Te Whatu Ora consultation on Principles for private training of Surgical Registrars
Te Whatu Ora consulted colleges on a draft of Principles for private training. We responded by proposing Principles for private training of Surgical Registrars.

The Group Manager, Future of Health Workforce, at Te Whatu Ora – Health NZ circulated to colleges a draft set of principles designed to support and regularise the current range of ad hoc training of surgical registrars in private settings. The intention was to use these for a suite of early pilots to deal with issues such as registrars facing undue pressure to provide out-of-hours support for private services.

Given the current focus on the outsourcing of surgical waiting lists, and the expected increase in longer-term training contracts, we proposed a set of principles to apply in both situations. We also proposed a two-part purpose statement, which recognises the private sector as an important partner in increasing the health system capacity to train surgical registrars:

·  To increase the health system capacity to train surgical registrars: surgeons working in private settings have trained on publicly funded vocational training schemes. Their social licence to operate carries an obligation to contribute to vocational training for future surgeons. The ability to train in the private setting on outsourced public patients fulfils this responsibility. 

·  Training surgical registrars operating in private ensures training registrars get exposure to cases with low volumes delivered in public: so, they can complete vocational training in a timely manner and with sufficient exposure to different case types to practice safely as a Senior Medical Officer.

We will continue discussions with Te Whatu Ora and the Council of Medical Colleges to embed these principles as private training of surgical registrars increases.

Read our submission.

Consultation on the communication protocol for accreditation of specialist medical training site posts
Te Kaunihera Rata o Aotearoa | Medical Council of New Zealand (MCNZ) and Te Whatu Ora – Health New Zealand (Te Whatu Ora) developed with the Council of Medical Colleges the draft of a proposal to update the Communication protocol for Accreditation of Specialist Medical Training Settings in AoNZ.

The Protocol outlines the roles, responsibilities, and communication mechanisms between the parties – MCNZ, Te Whatu Ora, and those specialist medical colleges which choose to sign it. 

The work on the Protocol arose from concerns from the colleges and the New Zealand Resident Doctors’ Association about the ongoing risk of loss of training positions.

The primary role and focus for MCNZ is protecting the public by ensuring high quality training, focusing on the system working properly, from its standpoint one step removed from the interests of a particular facility. Te Whatu Ora is looking to normalise escalation of problems, require reporting of all notifications, and standardise processes on a national basis. All parties agreed it is important issues are escalated effectively by each party before an impasse is reached. A named position within each organisation will be established as the contact point, potentially at two levels within Te Whatu Ora.

For RACS the benefit of this work is a clear line of sight within Te Whatu Ora—being able to escalate nationally when issues are not being dealt with at sites, as it is currently hard for colleges to access the local escalation processes.

RACS provided feedback on the draft Protocol. The key points being:
•  The unique matter for RACS (among the medical colleges) is the involvement of the surgical specialist societies which coordinate, action and attend accreditation visits. While societies are not individually parties to the protocol; their roles and responsibilities should be included.
•  Agreement with the principle: The withdrawal of accreditation from a setting should be a last resort with colleges, HNZ and MCNZ endeavouring to resolve issues in a manner that minimises adverse impacts on the training, wellbeing and education of trainees, and service provision.
•  While the draft Protocol was developed for medical training accreditation in public hospitals and health facilities, we will need to consider extension to cover private facilities where significant public work is outsourced or undertaken for ACC. The cost and fees for accreditation of private facilities will need to be considered.
•  All supervisors and Trainees should have access to and undergo appropriate training in cultural safety, cultural competency, and Te Tiriti o Waitangi.

We will be involved in further joint work to finalise the Protocol.

Code of Conduct for public servants – doctors working in the public sector 
The Public Service Commission undertook targeted consultation on a draft revised Code of Conduct for Public Servants (the Code). 

The Code is significant for doctors because the Healthy Futures (Pae Ora) Amendment Bill issued in July 2025 proposed all Te Whatu Ora employees be required to ‘uphold the public service principles, including political neutrality’ as set out in the Code. Doctors speaking out on inadequacies in the health system, or the impact of policy proposals on patient safety, could be seen as in breach of the Code. We submitted this was a ‘silencing’ mechanism, contravening professional and ethical standards, which require doctors to serve and advocate for patients and the public.

The Public Service Commission indicated to Council of Medical Colleges such ‘silencing’ was not intended; the Code of Conduct, already under review, would make the situation clear.

Our submission on 17 October 2025 supported the need for the Code and clarifying its application to doctors. It is essential the Code recognises and accommodates the professional obligations of medical practitioners and other regulated health professionals working in the public sector. It is also vital the Code recognises vocationally registered health professionals must also abide by their college’s Code of Conduct and considers the interface between these Codes. 

Health advocacy is a central competency of a surgeon, and a core value of this College. Surgeons must not be constrained from professional advocacy on policy proposals and organisational changes, which may impact the safety of patients, whānau, carers, the health workforce, and healthcare system. Likewise, they must not be constrained in relation to the impact on achieving better health outcomes for the diverse communities in Aotearoa New Zealand. 

We submitted that some specific provisions in the Political Neutrality section of the draft revised Code need further work. Wording should be explicitly designed to avoid ambiguity or conflict with the professional obligations of medical practitioners working in the public sector.

Read our submission on the RACS website.

