Reg 23 Recognition as a specialist in anaesthesia for International Medical Graduate Specialists (IMGS) and admission to Fellowship by assessment for IMGS

23. RECOGNITION AS A SPECIALIST IN ANAESTHESIA FOR INTERNATIONAL MEDICAL GRADUATE SPECIALISTS (IMGS) AND ADMISSION TO FELLOWSHIP BY ASSESSMENT FOR IMGS

(Effective as from 1 February 2011)

The Australian and New Zealand College of Anaesthetists (ANZCA) does not register specialists. On request, ANZCA will conduct an assessment regarding specialist recognition and provide advice to relevant authorities in Australia and New Zealand. Applications for assessment of specialist qualifications in Australia must be made to the Australian Medical Council (AMC) and applications for medical registration must be made to the Medical Board of Australia (MBA). IMGS with a basic medical degree from an Australian or New Zealand university who undertook their specialist training overseas should not apply through the AMC, but apply directly to ANZCA.  All applications in New Zealand must be made to the Medical Council of New Zealand (MCNZ).

• 23.1 An assessment undertaken by ANZCA on information supplied to it does not imply any recognition by ANZCA.
• 23.2 Support for an application for registration as a specialist in anaesthesia in Australia will be automatic in the case of a graduate in medicine from a medical school recognised by the AMC, who holds the Diploma of Fellowship of ANZCA, who is in active clinical practice, and who is participating in ANZCA’s Continuing Professional Development (CPD) program.
• 23.3 Support for an application for entry into the vocational scope of anaesthesia on the medical register of the MCNZ will be automatic in the case of a graduate in medicine from a medical school recognised by the MCNZ, who holds the Diploma of Fellowship of ANZCA, who is in active clinical practice, and who is participating in ANZCA’s CPD program.
• 23.4 For all other applicants, ANZCA’s support for an application for registration as a specialist in anaesthesia in Australia, or for entry into the vocational scope of anaesthesia on the medical register of the MCNZ, requires that:
• 23.4.1 The applicant has a basic medical qualification which is recognised by the AMC (for Australia), or a specialist qualification which is recognised by the MCNZ as providing an acceptable basis for vocational assessment (for New Zealand). 
• 23.4.2 The applicant has acceptable documentation of registration as a specialist (or equivalent) in anaesthesia in their country of training, together with acceptable proof of eligibility to work as a specialist in anaesthesia in that country.
• 23.4.3 The applicant has satisfied all the requirements of the IMGS assessment process.
• 23.5 The IMGS assessment process is not a specialist training program, but an evaluation of the ability of an IMGS to practise in Australia and / or New Zealand as an unsupervised specialist anaesthetist at a standard comparable to that required of a Fellow of ANZCA (FANZCA). The IMGS assessment process will be coordinated by the IMGS Committee. 
• 23.5.1 Assessment of documentation provided by the AMC or MCNZ on behalf of the IMGS is undertaken to arrive at a decision as to whether the applicant is potentially Substantially Comparable (SC) to a FANZCA, Partially Comparable (PC) to a FANZCA, or Not Comparable (NC) to a FANZCA.
• 23.5.1.1 Those assessed as NC are not considered further, and are so advised, via the AMC or MCNZ.
• 23.5.1.2 Those assessed as potentially SC or PC are invited to a face-to-face structured interview.
• 23.5.2 Those confirmed as SC at interview will normally be required to spend 12 months full time equivalent (FTE) in clinical anaesthesia posts in Australia and/or New Zealand that have been approved in advance by ANZCA. During this time they will be required to undergo Clinical Practice Assessment (CPA) and a Workplace Based Assessment (WBA).
• 23.5.3 Those confirmed as PC at interview will normally be required to spend 12 to 24 months FTE in clinical anaesthesia posts in Australia and/or New Zealand that have been approved in advance by ANZCA. During this time they will be required to undergo CPA and pass the Structured Performance Assessment or Final Examination.
• 23.5.4 All applicants must complete an Effective Management of Anaesthetic Crises (EMAC), Early Management of Severe Trauma (EMST), Advanced Trauma Life Support (ATLS) or comparable course, unless there is acceptable documentation confirming that this requirement has already been met.
