Practice Experience Program – Specialist Stream Comparability Assessment

1.1 Applicants to the Practice Experience Program (PEP) Specialist Stream are required to undertake a Comparability Assessment prior to applying for entry into the Program.

1.2 This policy aims to:

1. describe the assessment of applicants’ comparability to an Australian-trained specialist general practitioner at the point of Fellowship; and
2. specify the requirements concerning the provision and disclosure of applicant information.

2.1 The PEP Specialist Stream is the pathway to Fellowship of the RACGP (FRACGP) 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 the Specialist Recognition Program (SRP), which superseded the SPP from 2018 to 2019.

2.2 From 1 September 2019, the Specialist Pathway to Fellowship was recognised 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 were required to work under supervision under limited or provisional registration from the Medical Board of Australia. The RACGP issued PEP provider numbers to eligible SIMGs to permit access to A1 Medicare rebates.

3.1 This policy applies to all SIMGs wishing to pursue Fellowship of the RACGP via the Medical Board of Australia’s Specialist Pathway – specialist recognition.

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

3.3 This policy replaces the previous Practice Experience Program – Specialist Stream Policy and will come into effect as of 1^st April 2021.

3.4 Participants enrolled in the Specialist Pathway Program (SPP) or SRP before 31 August 2019 continued their candidacy under policies in existence at the time of their enrolment in the SRP or SPP.

3.5 Please read this policy in conjunction with the Practice Experience Program – Specialist Stream Assessment of Recency Policy.

3.6 Where there is inconsistency, this policy overrides.

4.1 General principles

1. Applicants for the PEP Specialist Stream must submit all information relevant to the Comparability Assessment as outlined in A Guide to Completing the PEP Specialist Stream Comparability Assessment.
2. RACGP assessors will use the information and evidence provided by the applicant to determine the comparability of the applicant to an Australian-trained specialist general practitioner at the point of Fellowship.
3. Where the RACGP receives publicly available information about an applicant that may inform the assessment decision, the applicant will be given the opportunity to make a submission about the information.

4.2 Comparability factors

The Comparability Assessment will assess SIMGs according to the following factors:

1. Recency

   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. 18 months’ FTE general practice experience prior to the date of application for the Comparability Assessment being accepted.
   4. For the RACGP to assess an applicant as substantially comparable, the applicant must have undertaken both the 12 month and four week experience requirements in a practice assessed as at least 85% comparable to comprehensive Australian general practice.
   5. For the RACGP to assess and applicant as partially comparable, the applicant must have undertaken both the 12 month and four week experience requirements 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.

   Assessments of recency will be made in line with the Practice Experience Program – Specialist Stream Assessment of Recency Policy.

2. Continuity of Practice

   All applicants must explain gaps in clinical practice of greater than three calendar months in their comparability assessment.

3. Continuing Professional Development

   All applicants must have:

   1. 50 hours of documented Continuing Professional Development (CPD)with the criteria outlined in clause 3.3.4 of A guide to completing the PEP Specialist Stream Comparability Assessment;  and
   2. documented evidence of completing a practice-based self-reflective activity using validated tools in the 36 calendar months preceding Comparability Assessment.

4. Assessment type
   1. Substantially comparable applicants have satisfactorily completed a highly reliable summative assessment using validated assessment instruments comprising both theoretical and practical components equivalent to those utilised within RACGP assessments and examinations.
   2. Partially comparable applicants have satisfactorily completed a summative assessment as mandated by the organisation granting their specialist qualification, but the RACGP deems examination was not equivalent to those components utilised within RACGP assessments and examinations.
   3. The RACGP deems applicants without any formal summative assessment not comparable.

5. Training route

   All applicants must have a specialist general practice qualification.

   1. Substantially comparable applicants have completed their specialist general practice qualification in a training program comparable to the RACGP Vocational Training Pathway. Substantially comparable training programs include summative assessments, formal education programs, and at least 12 months’ supervised in-practice training in a safe and supportive clinical environment.
   2. Partially comparable applicants have obtained their specialist general practice qualification predominantly in work experience at least 75% comparable, via a training program significantly different to the RACGP Vocational Training Pathway, or via an experience-based pathway, largely comprising supervised clinical work which may or may not have included formative assessments or formal educational programs.
   3. Applicants who received their qualification via grandfathering, reciprocal arrangements or other honorary routes are deemed not comparable.

6. Curriculum
   1. Substantially comparable curricula sufficiently cover the RACGP Curriculum such that the applicant is suitable to practice in Australian general practice, with only limited supervision and peer review.
   2. Partially comparable curricula have gaps, compared to the RACGP curriculum, which can be rectified in up to 24 months’ FTE work in Australian general practice, and the coverage of which must be assessed by formal examination.
   3. Curricula assessed as having gaps which cannot be rectified within 24 months’ FTE work in Australian general practice are deemed not comparable.

7. Additional formalised training
   1. Applicants who have qualified under a partially comparable curriculum can show that they have addressed the gaps in that curriculum with subsequent study, CPD, clinical exposure or other relevant experience.
   2. If the sum of the partially comparable applicant’s experience since obtaining their specialist general practice qualification sufficiently covers the identified gaps, the RACGP may deem the applicant substantially comparable.

8. Assessment outcome
   1. Applicants must provide current, full and verifiable information in their application with sufficient detail to assess comparability.
      1. The RACGP will take reasonable steps to verify the information provided; additional information or documentation may be requested to substantiate the assessment.
      2. Submission of plagiarised, false or misleading information will be handled as per the Academic Misconduct Policy.
   2. If the applicant believes the assessment was made incorrectly, they may apply for reconsideration of their assessment outcome as per the Dispute, Reconsideration and Appeals Policy. An applicant must submit their reconsideration to the RACGP within 10 business days of being notified of the original decision.
   3. The applicant may choose to repeat the Comparability Assessment and may take the opportunity to complete further CPD or additional education, improve their recency of practice, or gain additional experience in general practice before submitting a new assessment.
      1. Comparability Assessment outcomes are valid for 12 calendar months from the date of the outcome.