Supplementary memorandum by the General
Medical Council
ARRANGEMENTS FOR REGISTERING OVERSEAS QUALIFIED
DOCTORS (GMC2)
1. The framework for the registration of
overseas qualified doctors is contained in Part III of the Medical
Act 1983. Broadly speaking, overseas qualified doctors can be
split into three groups: those eligible for limited registration
under section 22 of the Act, those eligible for provisional or
full registration under sections 19-21 of the Act, and those eligible
for temporary full registration under section 27 of the Act.
LIMITED REGISTRATION
2. Section 22 of the Act requires applicants
for limited registration to satisfy the Registrar on the following
points:
(a) They must have been selected for employment
in a hospital or other institution approved by the GMC (see paragraphs
15-16 below).
(b) They must hold an overseas primary medical
qualification which is accepted by the GMC (see paragraphs 3-6
below).
(c) They must have the necessary knowledge
of English (see paragraph 10 below).
(d) They must be of good character (see paragraphs
11-14 below).
(e) They must have the knowledge, skill and
experience which are necessary for practice under limited registration,
and which are appropriate in their case (see paragraphs 7-9 below).
Our arrangements of granting limited registration
are intended to address each of these requirements.
Acceptable qualifications for limited registration
3. All applicants for limited registration
must provide us with original documentary evidence of their primary
medical qualifications. This must be in the form of either an
original diploma or original certificate from the awarding body.
The certificate must bear the stamp or insignia of the university
or carry other evidence of authenticity. It must also be signed
by a person whose name and official position at the university
are identified.
4. Until 1996 we maintained a list of some
900 overseas primary qualifications which were accepted for the
purposes of limited registration. However, it was impossible to
maintain up to date information about the medical schools on the
list. The system was also arbitrary and inequitable. It discriminated
against competent doctors whose medical schools were not on the
list and gave no assurance of the current capabilities of doctors
whose medical schools were listed. We addressed these problems
in two ways.
5. First, we discontinued our own list of
qualifications in favour of the much more extensive list contained
in the World Health Organisation's World Directory of Medical
Schools. Any doctor whose primary medical qualification is
contained in the Directory is now eligible to apply for limited
registration. However, the WHO Directory is still just a list
of medical schools. It provides no guarantees regarding the standards
achieved by the individuals who qualify at those schools. Crucially,
it also tells us nothing about the capabilities of individuals
at the point they come to the UK for registration.
6. Our second step, therefore, was to shift
our focus away from primary medical qualifications and more clearly
onto doctors' current knowledge and skills.
Assessing Applicants' Knowledge, Skills and Experience
for Limited Registration
7. Although the law requires all applicants
for limited registration to have an acceptable qualification,
we know that we cannot rely on doctors' qualifications as evidence
of their capability to practise in the UK. All applicants must
therefore provide us with objective evidence of their current
capability to practise. They can do this in a number of ways.
8. The most common means for overseas qualified
doctors to demonstrate their competence is by passing the Professional
and Linguistic Assessments Board (PLAB) test. About half of all
new applicants for limited registration each year will have passed
the test.
9. Of those who do not take the PLAB test,
most doctors are sponsored either by one of the Medical Royal
Colleges or the British Council under quality assured arrangements
which we have approved. Further details of this and other routes
to limited registration are contained in the Note at Annex A.
Assessing Knowledge of English
10. Prior to 1996 the PLAB test incorporated
a test of English. In 1996 we introduced the British Council's
International English Language Testing System (IELTS) examination
as a standard test of language proficiency for prospective PLAB
test candidates. In 1998 this was extended to all applicants for
limited registration. Doctors are not permitted to take the PLAB
test or apply for limited registration until they have demonstrated
their knowledge of English by achieving a satisfactory IELTS score.
Assessing good character for limited registration
11. Applicants for limited registration
must make a declaration on the application form stating whether
they have been:
(a) Convicted of a criminal offence,
(b) Suspended from duty as a doctor in any
country,
(c) Refused registration or had their registration
removed or suspended in any country; and
(d) Whether there are any proceedings contemplated
in any country or any other matters which may lead to their registration
in that country being removed, suspended or restricted in any
way.
12. A positive declaration in respect of
any of the above will lead us to make further enquiries and may
result in a refusal to grant registration if the doctor cannot
be deemed of good character.
13. In addition to requiring the voluntary
declaration described above, we also receive notifications from
regulatory bodies overseas when they take disciplinary action
against doctors within their jurisdictions. We, in turn, inform
them of action that we have taken. We know, however, that the
exchange of information is not comprehensive. There are many countries
from which we receive no information. We are working to improve
our links with other bodies, but it is unrealistic to expect that
we will ever plug all of the gaps.
14. To address this weakness in the system,
we are introducing a requirement for all new applicants for limited
registration to provide further evidence of their identity and
of their good standing overseas.
Selection for employment
15. The law requires that before limited
registration can be granted a doctor must have been selected for
employment in a hospital or other institution approved by the
GMC. It also requires doctors with limited registration to work
under the supervision of a fully registered medical practitioner.