• 23.5.5 All applicants must participate in the ANZCA CPD program.
• 23.5.6 Applicants may be required to address other specific deficiencies as assessed at the structured interview.
• 23.5.7 On completion of all requirements, applicants may apply for Fellowship of ANZCA.
• 23.6 Fees for components of the IMGS assessment process will be determined by ANZCA Council.
• 23.7 The Face-to-Face Structured Interview will be conducted by an IMGS Interview Panel (hereafter ‘the Panel’) that has mixed gender representation and community and / or jurisdictional representation.
• 23.7.1 In Australia, the Chair of the IMGS Committee will select a Panel that will comprise three ANZCA Fellows plus at least one community and / or jurisdictional representative. The Panel will be formed from the following: IMGS Committee Chair, Chair Final Examination Subcommittee, other members of the IMGS Committee, Councillors, Directors of Professional Affairs (DPAs), Fellows, and nominated community / jurisdictional representatives. The President should not normally be a member of the Panel. The Chair of the IMGS Committee or his / her nominee will be the Chair of the Panel.
• 23.7.2 In New Zealand, the New Zealand National Committee will form a Panel that will comprise three ANZCA Fellows plus at least one community and / or jurisdictional representative. The Panel will be formed from the following: Councillors resident in New Zealand, members of the New Zealand National Committee, Fellows, DPAs and nominated community and / or jurisdictional representatives. The President and the Chair of the New Zealand National Committee should not normally be members of the Panel.  The Chair of the New Zealand Panel for Vocational Registration or his / her nominee will be the Chair of the Panel.
• 23.7.3 The Panel will use the following criteria in assessing an applicant:
• 23.7.3.1 Evidence of completion, at any stage along the training pathway, of at least 12 months of broadly-based clinical experience in areas of practice other than clinical anaesthesia, intensive care medicine or pain medicine. This will usually be experience in surgery, emergency medicine, general medicine and related specialties, obstetrics, or general practice. The experience must have involved a significant degree of independence in practice, such as the authority to prescribe medicines without requiring endorsement by a senior colleague.
• 23.7.3.2 Comparability of the IMGS’s specialist anaesthesia training with the ANZCA Vocational Training Program with regard to duration, structure, content, sub-specialty experience, supervision and assessment. The onus will be on the applicant to provide evidence in this regard. The comparability of the health system of the country within which the training occurred to that in Australia and New Zealand will be considered, as will training in the context of a nationally consistent program that requires training institutions be accredited regularly against external standards.
• 23.7.3.3 Specialist qualifications and acceptable documentation indicating specialist status in the country of training. All documentation must be either originals or certified copies.
• 23.7.3.4 Experience as a specialist, in terms of case mix, use of equipment and drugs, and compliance with standards of anaesthesia practice as promoted in ANZCA Professional Documents and as practised in Australia and New Zealand. Consideration will be given to the curriculum vitae, references, and details of practice as a specialist anaesthetist.  Experience must be substantiated by acceptable documentation. The comparability of the health system of the country or countries, within which clinical experience as a specialist was obtained, to that in Australia and New Zealand will be considered.
• 23.7.3.5 Evidence of participation in CPD, comparable to ANZCA’s CPD Program. Continuous involvement in recent years is particularly important.
• 23.7.3.6 Where there has been a break in clinical practice of more than 12 months immediately prior to commencement of the IMGS assessment process, a formalised individual program following the principles set out in Professional Document PS 50 Recommendations on Practice Re-entry for a Specialist Anaesthetist and approved by the DPA (IMGS) or his/her nominee must be completed and approved before commencement of CPA.
  
