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Last September, three delegates from the Medical Council travelled to the US.
The purpose was to meet the National Committee on Foreign Medical Education and Accreditation (NCFMEA), a body under the aegis of the US Department of Education.
Specifically, the NCFMEA was to assess whether the Council’s standards and processes for accrediting Irish medical schools were comparable to those in the United States.
Under US law, accredited medical schools in another country that the NCFMEA finds comparable may apply to participate in the US William D Ford Federal Direct Loan programme. If a medical school participates in the programme, US students attending the school may apply for direct loans to help cover education expenses.
In that sense, the determination of comparability is of significant financial import to Irish medical schools.
It is 20 years since the NCFMEA first determined that Ireland’s standards and processes of accreditation were comparable to those in the US. This determination was reaffirmed in 2009 and 2013, and the Medical Council was requested to submit an application for redetermination of comparability in 2016. However, the most recent meeting with the Council prompted the US body to defer its decision, pending receipt of further information.
In October, a letter to Council CEO Mr Bill Prasifka from the then US Secretary of Education Mr John B King Junior stated that the NCFMEA “needs additional information in order to make its decision regarding the comparability of the standards used by the Medical Council of Ireland to accredit medical schools in Ireland”. The NCFMEA has deferred a decision to its spring 2018 meeting, “pending receipt of supporting documentation and outstanding information identified in the final staff analysis”. In the meantime, its prior determination of comparability remains in effect.
The type of “additional information” that the NCFMEA is seeking could signal changes in the Council’s accreditation processes with respect to medical schools over the next number of years.
The NCFMEA Redetermination of Comparability document, dated September 2016, is publicly available (https://opeweb.ed.gov/aslweb/ in the ‘public documents’ section).
The document outlines particular areas where the NCFMEA “may wish” to request additional information, including clarification on plans, if any, to establish a national curriculum or national medical school exit exams; governance arrangements between the medical school and the parent university as evidence; clarification on plans to adopt requirements regarding the position of chief academic official of a medical school; and clarification on the threshold score utilised in the admission of students.
The report is worded in such a manner that makes it difficult to gauge whether, for example, it is suggesting that a national curriculum needs to be instigated in order to ensure a determination of comparability.
A US Department of Education spokesperson told the Medical Independent (MI) that NCFMEA guidelines do not “require” countries to establish a national curriculum, for example, but rather to ensure that an essential objective of a programme of medical education “must be to prepare graduates to enter and complete graduate medical education, qualify for licensure, provide competent medical care and have the educational background necessary for continued learning” (NCFMEA Guidelines, Part 2, Section 1(b)).
“Therefore, in order to make an assessment of comparability, the NCFMEA requires a more thorough understanding of the process used by Ireland to accredit its medical schools. When such information is provided in accord with the Secretary’s decision letter, the NCFMEA will be able to make a determination at its spring 2018 meeting.”
The narratives and remarks from both parties in the September 2016 document make for interesting reading. For example, in its comment on the issue of chief academic officials of a medical school, the Medical Council said it does not specify the qualifications required of a person holding this position. Rather, such requirements are specified by the individual university.
In response, the US analyst wrote that the country had not provided any documentation to “demonstrate the medical schools’ adherence to this question”.
The Council responded that it did not consider it “appropriate or necessary to be overly prescriptive in this area, as it may inadvertently hinder local innovation and culture”. The Council “has no specific requirements of medical schools in this area”.
Kingram House added that it had adopted World Federation for Medical Education (WFME) European Specifications (2007) and will review these to take into account any amendments under the WFME Global Specifications (2015). “As these are global standards and considered to be best practice standards, the Medical Council does not deem it necessary to expand on these specifications.”
In a further response, the US analyst noted that the Council provided an accreditation site visit report to demonstrate the review of medical schools against the WFME Global Standards and a blank template of the pre-site visit questionnaire that is completed by a medical school.
The US department staff accepted the supporting documentation but said the NCFMEA “may still wish to request” a completed pre-site visit questionnaire and “clarification on plans to adopt requirements regarding the position of chief academic official of a medical school”.
In another interesting exchange, the Council outlined that there was no national curriculum or national medical school exit examination. While medical schools “differ in the way they deliver their programmes”, each school provided a course accredited by the Council using the WFME standards. The Council added that, arising from the accreditation process, it engages with medical schools in relation to curriculum design and content, duration, assessment, evaluation and renewal.
In response, however, the US analyst found that the Council had not provided the specific WFME standards or the medical school requirements related to how medical schools prepare graduates to qualify for licensure and provide competent medical care. The analyst added that the Council also engages medical schools in “several areas” during the accreditation process to ensure they are producing doctors who are fit to practice, but evidence of this engagement and review were not provided.
The analyst concluded that the NCFMEA may wish to request as evidence a copy of accreditation team on-site visit reports, a list of the medical school requirements that address this question and the WFME Standards that are reviewed relative to this question.
The NCFMEA may also wish to request “clarification” on whether there are any plans to establish requirements for how schools must prepare graduates to qualify for licensure and provide competent medical care.
The narratives and remarks from both parties in the document make for interesting reading
In response, the Medical Council provided sample reports of accreditation visits. It added that a review of all of the Council’s standards is planned to assess whether they are sufficiently outcomes-focused.
The analyst again responded that the NCFMEA may wish to request additional clarification regarding plans, if any, to establish a national curriculum or national medical school exit exams.
A Medical Council spokesperson informed MI that there is no charge from the NCFMEA for the process of determining comparability.
“Three representatives of the Medical Council attended the meeting in Alexandria, Virginia. At the time of the NCFMEA meeting, the Medical Council had approved moving its standards, for undergraduate medical education, to reflect the WFME’s newly-revised 2015 standards. With the process of updating standards in train, the NCFMEA requested additional information in order to make a determination. As a result, the Medical Council, having made a substantial submission, was not in a position to definitively answer all of the NCFMEA’s questions,” commented the Council’s spokesperson.
“Therefore, they deferred its decision until 2018 (their earliest available meeting, given the NCFMEA’s busy schedule). Given this requirement, the NCFMEA’s prior determination of comparability remains in effect.”
The delegation that travelled to the US were Ms Una O’Rourke, the Council’s Head of Education, Training and Professionalism; and Dr Siun O’Flynn and Dr Anna Clarke, external members of the Council’s Education, Training and Professional Development Committee.
MI asked the Council for details of the costs associated with the visit. However, its spokesperson said “we have not released our 2016 accounts yet and so will be unable to provide this information”.
On issues such as a national curriculum and requirements for the position of chief academic officials, MI asked the Council if it interpreted the report as meaning it must adopt such requirements to maintain the NCFMEA determination of comparability come 2018.
“It would be premature to comment on this until a final determination is made by NCFMEA,” answered the spokesperson.
The Council has previously commissioned an external review of its accreditation process of medical schools. MI sought information from the Council as to key findings, the cost of this exercise and who conducted the review. The cost was not provided, nor information on key findings.
“Prof Pauline McAvoy conducted an external review, which commenced in 2015 and was completed in 2016 — her report is not in the public domain. A number of recommendations were made, which the Council is working to implement.”