RACS responded to a consultation by Manatū Hauora for the Minister of Health on Putting Patients First: Modernising Health Workforce Regulation. 

The Chairs of the Aotearoa New Zealand National Committee and the Māori Health Advisory Group made a written submission to the Minister of Health and the Director-General of Health. Their submission responded to a consultation document proposing significant changes to the regulation of the health workforce through the Health Practitioners Competence Assurance Act 2002 (the Act).

RACS expressed concern about four key points.
•    Purpose: the lack of focus on the purpose of the Act to ‘protect the health and safety of members of the public by providing mechanisms to ensure that health practitioners are competent and fit to practise their professions.’. The focus of the consultation was on efficiency and cost saving.
•    Cultural safety: the consultation document suggested cultural safety is not related to clinical quality and safety. For example, ‘Regulators today often encourage or require health practitioners to consider factors beyond clinical safety. In some cases, this involves requiring certain professions to favour cultural requirements in hiring decisions, such as mandating an understanding of tikanga Māori.’ Cultural safety is crucial for clinical safety and patient-centred care.
•    The role of regulators and professional colleges: the tone of the document undermined the role of regulators and professional colleges in maintaining health standards. For example, ’When most members of an authority are practitioners, decisions are more likely to be based on the interests of the profession, which may not match the public interest.’ This statement implied health workforce regulation is the cause of Aotearoa New Zealand’s health workforce shortages. Some comments are: “I keep hearing about doctors from overseas who want to work here but can’t. I know we need more doctors, why is it so hard?” and “Instead of welcoming these qualified workers, we’ve created complicated bureaucratic barriers that discourage even the most motivated individuals from staying.”. 
•    The consultation process: only 30 days for consideration and submissions, a poorly written consultation document with factual inaccuracies, and an online survey with leading questions. 

We also made a submission through the online survey portal, working around a set of leading questions, and encouraged and supported numerous surgeons and societies to make submissions. 

RACS supported the Council of Medical Colleges in lodging a complaint with the Ombudsman’s office, as the process breached the  guidelines for fair public sector consultation processes.   The ombudsman’s requirement was to be objective, open-ended, evidence-based, unbiased, and politically neutral. 

Read submission .