New Zealand Melanoma Clinical Guidelines
The National Melanoma Working Group (NMWG), with support from Skin Cancer New Zealand, is reviewing the revised New Zealand Melanoma Clinical Guidelines (Guidelines). The review had a particular focus on neoadjuvant and adjuvant treatment, which is now funded in Aotearoa New Zealand.

We commended them on producing well-researched, referenced, and practical melanoma guidelines, which will hopefully improve the care provided for melanoma in Aotearoa New Zealand. The inclusion of key performance indicators for some stages will allow progress towards these targets to be measured. 

We recommended the guidelines use Aotearoa New Zealand rather than just New Zealand—Te reo Māori is an official language of Aotearoa New Zealand. Our Māori population has poorer melanoma health outcomes, and we must work to reverse this inequity. Māori often feel disenfranchised by our healthcare system and are less likely to seek help at earlier stages. We also recommended adding ‘data sovereignty’ as an important issue for Māori considering the use of artificial intelligence.

The revised draft guidelines were reviewed in detail by Dr Sarah Rennie, Aotearoa New Zealand Surgical Advisor, who made a range of other suggestions as set out in our submission. 

Read our submission.

Te Whatu Ora – proposed approach to advance offers for Fellows
Te Whatu Ora consulted us on an Early Draft Proposed Approach: Advance offers for Fellows. We supported the proposal to test and introduce advance offers for Fellows. RACS has for some time been advocating for measures to ensure doctors can commit to specialist surgical Fellowship training whether in Aotearoa or overseas, knowing they have secure roles in Aotearoa at the end of this time. Retaining and reattracting Fellows is a key part of the strategy to build a sustainable surgical workforce within Aotearoa. It will also maximise the return on our investment in training, reducing the loss to other health systems. We expect a significant benefit of the proposal to be Fellows accepting SMO positions in regional and rural hospitals where recruitment is most challenging. 

We agreed with the overall proposed approach to formalising the process for advance offers, the rigorous approach proposed, and the early consultation with colleges before consulting more widely. 

However, we conveyed some concerns and suggestions:
•  Achieving a sustainable surgical workforce will be significantly dependent on the availability of budgeted positions (FTE) within Hospital and Specialist Services. To enable successful implementation, the budget for new positions in the relevant year must be a pre-condition, not a constraint. There is a clear need in some areas to increase FTE to provide appropriate capacity.
•  Making advance offers by moving resource from current positions, with SMOs choosing to reduce their position, job share, or commit to a retirement date, has been successful informally, and could be formalised. 
•  Consideration should be given to offering less than 1.0 FTE positions as advanced offers or enabling Fellows to access less than 1.0 FTE. 

Of the three options proposed:
•  Our clear preference was: An advance job offer of a specified role in a specified location within a region as likely to be the greatest incentive for Trainees to commit to returning from a specialist surgical Fellowship.
•  An advance job offer for a specified role at an unspecified location within a region is much less of an incentive and should be improved by specifying some locations if possible.
•  An invitation to join the National SMO Talent Pool may capture the interest of a new Fellow but is not an incentive for returning post-Fellowship. 

Read our submission.

MCNZ statement on Using artificial intelligence (AI) in patient care 
MCNZ consulted on a draft statement on Using artificial intelligence (AI) in patient care. We supported the draft as circulated, although noting it will be challenging to apply in practice. As use of AI increases within all aspects of medical practice and patient care, the issue of patient consent and the implications for patients who decline treatment will become both more nuanced and more significant.

The draft statement outlined what doctors need to consider when they use AI in activities directly related to patient care. We submitted the seemingly straightforward differentiation between patient care and medical administration required further clarification. We submitted that the seemingly straightforward differentiation between patient care and medical administration requires further clarification.

AI is likely to form the backbone of the organisational structure and administration of many medical practices, with no option of a person booking and amending appointments for clinics, procedures, and scans, or undertaking administration, transcription, and typing.

In relation to patient care, we agreed doctors must never use an AI tool to represent them in the practice of medicine, for example by using an avatar, chatbot or deep-fake video to carry out a consultation. However, there will be a useful role in future for AI avatars in education. Safeguards required will be along the lines of ‘the avatar can provide generic information only, not specific medical advice, and AI generated content must be clearly labelled’.

Patient consent will become a more nuanced consideration in future as use of AI increases within all aspects of patient care and treatment. Doctors will need to consider the important question of the implications for patients who chose to decline an AI element, which is fundamentally integrated into a service. Can we offer them options? Will their care be jeopardised or possibly declined? We suggested the issue of requesting and confirming patient consent be covered more fully.

Associate Professor Matthew Clark, Chair of the RACS AI in Surgery Advisory Group, contributed to and endorsed our submission.
 
Read our submission 

Te Whata Kura – National Antibiotic Guidelines for Aotearoa
The University of Auckland Antimicrobial Stewardship Team sought feedback on the draft electronic version of Te Whatu Kura - National Antibiotic Guidelines for Aotearoa. We supported development of the resource to help achieve effective, equitable and sustainable use of antibiotics, noting RACS’ own commitment to address inequities in antibiotic use. We shared the link with the members of the AoNZ National Committee, requesting feedback within the app and to contribute to a RACS submission.

The general feedback was Te Whatu Kura will be a valuable resource—it is clear, simple to navigate and on point. We suggested checking alignment with the Health Pathways available to general practitioners to guide disease management and referrals (the team has responded this is underway), and provided some specific feedback where changes are needed. 

Read our submission