensive Australian General Practice	As defined in the Comprehensive Australian general practice guide.
Consequential Amendment	An amendment that requires urgent implementation as a necessary result of an amendment to another policy or process.
Full-time Training	A 38-hour working week, over a minimum of four days per week. A minimum of 27 hours must be in face-to-face, rostered, patient consultation time undertaking general practice activities. Work periods of less than three consecutive hours, or less than 4 calendar weeks in any one practice, will not be considered. Hours worked beyond this definition of full time will not be considered.
Genuine Training Position	As per the Medical Board of Australia’s definition in the Guidelines: Short-term training in a medical Specialty  for international medical graduates who are not qualified for general or specialist registration.
Internationally Qualified Specialist	As per the Medical Board of Australia’s definition in the Guidelines: Short-term training in a medical Specialty  for international medical graduates who are not qualified for general or specialist registration.
International Specialist-in-training	As per the Medical Board of Australia’s definition for ‘genuine specialist in training’ in the Guidelines: Short-term training in a medical Specialty  for international medical graduates who are not qualified for general or specialist registration.
Limited Registration	As per the Medical Board of Australia’s definition.
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).
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.
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).
RACGP-Approved Program	An education or training program approved by the RACGP as a suitable pathway to Fellowship, including: Australian General Practice Training Program, Remote Vocational Training Scheme, Fellowship Support Program, Practice Experience Program – Standard Stream Practice Experience Program – Specialist Stream Partially Comparable, and Practice Experience Program – Specialist Stream Substantially Comparable. These training programs are approved specified programs listed in Division 6 of the Health Insurance Regulations 2018.
Short-term Training in a Medical Specialty (STTMS) Pathway	The MBA pathway to short-term medical registration that allows IMGs who are qualified specialists or specialists-in-training to undertake a short period (up to 24 calendar months) of training in a particular medical specialty area in Australia.
Supervisor	A general practitioner who is both a clinician and a role model, who takes responsibility for the educational and training needs of the IMG while in the practice, in adherence with the Medical Board of Australia's Supervised practice for international medical graduates guidelines.

13. Related documents, legislation and policies

• Dispute, Reconsideration and Appeals Policy

• Medical Board of Australia Guidelines: Short-term training in a medical specialty for international medical graduates who are not qualified for general or specialist registration

• Medical Board of Australia Supervised practice for international medical graduates guidelines

• Medical Board of Australia Limited Registration for Postgraduate Training or Supervisor Practice Registration Standard

14. 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.