Practice Experience Program – Specialist Stream Assessment of Recency

1. Practice Experience Program – Specialist Stream Assessment of Recency Policy

1.1 Policy number: CO-E-0053.0

1.2 Category: Education

1.3 Approval date: September 2019

1.4 Revision due date: September 2022

1.5 Unit responsible: Education Services

2. Policy declaration

This policy describes the principles which underpin assessments of recency under Comparability Assessments for specialist international medical graduates (SIMGs) in general practice.

3. Background, objectives and scope

3.1 Background

1. The PEP Specialist Stream is the pathway to Fellowship of the RACGP available to specialist international medical graduates (SIMGs). Previous iterations of this pathway include:
   1. the Specialist Pathway Program (SPP), which ran from 2010 to 2018, and categorised SIMGs as Category 1, 2 or 3, or not comparable; and
   2. the Specialist Recognition Program (SRP), which superseded the SPP from 2018 to 2019.
2. From 1 September 2019, the Specialist Pathway to Fellowship will fall under the PEP as a specialist stream. This adjustment supports the removal of Fellowship ad eudem gradum (FAEG) to ensure a robust and more uniform approach to the assessment of SIMGs. From this time, SIMGs will be required to work under supervision under limited or provisional registration from the Medical Board of Australia. The RACGP will issue PEP provider numbers to eligible SIMGs to permit access to A1 Medicare rebates.

3.2 Objectives

This policy aims to:

1. describe how recency will be assessed as part of a Comparability Assessment;
2. detail the requirements concerning the provision and disclosure of applicant information.

3.3 Scope

This policy applies to SIMGs wishing to have their comparability assessed by the RACGP for the Medical Board of Australia’s specialist pathway – specialist recognition.

4. Definitions

For the purposes of this policy:

1. Acceptance of application means the date on which the Comparability Assessment application is accepted. It is the date that all necessary documents are received by the RACGP. As this date is used to determine timeframes for certain requirements, delays in submitting documentation may affect the validity of other, already submitted documents.
2. Applicant means an SIMG who is applying for a Comparability Assessment prior to applying for entry into the PEP Specialist Stream.
3. Comparable/comparability means the extent to which an SIMG’s recency is assessed as equivalent to an Australian-trained specialist general practitioner at the point of Fellowship.
   1. Substantially comparable means the applicant has been assessed as suitable to undertake the full scope of practice in general practice, taking full responsibility for all patients, with limited oversight of their practice by a supervisor (peer review) and reach comparability within 12 months' full time equivalent (FTE) practice, with a maximum time on the program of 24 months if working part time;
   2. Partially comparable means the applicant has been assessed as suitable to undertake work in general practice in a supervised capacity and is able to reach comparability within 24 months’ full time equivalent (FTE) practice, with a maximum time on the program of 48 months if working part time;
   3. Not Comparable means the applicant does not meet the comparability requirements of the PEP Specialist Stream, or is assessed as unable to reach comparability within 24 months’ FTE practice.
4. Comprehensive Australian general practice means:
   1. continuity of care that is person centred, comprehensive and coordinated; focusing on the whole person, and all presenting symptoms;
   2. health promotion and illness prevention services that are based on patient need and the best available evidence;
   3. the diagnosis, treatment and management of the full range of undifferentiated conditions in a diverse range of individuals, families and communities not limited by practice intention or business focus; and
   4. general practice undertaken in Australia.

This is an abridged definition distilled from the Competency profile of the Australian general practitioner at the point of Fellowship.

