In preparing our response RACS consulted with key stakeholders and make the following observations: 

Qualification and Expertise

We would recommend the inclusion of a statement that supervised clinical attachments are assessed by credentialing committees as being at the level of independent or supervised practice, as relevant to the proposed applicant’s role at the facility where they are being credentialed. However, the skills obtained should be assessed based on competence rather than time spent or numbers of cases. 

Renewal of Scope of Clinical Practice

A specialist medical college may sanction a Fellow, restrict their activities (i.e. to act as a supervisor) or suspend or terminate their Fellowship. Under declarations we recommend the addition of a statement that a clinician declares that they are not subject to any censure, restriction or undertaking by a relevant authority. If they are subject to censure, restriction or undertaking by a relevant authority, they should disclose these in their application to the credentialing committee. This may not affect re-credentialing depending on the sanction and the facility’s activities. 

CPD Standards

The draft guidelines state that:

“Completed CPD that is relevant to the applicant’s scope of practice and profession set by a national board for national registration and accreditation scheme health professions, or appropriate college or association, which is verified and submitted annually” (pg. 12)  

Credentialing committees should only accept evidence of CPD compliance from organisations accredited to provide CPD programs by a relevant authority. There is no reference in this document to the Australian Medical Council (AMC) which accredits specialist medical colleges in Australia and acts as an important quality assurance measure. Evidence of CPD compliance should not be considered from organisations that do not hold AMC accreditation to deliver CPD Programs or are not affiliated with those who do. Given the complexity of the Australian accreditation environment, it may be helpful to include this in the guideline.  

The checklist also indicates that a CPD check is:

only required if the organisation sets CPD requirements that are additional to those required for registration’ (see 1.7)

We recommend that credentialing refer to the CPD standards set by the relevant medical specialist college. 

While the vast majority of clinicians complete their CPD, a small number do not, yet still retain registration as CPD compliance is largely self-reported. We would therefore recommend that evidence of CPD compliance is sought when a clinician is being credentialed. In respect to surgeons, those who have met their requirements will have access to a CPD statement confirming their compliance.  

Definitions of Scope of Clinical Practice and Credentialing

In Australia, the term ‘Scope of Practice’ is traditionally used by surgical groups to describe the whole of a surgeon's repertoire, which includes all procedures that they are capable of performing. ‘Credentialing’ indicates the parts of a surgeon's scope of practice that they can perform at a particular facility, given the particular facility’s ability to provide a safe environment for particular procedures. Some surgeons may wish to self-limit their scope of practice. 

The guideline states that "Defining the scope of practice... follows on from Credentialing" and appears to use the term "Scope of Practice" to mean the group of procedures for which a surgeon is credentialed at a facility. If the authors of the document wish to use the phrase "Scope of Practice" in this manner (i.e. differently to its traditional usage), then the words "Scope of Practice at this facility" should be used so that Managers are not misled into believing that this is all the surgeon is capable of. 

The influence of a hospital or facilities service capabilities could be further strengthened by explicitly stating that a clinician’s group of credentialed procedures is dependent on each facilities service capabilities and will be different in each facility.  

RACS position on Credentialing and Scope of Practice

The RACS position on Credentialing and Scope of Practice can be found at here.