  23.7.4 The Panel will recommend that the IMGS be allocated to one of the following:
• 23.7.4.1 SC: Eligible to proceed to a CPA period, normally of 12 months FTE, in a position approved by the DPA (IMGS) or his/her nominee. A comprehensive WBA must be completed satisfactorily.
• 23.7.4.2 PC: Eligible to proceed to a CPA period, normally of 12 to 24 months FTE, in a position approved by the DPA (IMGS) and eligible to proceed to the IMGS Performance Assessment or Final Examination. Exemption from the written section of the Structured Performance Assessment may be granted, having regard to significant achievement in the criteria in Regulation 23.7.3.
• 23.7.4.3 NC: Ineligible for further consideration under the IMGS assessment process. 
• 23.8 The IMGS Performance Assessment will be conducted by the Final Examination Subcommittee, usually at the same time as the Final Examination.
• 23.8.1 The IMGS Performance Assessment will comprise:
• 23.8.1.1 A written section that evaluates knowledge fundamental to anaesthesia practice, including relevant basic sciences.
• 23.8.1.2 A clinical section that evaluates clinical performance in a standardised setting. 
• 23.8.1.3 An oral section that provides a structured evaluation of the applicant’s applied clinical knowledge and decision making in a wide range of sub-specialties.
• 23.8.2 An applicant may choose to apply to present for ANZCA’s Final Examination in preference to the IMGS Performance Assessment. In these circumstances, the Final Examination will function as a surrogate for IMGS Performance Assessment within the IMGS assessment process.
• 23.8.3 A satisfactory CPA report covering at least 3 months FTE must have been received by the closing date for applicants to present for the IMGS Performance Assessment / Final Examination.
• 23.8.4 Provided the requirement of 23.8.3 is met, an application to sit the IMGS Performance Assessment / Final Examination may be submitted to the ANZCA at any time subsequent to the structured interview.
• 23.8.5 An entry form must be submitted and the fee paid by the specified closing date for the IMGS Performance Assessment / Final Examination.
• 23.8.6 Announcement of successful candidates will occur at the completion of the IMGS Performance Assessment / Final Examination and such candidates will be presented to the Court of Examiners.
• 23.9 The CPA period serves both to familiarise the applicant with anaesthesia practice in Australia and / or New Zealand, and to facilitate assessment of practice performance. In some cases, it may also address specific deficiencies in anaesthesia training or experience.
• 23.9.1 The duration of the CPA period will be determined by the Panel and will normally require a minimum of 12 months with a maximum of 24 months FTE. The total duration of training and experience may not be less than the minimum duration required for trainees in Australia and New Zealand.
• 23.9.2 The CPA period must be structured to allow the IMGS to satisfy any other specific requirements stipulated by the Panel.
• 23.9.3 The CPA period must be undertaken in Departments of Anaesthesia (or other organisations) in Australia or New Zealand accepted by ANZCA as appropriate for the assessment period. All positions to be considered towards the CPA period must be approved by the DPA (IMGS) in Australia or the Chair of the Panel for Vocational Registration in New Zealand, or their nominees. Positions for less than 3 months in duration FTE will not normally be approved for CPA.
• 23.9.4 The CPA Period may be undertaken on a part-time or interrupted basis subject to approval by the DPA (IMGS) in Australia or the Chair of the Panel for Vocational Registration in New Zealand, or their nominees. A part-time appointment should not normally be less than 0.5 FTE.
• 23.9.5 If the applicant, prior to the interview, is already working in a position suitable for the CPA period, this previous experience may, at the Panel’s discretion, be noted for possible recognition retrospectively. Such retrospective experience can be considered for a maximum of six months, provided the post meets the criteria determined at interview, and a suitable CPA Supervisor is nominated who is willing to act retrospectively in this capacity and provide a CPA report for that period. The final decision as to whether retrospective CPA will be approved will not be made until all other requirements have been completed satisfactorily.
• 23.9.6 In all other circumstances, the position and CPA supervisor must be approved prospectively. The applicant may commence the CPA period from the date of the structured interview. 
• 23.9.7 The IMGS Committee will approve a CPA Supervisor nominated by the employer to oversee each applicant’s CPA period. The Supervisor will provide a structured report of the applicant’s practice each 6 months, or as required, to the DPA (IMGS) in Australia, or the Chair of the New Zealand Panel for Vocational Registration in New Zealand, or their nominees. Based on these reports, the time may or may not be accredited towards the required duration of CPA and / or the IMGS Committee may review the initial assessment of the applicant.
• 23.9.8 The duration of CPA may be extended from the duration decided at the structured interview until all requirements have been fulfilled.  If the IMGS assessment process has not been completed within four years, the IMGS Committee will consider all relevant issues prior to deciding whether to terminate the IMGS assessment process. In exceptional circumstances, the IMGS Committee may grant an extension of time.