5. Full time general practice experience comprises a 38-hour minimum working week, over a minimum of four days per week, of which 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 of less than one month in any one practice, will not be considered. Hours worked beyond this definition of full time will not be considered.
6. Participant means a medical practitioner who has been accepted into the PEP Specialist Stream.
7. Part time general practice experience is calculated pro-rata against the definition of full time general practice experience. Part time general practice must comprise a 14.5-hour minimum working week, over a minimum of two days per week, of which a minimum of 10.5 hours must be in face-to-face, rostered, patient consultation time undertaking general practice activities. Work periods of less than three consecutive hours, or of less than one month in any one practice, will not be considered.
8. PEP Specialist Stream means the route to Fellowship available to SIMGs who have been assessed as substantially or partially comparable to an Australian-trained specialist general practitioner at the point of Fellowship.
9. Recency means clinical recency in general practice, and is not the same as continuity of employment. Recency is assessed under the RACGP’s Practice Experience Program – Specialist Stream Assessment of Recency Policy. Please note the RACGP’s assessment of recency differs from the Medical Board of Australia’s recency of practice standards.

5. General principles

5.1 Recency and comparability rating requirements

5.1.1 As per clause 5.2.1 of the RACGP’s Practice Experience Program – Specialist Stream Comparability Assessment Policy, all applicants must have completed:

1. 12 months’ FTE general practice in the 48 calendar months prior to the date of the application for Comparability Assessment being accepted, as assessed under the Practice Experience Program – Specialist Stream Assessment of Recency Policy.
2. At least four weeks’ FTE general practice in the 12 calendar months prior to the date of the application for Comparability Assessment being accepted, as assessed under the Practice Experience Program – Specialist Stream Assessment of Recency Policy.
3. To be assessed as substantially comparable, both the 12 month and four week experience requirements must have been undertaken in a practice assessed as at least 85% comparable to comprehensive Australian general practice.
4. To be assessed as partially comparable, both the 12 month and four week experience requirements must have been undertaken in a practice assessed as at least 75% comparable to comprehensive Australian general practice.

The requirements outlined in 1a and b above refer to clinical recency, not continuity of employment. Applicants who have taken leave for any reason during the 48 calendar months must still meet these requirements.

5.1.2 The process for applying for a recency assessment is detailed in the RACGP’s A Guide to completing the PEP Specialist Stream Comparability Assessment.

5.1.3 Recency is measured until the date the applicant signs the statutory declaration in their application for Comparability Assessment.

5.2 Assigning a comparability rating

Each clinical post is assessed and assigned one of the following comparability ratings:

1. Comprehensive Australian general practice: as defined in clause 4d of this policy and is rated as 100% comparable.
2. Substantially comparable: The post was undertaken within a comparable health system and covered the full range of presentations expected to be seen within a fully comparable comprehensive Australian general practice, but with a limited scope or demographic of patients. Health systems will be compared to the scope of general practice service to the Australian community in the ‘Competency profile of the Australian general practitioner at the point of Fellowship'. Posts of this type can count towards recency for substantially and partially comparable outcomes.
3. Partially comparable: The post covered the full range of presentations expected to be seen within a fully comparable comprehensive in-clinic Australian general practice, except with a somewhat limited scope of practice due to a slightly limited demographic of patients, or due to management somewhat different to that of comprehensive Australian general practice. Posts of this type count towards recency for partially comparable outcomes, and can count towards recency for substantially comparable outcomes if undertaken concurrently with work as described in clause 5.2 a – b.
4. 50% comparable: The post involved a limited scope of practice due to a limited demographic of patients, a limited range of presentations, and/or limited management options, compared to that of comprehensive in-clinic Australian general practice, or the post was primarily concerned with education, research or teaching of general practice. Posts of this type do not count towards recency, unless combined with work as described in clause 5.2 a – c.
5. Not comparable: hospital experience or otherwise not comparable to comprehensive Australian general practice.

5.3 Assessment of recency

5.3.1 Only general practice work done in the four years prior to the date of signing the statutory declaration in the application process will be assessed.

5.3.2 Full time general practice experience may include up to four weeks’ annual leave per year.

5.3.3 General practice experience may be undertaken outside of normal working hours. In such cases the assessment will be based on the type of work performed and the clinical scope of practice, compared to comprehensive Australian general practice.

