Request for submissions: Withdrawal of the Special Purpose (Teleradiology) scope of practice.

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1 Request for submissions: Withdrawal of the Special Purpose (Teleradiology) scope of practice. October 2014 Introduction This consultation document seeks your views on Council s proposal to withdraw its special purpose (teleradiology) scope of practice. The Council acknowledges its statutory obligations to consult on proposed changes to scopes of practices (under s 14 of the Health Practitioners Competence Assurance Act 2003), but more than that sees such consultation as a fundamental element in its engagement with the profession over matters in which the profession has an interest. Council welcomes your submissions. Structure of this paper The document sets out the background and reasons for the proposed withdrawal. It concludes with a number of questions designed to assist you in your responses. Your responses to these questions will help ensure that Council not only has a full understanding of implications for the profession but also identifies any questions of public health and safety that may need to be considered as part of this proposed change. Registration with the Medical Council of New Zealand The Medical Council of New Zealand (Council) is responsible for protecting the health and safety of members of the public by providing mechanisms to ensure that doctors are competent and fit to practise medicine in New Zealand (Health Practitioners Competence Assurance Act or HPCAA, section 3). Specifically, Council can only register a doctor who meets the following three requirements: has a prescribed qualification. A prescribed qualification is an approved medical qualification or a combination of overseas / New Zealand qualifications, training and experience; is fit for registration; is competent to practise within the scope of practice for which he or she has applied. Special purpose (teleradiology) scope of practice In 2011, Council introduced a scope of practice to allow the provision of teleradiology services to New Zealand from radiologists based overseas. This was intended to act as a trial for wider regulation of telemedicine; diagnostic radiology was selected due to teleradiology services being relatively common, and as it had the support of the Royal Australian and New Zealand College of Radiologists. For an applicant to obtain registration in the special purpose (teleradiology) scope of practice key elements must be satisfied not just by the applicant, but by the New Zealand-based health provider. The applicant must:

2 have a postgraduate qualification in diagnostic radiology, approved by Council and published on the Council s website (Appendix 1); and be registered in the jurisdiction where they are able to gain a postgraduate qualification approved by the Council (ie the doctor may hold a qualification from one approved jurisdiction and have practised in another, different approved jurisdiction); and have been in active clinical practice (at least 20 hours per week) in the scope of diagnostic radiology for at least 24 out of the last 36 months; and be providing radiology services under contract to a health provider located in New Zealand and be fully credentialled by the health provider; and be working for a facility overseas that is accredited by a suitable national or international accreditation body. (IANZ accreditation is required, where this is available.) The New Zealand-based health provider must: carry out a comprehensive credentialling process for the doctor prior to applying for registration. This means that the health provider will be assured that the doctor has the qualifications, training and experience to carry out the specific procedures that the health provider requires within their specific clinical setting; and credential CPD throughout the period of registration; and have appropriate systems in place to provide supervision and induction, and to deal with complaints. This must include an agreement to fund the doctor to come to New Zealand if an investigation is necessary; and have a dispute resolution process to facilitate the fair, simple, speedy and efficient resolution of complaints. This process must include automatic notification of the relevant authorities in NZ and the doctor s home country should a complaint be received and must also permit and facilitate external review and investigation by those authorities; and provide supervision of the doctor by the clinical director of the New Zealand health facility; such supervision must include: o details of the level of responsibility to be delegated to the doctor o an induction / orientation and supervision plan which contains details of induction and orientation; details of how supervision will occur, including the frequency of meetings; and availability of the supervisor by telephone and o An audit carried out by the supervisor of 30 consecutive cases for each reporting radiologist to coincide with the first three-month supervision report. If reporting of a full 30 cases is not possible because the radiologist has not undertaken that number of cases yet, Council may consider accepting fewer cases for the audit o Supervision reports are to be provided to Council for each three-month period. Reports must include details of audits undertaken and reviewed by the supervisor. Registration in this scope of practice is valid for a maximum of 12 months. Applicants must reapply annually.