• 23.9.9 ANZCA has no responsibility on behalf of applicants for obtaining positions suitable for the CPA period.
• 23.10 The Workplace Based Assessment (WBA) is normally a one to two day comprehensive assessment that is held during the final 3 months of CPA in a hospital in which the IMGS provides clinical anaesthesia.  Where the Interview Panel has indicated the possibility of retrospective CPA, the WBA may be held at any time after 9 months of experience in a post suitable for CPA.
• 23.10.1 The WBA assesses professional performance with regard to the standard that would reasonably be expected of a Fellow of ANZCA at a comparable stage of his / her career.
• 23.10.2 The WBA will be conducted by two Fellows of ANZCA, at least one of whom must come from outside the IMGS’s region of practice.  The relevant Regional / National Committee of ANZCA may be asked to recommend a local Assessor.
• 23.10.3 The Assessors will be provided with relevant information about the IMGS and the hospital in which he / she practises.
• 23.10.4 The IMGS will be provided with detailed information about the process and the responsibilities of the IMGS regarding the planning of each day’s activities.
• 23.10.5 The WBA will include a preliminary interview, an assessment of anaesthesia records, observation of clinical practice, multi-source staff interviews, case-based discussions and an end-of-assessment interview.
• 23.10.6 Following the WBA, the Assessors will prepare a structured report with a recommendation that is reviewed by ANZCA and, in Australia, the final recommendation is then forwarded to the AMC. In New Zealand, the final recommendation is only forwarded to the MCNZ for those applicants who are not already vocationally registered.
• 23.10.7 The fee for this process is determined by ANZCA Council and is the responsibility of the applicant or the hospital administrator.
• 23.11 A serious breach of patient care or disciplinary action in respect of employment or medical registration is a matter for the employer or the relevant Medical Board / Council and not ANZCA. In some situations, it may be appropriate   or required for the Head of Department or other colleagues to report the matter to the Medical Board / Council. The IMGS must maintain medical registration, without any conditions, limitations or restrictions unless those conditions are approved by ANZCA.
• 23.12 Review of the progress of applicants by the IMGS Committee may occur for reasons including: a grossly unsatisfactory performance in the IMGS Performance Assessment / Final Examination, failure of the IMGS Performance Assessment / Final Examination for a second or subsequent time, a significantly unsatisfactory CPA report, lapse of the IMGS assessment process, an unsatisfactory WBA, or failure to make satisfactory progress through the IMGS assessment process.
• 23.12.1The purpose of the review process is to identify barriers to completion of the IMGS assessment process.
• 23.12.2 The review may be initiated on advice from the Chairman of the Final Examination Sub-committee, the applicant’s authorised CPA Supervisor or the IMGS Committee.
• 23.12.3 The review will consist of a re-interview conducted by a Panel nominated by the Chair of the IMGS Committee in Australia or the Chair of the New Zealand Panel for Vocational Registration in New Zealand.
• 23.12.4 Reports from the applicant’s CPA Supervisor and other referees, and performance in the IMGS Performance Assessment / Final Examination or WBA will be considered during the review.
• 23.12.5 The review may result in one or more of the following:
• 23.12.5.1 More frequent CPA reports.
• 23.12.5.2 A requirement for remedial activities to address areas of weakness.
• 23.12.5.3 Extension of the required CPA period.
• 23.12.5.4 The applicant being recommended by the Panel to the MBA, the AMC (in Australia) or the MCNZ (in New Zealand) for withdrawal from the IMGS assessment process. ANZCA Council will be notified of applicants who have been withdrawn from the Process.
• 23.13 Applicants will be recommended for specialist recognition following satisfactory completion of all requirements specified by ANZCA and will be eligible to apply for admission to Fellowship of ANZCA by assessment under Regulation 6.4. 
• 23.14 An applicant may request reconsideration and subsequent review of ANZCA’s decision.  This latter decision may be formally appealed in accordance with ANZCA’s Reconsideration, Review and Appeals Process (See Regulations 30 and 31).
• 23.15 Any IMGS Assessment not completed satisfactorily within four years (FTE) from the date of the initial interview, taking into account Regulations 23.12 and 23.9.8, will lapse and the AMC or MCNZ will be notified.
• 23.16 Interpretation and Non-Binding Decisions 
• 23.16.1 Any decision, approval, consent or the exercise of any discretion by ANZCA or other committee or authority under Regulation 23 will be considered on a case-by-case basis, having regard to the particular circumstances of each case.
• 23.16.2 Notwithstanding Regulation 23, ANZCA Council may exercise or dispense other decisions after consideration of relevant circumstances.
• 23.16.3 Any such decision, approval, consent or exercise of discretion will not be binding on any other or future decisions or set any precedent for other or future decisions regarding Regulation 23.
  
