Some NCHD work duties are being re-categorised as ‘protected training time’, leading to inaccurate recording of compliance with working time law, according to the IMO’s NCHD Chair.
Dr Rachel McNamara told the Medical Independent (MI) that NCHD protected training time does not count towards working hours when assessing compliance with the European Working Time Directive (EWTD).
Over time, “there has been creep” in the number of areas being categorised by healthcare settings as “training time”.
She emphasised there are “very few instances of time where you are not actively working when you are in your role as an NCHD”.
Dr McNamara said it was “very easy” for these re-categorised hours to accumulate, and “all of a sudden you have ‘100 per cent compliant rosters’, but the reality is very different.”
At the IMO’s recent AGM, NCHDs called for “further discussion on protected training time for NCHDs” and for the HSE to “provide specific safeguards as to what constitutes protected training time”.
The motion added: “The IMO deem it necessary for engagement with relevant training bodies where changes are implemented that could impact the agreements set out in the NCHD contract and agreement.”
A HSE spokesperson told MI it was “fully committed” to the provision of NCHD access to protected time for education and training activities.
According to the HSE, protected training time includes scheduled and protected time off-site attending training or undertaking study in line with the requirements of a training/educational programme.
It also incorporates on-site scheduled educational and training activities, including on-site regular weekly/fortnightly scheduled educational and training activities, such as conferences, grand rounds, and morbidity and mortality conferences.
It further includes exposure to and practice of specific clinical procedures, time to allow trainees to observe, and subject to consultant approval, participation in certain planned procedures under supervision.
Research – including that taking place during ‘paid time’ – is also counted as protected training time, stated the HSE.
“NCHD participation in protected training time must be sanctioned and recorded as part of the NCHD timesheets.”
MI asked the Forum of Irish Postgraduate Medical Training Bodies if it had had any involvement in this area, particularly in regard to promoting protected training time.
A Forum spokesperson said: “The impact of this issue seems to affect the various specialties to a greater or lesser degree. It’s one that all the training bodies are monitoring and actively addressing as much as we can. It is a topic that the Forum and the individual training bodies return to frequently and will be discussed again at the next Forum meeting.”
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