5.3.4 The minimum part time working week (detailed in clause 4g) may comprise two separate jobs, of which one must be in clinical general practice and must include at least a minimum of 7 hours face-to-face, rostered patient consultation time undertaking general practice activities as defined in clause 5.2a – c. The second job must also relate to general practice, as defined in clause 5.2a – d. 

5.3.5 When an applicant is working in excess of 38 hours per week, the most comparable posts will be selected to make up the 38 assessable hours.

5.3.6 Only clinical general practice experience following the awarding of the primary medical qualification and the completion of internship will be assessed.

5.3.7 An applicant who satisfies the recency requirement as stipulated in clause 5.1.1b but fails to meet the recency requirement as stipulated in clause 5.1.1a of this policy may still be granted entry into the PEP Specialist Stream if they have been assessed as having completed between nine and 12 months’ FTE general practice in the 48 calendar months prior to the date of the application for Comparability Assessment being accepted. The shortfall required to be met (up to three months’ FTE comprehensive general practice) will be added to the participant’s total time in the program. The participant must also satisfy the recency requirement as stipulated in clause 5.1.1b of this policy or as varied by clause 5.3.8 below. There will be no extension of the participant’s maximum time on the program.

5.3.8 An applicant who satisfies the recency requirement as stipulated in clause 5.1.1a but fails to meet the recency requirement as stipulated in clause 5.1.1b of this policy may still be granted entry into the PEP Specialist Stream. The applicant must complete four weeks’ FTE in comprehensive Australian general practice whilst in the program, and satisfy the recency requirement as stipulated in clause 5.1.1a of this policy or as varied by clause 5.3.7 above.

5.3.9 The RACGP recommends that an applicant who fails to meet the recency requirements as stipulated in clause 5.1.1a and 5.1.1b make up the remaining time in the country in which they are currently residing and reapply for a Comparability Assessment upon perceived satisfaction of the recency requirements.

If the applicant has already settled in Australia, the applicant may still be granted entry into the PEP Specialist Stream, at the RACGP’s discretion. The applicant must satisfy the recency requirements as stipulated in clause 5.1.1a and b of this policy or as varied by clause 5.3.7 or 5.3.8 above. Any additional time required to satisfy the requirements of 5.3.7 or 5.3.8 will be in addition to the required six month FTE supervised practice and will extend the program length..

5.4 Provision and disclosure of information

5.4.1 Applicants must provide current, full and verifiable information in their application. Post descriptions must be individualised and include breakdowns of both clinical and non-clinical tasks. Duplicated descriptions of posts will not be accepted. An RACGP Assessor will take reasonable steps to verify the information provided. Submission of plagiarised, false or misleading information will be handled as per the RACGP’s Academic Misconduct Policy.

5.4.2 Applicants must disclose in their application all details of any:

1. any past or present restrictions, conditions, suspensions and/or undertakings on, or changes to, their medical registration; and
2. regulatory authority activity, whether in Australia or otherwise, that:
   • has led or may lead to a restriction, condition, suspension and/or undertaking on practice; or
   • has led to an adverse finding for the medical practitioner, or forms part of an ongoing investigation.

Failure to do this will be handled as per the Academic Misconduct Policy

5.5 Outcome

5.5.1 Applicants who meet the recency requirements for entry into the PEP Specialist Stream must also meet the other comparability factors detailed in the Practice Experience Program – Specialist Stream Comparability Assessment Policy in order to be eligible for entry into the PEP Specialist Stream.

5.5.2 Applicants who contend their recency assessment was made incorrectly may apply for reconsideration as per the RACGP’s Dispute, Reconsideration and Appeals Policy.

An application for reconsideration must be submitted to the RACGP within 10 business days of being notified of the original decision.

6. Related policies, documents and legislation

All policies and procedures are available at the policy page.

7. Administrative procedures

7.1 Access to published policy

This policy will be available via the RACGP website as detailed in clause 6.

7.2 Promulgation of published policy

Relevant staff members will be provided communications explaining the function and role of this policy.

7.3 Review of this policy

This policy will have a review cycle of three years.