  23.17 Area of Need (Australia only)
• 23.17.1 The Area of Need (AoN) Process applies to Australia only.  It is a process that is used by the AMC and jurisdictions to address medical workforce shortages in designated areas.
• 23.17.2 The AoN Process is not an ANZCA process and the assessments associated with AoN appointments do not lead to Fellowship of ANZCA or to specialist registration by the MBA. An IMGS must apply to the MBA for, and be granted, limited general registration prior to commencing work in an Area of Need. Limited registration is site-specific and not transferrable to another site or position.
• 23.17.3 As applicants for AoN posts are normally IMGS, ANZCA has a role in advising the jurisdictions on the suitability of the particular IMGS for that particular position. ANZCA follows the processes described in ‘assessment process for AoN Specialists User’s Guide’ on the AMC website (www.amc.org.au).
• 23.17.4 The status of an AoN post is declared by the Department of Health and Ageing or other jurisdictional body. Prescribed documentation regarding a potential appointee is sent to the AMC and a similar set of documents is sent to ANZCA to facilitate a fast-track paper assessment of ‘fitness for task’. This is not an assessment of the comparability of that IMGS’s qualifications, training and experience with that of a FANZCA. The fast-track paper assessment matches an applicant’s qualifications, training and experience as indicated in his / her curriculum vitae to the requirements stated in the Position Description and the selection criteria. A key issue is the need for and the availability of suitable supervision.  ANZCA will advise the AMC, hospital administrator and jurisdictional officer regarding the applicant’s suitability for appointment to the post and whether any conditions should be applied to the appointment. ANZCA will review the appointee after 2 months via a comprehensive on-site assessment. Results of this assessment will be provided to the AMC, AoN doctor and hospital administrator. Should the inspection determine that the appointee’s standards of care are unsatisfactory, ANZCA will withdraw support.
• 23.17.5 ANZCA’s support for an IMGS in an AoN position will normally be for a period of 12 months. Extensions of support for up to 3 further 12-month periods may be granted if the IMGS continues to fulfil all conditions set out in the letter of support. Such re-appointments must be supported by the IMGS’s supervisor.
• 23.17.6 It is expected that an IMGS in an AoN position will undertake the formal IMGS assessment process as described elsewhere in Regulation 23. The IMGS assessment process is separate and different from the AoN assessments as the former is an assessment of comparability with Fellows of ANZCA. Successful completion of the IMGS process results in eligibility to apply for Fellowship of ANZCA and specialist registration by the MBA.
• 23.17.7 Any information obtained during the AoN assessment may be subsequently used in any ANZCA IMGS assessment.
• 23.18 Communications

All enquiries, applications, and communications regarding Regulation 23 must be made in writing and addressed to:

The Chief Executive Officer

Australian and New Zealand College of Anaesthetists

630 St Kilda Road, Melbourne

Victoria 3004, Australia.

1 February 2011