They may not undertake any form of independent medical practice.
16. All NHS hospitals are approved institutions
for the purposes of limited registration. We also restrict doctors
to appointments which are approved for education and training
purposes by the relevant Medical Royal College. This provides
protection for the public and ensures that overseas qualified
doctors have the opportunity to acquire the knowledge, skills
and experience necessary for them to progress to full registration.
PROCEEDING FROM
LIMITED TO
FULL REGISTRATION
17. Under section 25 of the Medical Act
1983, a doctor who has held limited registration may apply to
proceed from limited to full registration. Limited registration
is therefore the stepping stone to full registration.
What knowledge, skills and experience are required
for full registration?
18. The Act does not specify the knowledge,
skills and experience required for full registration. The Registration
Committee has determined, however, that applicants must demonstrate
the knowledge, skills and attitudes equal to those which would
be expected of a competent senior house officer. This is the grade
at which UK qualified doctors would first hold full registration.
The level of competence achieved is evidenced primarily by reports
on the applicants' performance during the course of two years'
practice under limited registration.
PROVISIONAL AND
FULL REGISTRATION
19. Most overseas qualified doctors are,
by virtue of where they qualified, only eligible for limited registration
when they first come to the UK (See paragraphs 3-5 above). However,
there are currently 22 overseas primary medical qualifications
which are recognised under section 19 of the Act for provisional
and full registration. These are qualifications awarded in the
following countries: Australia, Hong Kong, New Zealand, Singapore,
South Africa and West Indies. This arrangement will cease with
the introduction of the single form of registration for all overseas
qualified doctors.
20. The Act requires applicants for full
registration to satisfy the Registrar that:
(a) They hold a recognised overseas qualification
(see paragraph 21).
(b) They have the necessary knowledge of
English (see paragraph 22).
(c) They are of good character (see paragraphs
23-24).
(d) They have either completed the internship
prescribed for UK graduates or experience in the UK or overseas
which is not less extensive than that prescribed for UK graduates
before full registration (see paragraphs 25-26). For doctors who
have yet to complete this experience, we will grant provisional
registration which will enable them to acquire the necessary experience
in pre-registration house officer posts in the UK.
Recognised qualifications
21. Like applicants for limited registration,
doctors seeking full registration must provide documentary evidence
of their primary medical qualifications, either in the form of
an original diploma or an original certificate from the university
which awarded the qualification.
Assessing knowledge of English
22. Since January 1999 all applicants for
provisional and full registration have been required to demonstrate
their language proficiency by achieving a satisfactory score in
the IELTS examination.
Assessing good character
23. Like applicants for limited registration,
doctors are required to state on the application form whether
they have ever been convicted of a criminal offence, suspended
from duty, or subject to disciplinary proceedings in any country
(see paragraph 11).
24. In addition, we also have good working
relations with the registration authorities in most of the countries
which award recognised qualifications. This means that we regularly
receive notifications from those authorities about doctors who
have been subject to disciplinary proceedings within their jurisdictions.
We are able to take this information into account should we receive
an application from a doctor who has been subject to such proceedings.
Assessing experience for full registration
25. Historically, the systems of medical
education and training in the countries which award recognised
qualifications have mirrored those in the UK. We therefore accept
evidence of full registration in those countries as evidence that
a doctor has completed the experience required for full registration
in this country. Applicants are asked to provide an original certificate
of full registration issued by the registration authority in the
country concerned.
26. As an alternative to evidence of full
registration overseas, we will accept original certificates of
professional experience which demonstrate that an applicant has
completed experience here or overseas which is no less extensive
than that required for UK graduates.
TEMPORARY FULL
REGISTRATION
27. Temporary full registration under section
27 of this Act is intended to enable senior specialists from overseas,
who would otherwise be eligible only for supervised employment
under limited registration, to come to the UK temporarily to provide
medical services of a specialist nature. Unlike their colleagues
under limited registration, they come here not to receive training,
but to provide training or other medical services which are not
available in this country. Typically, such a doctor might be a
senior clinician from the United States who is here to demonstrate
a particular technique or perform a single operation. The criteria
specified in the Act for the grant of temporary full registration
are that the applicant must:
(a) hold a qualification accepted or recognised
by the GMC (see paragraph 28).
(b) possess special knowledge of and skill
in a particular branch of medicine (see paragraph 29).
(c) be intending to provide medical services
which are within the branch of medicine in which he or she has
special knowledge and skill.
Qualifications
28. Applicants must provide original documentary
evidence of their primary qualifications. The nature of the evidence
required is the same as that for doctors seeking limited registration
(see paragraph 3).
Establishing specialist knowledge and skill
29 Applicants must provide original documentary
evidence of their specialist medical qualifications awarded overseas,
or of their specialist registration overseas.
Knowledge of English and good character
30. It should be noted that section 27 of
the Act does not require applicants to satisfy us as to their
knowledge of English or good character. Accordingly, it would
be illegal for us to require evidence relating to either of these
elements.
16 March 2000
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