The National Specialist Register (NSR) has been the focus of consideration in the previous six months in the debate about specialist registration, notably the parallel pathway.
Misinformation and disinformation about the NSR have flooded the print and social media.
This article seeks to offer the perspective of the author who has been carefully concerned with the NSR.
Historical views
The Academy of Medicine (AMM), whose members are all specialists, established its Specialist Register (AMMSR) in Nov 2000.
It comprised a database of AMM members with their specialist standing.
The AMMSR was made accessible on the AMM web site for public reference and inspection.
The Health Ministry (MOH) specialists have been gazetted with particulars about their specialty standing.
The impetus to determine a NSR led to the MOH and AMM establishing a joint committee to deal with the procedures and pointers for credentialling the specialists.
The MOH agreed that the NSR be initiated and maintained by the AMM.
The NSR was launched by the then Health minister on Aug 24, 2006.
The NSR was overseen by a National Credentialling Committee (NCC) chaired by the Health director normal who was and can be the Malaysian Medical Council’s (MMC) president.
Its membership comprised 4 representatives every from the MOH and AMM and one consultant from the MMC.
The NCC offered requirements of observe for specialist observe and directed the upkeep of the NSR.
The NCC chairman appointed members of the specialist sub-committees (SSC) for every of the 47 specialties in the NSR.
The SSC’s function was to develop standards for recognition of their specialties, to judge functions in opposition to the stipulated standards and to make applicable suggestions to the NCC.
A devoted secretariat was established at the AMM to keep up the NSR and supply administrative assist.
The Medical (Amendment) Act was handed by Parliament and acquired royal assent on Sept 5, 2012.
Sections 14A-C and 42(6) of the amended Act offered for the institution of the NSR.
Section 42(6) states:
Any one who, on or earlier than the date of coming into operation of this Act:
(a) Had or been registered as a specialist in a registry of specialists
(b) Had been appointed as a specialist by the director normal, shall be deemed to be registered as a specialist beneath this Act.
The MMC held a number of conferences with stakeholders to replace its 2001 Institutional Memory pointers, which have been utilized in its analysis of functions for registration.
The Registration Procedures and Guidelines for provisional, full and specialist registration, and non permanent practising certificates have been adopted by the MMC on Dec 18, 2012.
This adopted a MMC workshop in Port Dickson, Negeri Sembilan, the contributors of which included representatives of MOH and AMM.
This doc was revised by the MMC in 2013 and 2015.
The Medical (Amendment) Act got here into power on July 1, 2017.
The MMC at its assembly on Nov 21, 2017 adopted the NCC checklist of recognised specialist {qualifications} and numerous administrative measures associated to the NSR.
The MMC then was cognisant of the proven fact that its NSR checklist was not exhaustive, and that the public shouldn’t be disadvantaged of the abilities and expertise of some Malaysians who had and proceed to have specialty coaching in “non-traditional” international locations.
As such, till July 2022, there was a pathway for such Malaysians to use to the NSR.
To-date, the MMC has not offered any clarification for its resolution to shut this pathway in Nov 2023 and its failure to inform the medical career.
Application course of
The course of for functions for placement in the MMC’s NSR was and nonetheless is:
> All functions are thought-about by the related SSC comprising senior members of the speciality e.g. SSC for obstetrics and gynaecology, SSC for paediatrics, and so on.
> The SSC’s suggestions are thought-about by MMC Evaluation Committee, which comprised MMC members, representatives of the MOH and AMM.
> The MMC Evaluation Committee’s suggestions are thought-about by MMC, which decides whether or not an applicant might be positioned in the MMC’s NSR.
The MMC has but to deal with the query of whether or not all functions to the NSR have been thought-about by its SSC, Evaluation Committee and MMC, in accordance with MMC’s publicly acknowledged processes; and if not, what have been the causes for non-consideration and rejection at every stage of the course of, and the variety of functions concerned?
Recognised coaching establishment
The above time period in part 14B of the Medical Act has been utilized in arguments in opposition to recognition of {qualifications} from the parallel pathway from July 1, 2017.
The rivalry is that MOH amenities are healthcare suppliers, and never recognised coaching establishments; and thus, MOH consultants and specialists should not accredited/recognised trainers.
This fallacious argument ignores the proven fact that the MOH offers work-based coaching for all junior medical doctors, together with 80-90% of masters trainees.
Since the MOH amenities should not recognised coaching establishments and its consultants and specialists should not accredited/recognised trainers, it implies that the {qualifications} of the masters trainees in MOH amenities from July 1, 2017 can’t be recognised.
The Health minister was spot on when he knowledgeable the Dewan Rakyat that the Medical Act amendments have been crucial as each the masters programmes and parallel pathway have been technically irregular.
(Editors’s observe: The Medical (Amendment) Bill 2024 was handed in Parliament on July 17. The Bill seeks to enhance provisions associated to the registration of specialists in addition to the recognition of {qualifications} and specialised coaching. It has additionally proposed modifications in the composition of MMC’s members.)
MMC’s non-delegable obligation of care
When the Medical (Amendment) Act got here into power on July 1, 2017, the MMC took over accountability for the NSR.
As the MMC then didn’t have the capability, it requested the AMM to proceed to keep up the NSR administration and web site.
In brief, the AMM grew to become an agent of the MMC.
The then AMM’s upkeep of the NSR web site was beneath the management and supervision of MMC and any amendments may solely be made at MMC’s course and prior approval.
This is mirrored in the proven fact that the AMM knowledgeable MMC in 2021 and 2022 of the must amend inaccuracies in the NSR web site, which occurred after MMC took over the upkeep of the NSR web site in 2021.
In an online portal, the MMC reportedly claimed that it “had no knowledge of, and no control over, the contents of the NSR website, which at all times has been under the control of the AMM”.
This declare by MMC is grossly inaccurate.
The MMC, as a regulator, had and continues to have a obligation to make sure that contents on the NSR web site are correct, notably after it required all functions to be made via its web site.
The non-delegable obligation of care has been accepted by the Federal Court.
As such, the MMC ought to desist from blaming others for any inaccuracies in the NSR web site.
Dr Milton Lum was an elected member of the MMC from August 1995 to July 2022, and a previous president of the Federation of Private Medical Practitioners Associations and the Malaysian Medical Association. For extra data, e-mail [email protected]. The views expressed don’t characterize that of organisations that the author is related to. The data offered is for academic and communication functions solely, and it shouldn’t be construed as private medical recommendation. Information printed on this article will not be supposed to interchange, supplant or increase a session with a well being skilled concerning the reader’s personal medical care. The Star disclaims all accountability for any losses, injury to property or private damage suffered immediately or not directly from reliance on such data.