2 October, 2012
September 2012 – European Network of Medical Competent Authorities views on the European Parliament reports. ENMCA produced the following statement in response to the IMCO draft report and ENVI draft opinion on the proposal, which reflects earlier discussions had in Cyprus in September.
ENMCA views on the European Parliament reports on the proposal amending the recognition of professional qualifications Directive (2005/36/EC)
The European Network of Medical Competent Authorities (ENMCA) brings together organisations in Europe responsible for recognising medical qualifications under the Directive.
We have produced the following statement in response to the IMCO draft report and ENVI draft opinion on the proposal, which reflects discussions that we had at our latest meeting in Cyprus in September.
We welcome that both reports have taken into consideration the specificities of healthcare professionals, in particular doctors, and the need to enhance patient safety.
European Professional Card (EPC) (Article 4)
We welcome the proposed increase in timescales for recognition proposed in the ENVI draft opinion (Ams 14; 17; 18) but consider the deadlines suggested in the IMCO draft report would still be very challenging for the host and home competent authorities to meet (Ams 24; 29).
We still maintain that the most effective way to ensure the successful implementation of the EPC would be to have pilot projects between competent authorities. This would ensure that the system is safe, appropriately resourced and delivers benefits for both the profession and competent authority.
We support ENVI’s proposal to delete tacit authorisation (Ams 19). It would not be safe if doctors were able to start practising without explicit authorisation by the host competent authority.
Language requirements (Article 53)
We welcome the approach taken by the ENVI committee which suggests language must be assessed systematically by competent authorities after recognition but before access to the profession (Ams 55). This respects the fundamental principle of recognising qualifications but acknowledges the legitimate need for competent authorities to assess a doctor’s language skills before they are granted access to the profession.
However, we believe that it should be the professional’s responsibility to ensure that they have the appropriate language skills to practise the profession as opposed to the approach taken in the Commission proposal. This would ensure a fair system is created for all doctors, regardless of whether they are trained within or outside the EEA.
Alert mechanism (Article 56.a)
The IMCO and ENVI draft reports make important improvements to the alert mechanism (IMCO Ams 80 and 82, ENVI Ams 3; 57; 59; 60; 62).
The proposal in both reports to extend the alert mechanism to the exchange of intelligence about individuals that try to register with fake diplomas or false identities would also introduce important safeguards for competent authorities and patients.
Continous competence
Currently professionals are not required to provide any evidence of current practice as a condition for automatic recognition, which means competent authorities are required to automatically register professionals who may have been out of practice or not kept their knowledge and skills up to date.
We ask the European Parliament to take this into consideration in their amendments.
Delegated acts – Role for Competent Authorities
ENMCA still remains concerned about the quantity and quality of legislation which the Commission is proposing to develop through delegated acts. We would like to highlight that medical education and training is a Member State competence.
We call for clear and active participation of competent authorities in the development of any delegated acts. ENMCA is well placed to support the Commission in this regard as a forum bringing together medical competent authorities across the EEA.
Partial Access
We welcome the amendments in both the IMCO and ENVI draft reports to strengthen the exemption to partial access for healthcare professionals. This is essential for patient safety (IMCO, Am. 1 and 34, ENVI. 1 and 23).