From 22 November 2023 an exemption will apply to the following Continuing Professional Development (CPD) requirements for Comparability Assessments:
- Any 50 hours of CPD in the 12 months prior to applying for your comparability assessment will be eligible to be assessed – the requirements for demonstrating breadth and a limit on the maximum hours per day will be removed (clause 3a).
- Ten Clinical Case Analyses will no longer be required to be submitted or assessed (clause 3b)
This will apply to all pending and new applications. You do not need to contact the RACGP to confirm this change if you have an application pending, the exemption to the requirement will be automatically applied.
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:
- describe the assessment of applicants’ comparability to an Australian-trained specialist general practitioner at the point of Fellowship; and
- 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:
- the Specialist Pathway Program (SPP), which ran from 2010 to 2018, and categorised SIMGs as Category 1, 2 or 3, or not comparable; and
- the Specialist Recognition Program (SRP), which superseded the SPP from 2018 to 2019.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 1st 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. Comparability assessment
4.1 General principles
- 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.
- 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.
- 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:
All applicants must have completed:
- 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.
- 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.
- 18 months’ FTE general practice experience prior to the date of application for the Comparability Assessment being accepted.
- 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.
- 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.
- Continuity of Practice
All applicants must explain gaps in clinical practice of greater than three calendar months in their comparability assessment.
- Continuing Professional Development
All applicants must have:
- 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
- documented evidence of completing a practice-based self-reflective activity using validated tools in the 36 calendar months preceding Comparability Assessment.
- Assessment type
- 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.
- 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.
- The RACGP deems applicants without any formal summative assessment not comparable.
- Training route
All applicants must have a specialist general practice qualification.
- 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.
- 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.
- Applicants who received their qualification via grandfathering, reciprocal arrangements or other honorary routes are deemed not comparable.
- 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.
- 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.
- Curricula assessed as having gaps which cannot be rectified within 24 months’ FTE work in Australian general practice are deemed not comparable.
- Additional formalised training
- 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.
- 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.
- Assessment outcome
- Applicants must provide current, full and verifiable information in their application with sufficient detail to assess comparability.
- The RACGP will take reasonable steps to verify the information provided; additional information or documentation may be requested to substantiate the assessment.
- Submission of plagiarised, false or misleading information will be handled as per the Academic Misconduct Policy.
- 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.
- 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.
- Comparability Assessment outcomes are valid for 12 calendar months from the date of the outcome.
5. Amendment of this Policy
The CIC may, without the consent of the Board, make Minor, Moderate and Extenuating Amendments to this policy at any time.
If the CIC makes amendments, they must advise the Board of those amendments as soon as practicable.
The Board may make amendments to this policy at any time.
Responsible for approval of policy and Major Amendments.
Responsible for Amendments of this policy
Responsible for submitting their comparability assessment with current, full and verifiable information with sufficient detail to assess comparability.
Responsible for assessing the comparability assessment and providing an outcome to the applicant.
Acceptance of application
the date on which the Comparability Assessment application is accepted. It is defined by the date the applicant duly signs the statutory declaration in the application.
a medical practitioner who is applying for entry onto the PEP Specialist Stream.
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 Fellowship:
- 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;
- Partially comparable means the applicant has been assessed as suitable to undertake work in general practice in a supervised capacity and able to reach comparability within 24 months’ FTE, with a maximum time on the program of 48 months if working part time;
- 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. Applicants assessed as not comparable may apply for the PEP Standard Stream.
Comprehensive Australian general practice
- continuity of care that is person centred, comprehensive and coordinated; focusing on the whole person, and all presenting symptoms;
- health promotion and illness prevention services that are based on patient need and the best available evidence;
- 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
- community-based general practice undertaken in Australia.
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
a medical practitioner who has been accepted into the PEP Specialist Stream.
PEP Specialist Stream
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.
clinical recency in general practice, and is not the same as with 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.
supervision in line with the principles of supervision and supervised practice, based upon the prescribed Medical Board of Australia Guidelines – Supervised Practice of International medical graduates.
Validated assessment instruments
theoretical and practical assessments recognised by the RACGP.
8. Related Documents, Legislation and Policies
9. Policy Review and Currency
This policy will be reviewed every three 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.
Date of effect
Comparability assessment validity
Policy Advisor, Strategy and Development
|Addition of clause 3.2 –clarification of Comparability Assessment scope
|Policy Advisor, Strategy and Development
|Addition of clause 4.2.1.c – reuqirement for general practice experience
|Policy Officer, Education Policy and Guidance
Next Review Due: