Demonstrating English language capability changing the required IELTS scores

Transcription

1 21 November 2013 Strategy and Policy Board 6 To consider Demonstrating English language capability changing the required IELTS scores Issue 1 At its meeting on 16 May 2013, the Strategy and Policy Board agreed, in light of research, to increase the existing International English Language Testing System (IELTS) score requirements to an overall score of 7.5 with no less than 7 to be achieved in each of the elements. This paper outlines proposals for implementation and transitional arrangements. Recommendations 2 The Strategy and Policy Board is asked to: a approve the proposals to implement the increase in IELTS scores concurrently with the plans to require European Economic Area (EEA 1 ) doctors to demonstrate their English language capability (in April 2014) b approve the proposed transitional arrangements for affected doctors c note our proposals for communicating the changes to stakeholders and affected doctors. 1 The term EEA doctor is used throughout this paper to refer to applicants who are nationals of a relevant European State (but not UK nationals) or who are entitled to be treated as such (including UK nationals who benefit by virtue of an enforceable Community Right). Registrations Decisions Guidance 2008 s.45

2 Demonstrating English language capability changing the required IELTS scores Issue 3 All International Medical Graduates (IMGs), irrespective of the route through which they apply 2, must 3 demonstrate their English language proficiency before we can grant registration. One of the approved mechanisms for demonstrating English language proficiency is by achieving the scores we require in the academic version of the International English Language Testing System (IELTS) test. This tests English language proficiency in four domains of writing, speaking, listening and reading. Candidates are given marks in each domain and an overall score. 4 In October 2010 we raised the required IELTS scores to a minimum overall score of 7.0 and at least 7.0 in each of the four domains. In 2012, we commissioned a team from the Centre for Language Assessment Research, University of Roehampton, to refresh and extend a previous study over all four IELTS domains. We received the final report in January This research recommended, among other things, that we should consider raising the IELTS scores it requires and at its meeting on 16 May 2013, the Strategy and Policy Board considered options for taking forward the findings of the research. 6 The Board agreed, among other things, that we should increase the existing IELTS requirements so that an overall score of 7.5 will be required, with no one category falling below a score of 7. This paper now sets out our proposed arrangements for phasing in these arrangements, given some doctors will be in the middle of the Professional and Linguistic Assessments Board (PLAB) or registration processes. Proposed transitional arrangements 7 We are proposing to provide three months notice of the implementation of the IELTS score increase. We will announce the increase in January 2014, with an implementation date of April We will write to all affected doctors (by or letter) to advise of the changes. The proposed transitional arrangements are as follows; 2 Either by virtue of a pass in the PLAB test, or the award of an acceptable postgraduate qualification or through a GMC-approved sponsorship scheme 3 Sections 21B and 21C of the Medical Act 1983, as amended. 2

3 a doctors holding previously acceptable 4 IELTS scores will still be able to continue through the PLAB booking process, however following the implementation date they will need to hold the new scores in order to make an application for registration b doctors holding previously acceptable IELTS scores who make an application for registration before the implementation date will be able to obtain registration with the old scores c from the implementation date, any applicant wishing to book onto any part of the PLAB test or apply for registration will be required to hold the new IELTS scores. Doctors with Pre-2010 IELTS scores 8 When we increased the IELTS scores to their current level in 2010 we contacted affected doctors to advise that all doctors who, prior to the implementation date, had either applied directly for registration or booked a PLAB part 1 place, passed Part 1, booked onto Part 2 or passed part 2, were eligible for registration with the old IELTS scores. This approach has resulted in a cohort of approximately 112 doctors with pre-2010 IELTS scores who have now passed PLAB parts 1 & 2 but have not yet applied for registration. 9 We obtained legal advice regarding the legal implications should we rescind the assurance previously given this group of doctors and require them to obtain the new IELTS scores in order to apply for registration after the implementation date. This suggests that we may have engendered a legitimate expectation, this being that (subject to passing the PLAB tests and meeting the approved timescales ) they would be able to proceed to registration despite possessing only pre-2010 IELTS threshold scores. Our proposed transitional arrangements would be counter to that expectation. 10 The legal advice also suggests the same may apply to doctors who have currently acceptable scores and who have booked onto or passed the PLAB test but do not make (or are not in a position to make) an application for registration before the implementation date. 11 However, the legal advice concludes that we can present a strong reason for cutting across the legitimate expectations of these two groups of doctors. The transitional arrangements that we are proposing have a strong public interest purpose and constitute the fairest and most equitable approach. Our proposed model would mean that from April 2014 both IMG and EEA doctors choosing to 4 The cohort of doctors with previously acceptable IELTS scores includes doctors who have had the validity of their IELTS scores extended by providing evidence of continuing study or work in English. 3

4 use the IELTS test to demonstrate their knowledge of English would be required to obtain the same scores, rather than a two tier approach where EEA and IMG doctors would be required to meet different standards of English language proficiency. 12 The legal advice acknowledges that our proposal to introduce a three month notice period prior to the implementation date will lessen the impact of the proposed transitional arrangements on affected doctors. They will have a period of three months in order to take stock and make any further necessary arrangements. 13 Whilst there is a residual risk of challenge on this issue, we believe the public interest imperative and the measures to minimise the impact on different groups of doctors mitigate this risk to an acceptable level. Requiring EEA doctors to demonstrate the necessary knowledge of English 14 Changes to the Medical Act will come into force in April 2014 that will enable us to withhold the grant of a licence to an EEA applicant who has not demonstrated the necessary English language capability. One of the ways in which EEA applicants will be able to demonstrate their knowledge of English is by achieving the required scores in the IELTS test. We therefore need to consider the timing of the proposed changes to the required IELTS scores as this will impact on EEA applicants. Timing of changes to the required IELTS scores 15 We are proposing to implement the increase in IELTS scores concurrently with the plans to require EEA doctors to demonstrate their English language capability, in April This approach would enable us to introduce a suite of policies relating to English language testing at the same time. Implementing both changes at the same time would demonstrate a more coherent and joined up approach and would be less confusing for doctors, stakeholders, patients and the public and for GMC staff who will need to disseminate the information. Operational impact 16 We are aware that introducing two intensive change programmes at the same time will be likely to lead to increased pressure on the areas of the business responsible for implementing the changes. Additionally there would be a likely increase in queries and complaints coinciding with the peak period for operational teams (which runs from May to August). We have set up a project group with operational managers to ensure that the changes are implemented with minimum disruption to operational teams. Communication strategy 17 Details of our communications strategy are set out at annex A. 4

5 Supporting information How this issue relates to the corporate strategy and business plan 18 Strategic Aim 1 of the 2013 Business Plan states that we will continue to register only those doctors that are properly qualified and fit to practise and to increase the utility of the medical register. Agreeing the transitional arrangements and communications plan will contribute to this strategic aim. What engagement approach has been used to inform the work (and what further communication and engagement is needed) 19 We will be undertaking focused engagement and communication with stakeholders and affected doctors. Our Communication strategy is set out at annex A. What equality and diversity considerations relate to this issue 20 Currently only IMGs are required to satisfy the GMC of their English language proficiency before registration is granted. The vast majority are from BME groups. Raising our requirements in terms of IELTS scores could have implications for doctors sharing protected characteristics under the Equality Act An equality impact analysis is underway. If you have any questions about this paper please contact: Jon Billings, Assistant Director Revalidation, jbillings@gmc-uk.org,

6 6 Demonstrating English language capability Annex A Summary of communications approach to support the publication of GMC research: Identifying the appropriate IELTS score levels for IMG applicants to the GMC register 1 There is likely to be varied stakeholder reaction to our decision to increase IELTS score levels for IMG applicants to the GMC register. It comes at the same time that there is heightened interest in the experience of International Medical Graduates performance in other medical entrance examinations 2 We propose announcing this decision shortly after the November meeting of the Strategy and Policy Board. Key stakeholders will be informed before a media release is issued to the medical trade press. It is important to note that our annual accountability hearing with the Health Select Committee will take place in the second week of December. 3 In announcing our decision, our communication objectives will be to: a engage those stakeholders that we identify as likely to be interested in and impacted by the research, managing any issues or concerns which they might have in a proactive and informed manner b communicate clearly our new requirements, our rationale for changing them highlighting the increasing protection we believe this will afford patients - and how we will implement them c indicate our intention to look at score requirements further in years to come, so we manage expectations around future changes. 4 We expect a number of key interest groups to have an interest in this decision and the research which supports it, including: a the researchers it will be important that that they are supportive of and consistent with our communications A1

7 b the four health departments of the UK c political representatives, including members of the House of Commons' Health Select Committee. d the medical profession, particularly those organisations which represent the interests of BME and IMG doctors e Royal Colleges f overseas medical regulators and doctor organisations including ENMCA (the European Network of Medical Competent Authorities) and IAMRA (the International Association of Medical Regulator Authorities) g employers h patient and public groups i j other professional regulators trade press and potentially some national media in context of recent coverage of IMG experiences of/performance in other examinations and current consultation on ELT powers. 5 A full handling plan will be developed to support the announcement and ensure key stakeholders are made aware of our decision before we make it public. We will endeavour to use existing engagement opportunities wherever possible. 6 Operational communications to explain the transitional arrangements to affected doctors and other stakeholders are planned to begin in January A full communications plan will be developed to support this. A2