3 Registration in the special purpose scope of practice for holders of RANZCR fellowship Doctors who hold Fellowship of the RANZCR, and wish to provide teleradiology services to New Zealand, are eligible to apply for registration via the special purpose teleradiology pathway. However, they are also eligible for vocational registration because they hold the Council s prescribed qualification (FRANZCR), and it is consequently simpler to apply for this permanent form of registration. In addition to the usual requirements, applicants for vocational registration who are intending to provide teleradiology services in New Zealand are asked to provide: confirmation of their employment with an international teleradiology service provider; and a copy of the contract for services between the international teleradiology service provider and the NZ site contracting the teleradiology services. This contract must include a disputes resolution process to facilitate the fair, simple, speedy and efficient resolution of complaints; and confirmation that they have been in active clinical practice (for at least 20 hours per week) in diagnostic radiology for at least 22 out of the past 36 months (in other words a minimum of 1,760 hours worked, counting a maximum of 40 hours per week and excluding on-call and overtime hours). Findings of the trial period The trial of the special purpose (teleradiology) scope of practice concluded in December Since its inception, only 3 teleradiologists have registered via this pathway (initially granted in 2011, and then the same applicants reapplied in 2012 and 2013). The trial highlighted a number of issues: The implementation of this scope of practice was quite costly. This cost has not been absorbed by the cost of registration of the three doctors subsequently registered with this scope of practice. The time taken to complete the registration process of the three teleradiologists exceeds what would be the expected norm for similar applications. Significant delay occurs in obtaining certificates of good standing (CGS) from all jurisdictions in which the applicant has worked over the previous 12 months. On average, each teleradiologist required CGSs from eight countries, some of which prove difficult to obtain in a timely fashion. Consideration of the difficult circumstances were made, however this lengthened the process, with the reapplications in 2013 taking over 6 months to complete. Supervision of the teleradiologist is required, with supervision reports due every 3 months, and an audit of 30 consecutive cases is also required. This has proved difficult to provide with variances in numbers of scans reported by each teleradiologist (between 50 and 300 over a 26 month period), and the limited areas of competence that can be assessed in the supervision report, when there is no face to face interaction between the supervisor and the teleradiologist. Issues of lengthy processing times also occur with applications for teleradiologists holding FRANZCR to be registered in a vocational scope of diagnostics & interventional radiology. As they hold full registration, these teleradiologists are also required to renew their practising certificate on an annual basis, and delays at time of renewal can also arise.

4 Since the practice of granting vocational registration to teleradiologists holding FRANZCR commenced, the number of applications via this pathway (doctor holding the approved qualification, but not holding other registration in New Zealand) increased from an average of seven per year ( ) to 34 per year ( ). As of August 2014, 32 applications had already been processed for the year, with a further five in progress. Whilst these figures will also include applications for doctors registering down this pathway in other areas of medicine, and subsequently practising in New Zealand, the majority of these applications are for teleradiologists operating out of Australia. There are currently 57 practising teleradiologists providing service to New Zealand. Council s intention to withdraw the scope of practice Based on the issues raised from the trial Council proposed at its meeting in December 2013 to withdraw the special purpose (teleradiology) scope of practice. Before doing so, however, Council would like to consult and seek the views of relevant stakeholders, in the interests of ensuring the protection of patient safety when care is provided by a radiologist based in another country. Request for comment Council invites your comments on the proposal to withdraw the special purpose (teleradiology) scope of practice You are also invited to provide any comments or suggestions on alternative mechanisms for ensuring patients safety when care is provided by a teleradiologist based outside of New Zealand, should the scope of practice be withdrawn, and such teleradiologists not be required to hold registration in New Zealand In responding, you are invited to address all or any of the following questions: Does the proposed scope withdrawal increase / decrease / not change the potential risk of harm to patient health and safety? Why do you believe this to be the case? Does the proposed withdrawal increase / decrease / not change the barriers to registration for doctors who present with a particular profile in terms of their qualifications training and experience? Why do you believe this to be true? Have you referred clearly in your submission to any evidence in support of your submission, that you believe the Council should be aware of? (Please include specific references, so that Council may source this information, for further consideration.) If you have supported the view that the scope of practice should be withdrawn, have you any suggestions about alternative options for ensuring patient safety, and any evidence to support these suggestions? If you have taken the view that the scope of practice should not be withdrawn, have you provided any evidence you may have in support of this submission? Please provide your submission on the above points to Laura Lumley by to teleradiology@mcnz.org.nz or by post to PO Box 10509, The Terrace, Wellington 6143 by 5pm, Tuesday 11 November 2014.

5 Please note, while considering submissions, or having made a final decision, Council may decide to publish all or part of the submissions it receives. Please be aware of this if providing personal information in your submission.