Chapter 3 Accreditation, registration and other processes
To practice medicine in Australia IMGs need to have their medical
qualifications accredited and their medical knowledge and skills assessed.
These processes are designed to assess eligibility for IMGs to work towards full
registration, allowing them to practise in Australia either as a general
practitioner or specialist. The Australian Medical Council (AMC) and the
Medical Board of Australia (MBA) through the Australian Health Practitioners
Registration Authority (AHPRA) are primarily responsible for accreditation and
In addition to navigating the AMC and MBA/AHPRA processes, IMGs seeking
to practise in Australia also usually need to interact with a range of other
government and non-government organisations to formalise their residency and
This Chapter provides a detailed description of the accreditation and
registration processes that are available to IMGs and briefly outlines other
inter-related processes that an IMG may have to pursue to practise in Australia
and progress toward full medical registration.
When an IMG seeks to work as a medical practitioner in Australia they
have to engage with a number of organisations, including, but not limited to:
n the Australian
Medical Council (AMC) for recognition of academic qualifications and the
certification of documents;
n a specialist medical
college for assessment of equivalence of qualifications and experience if seeking
n the Medical Board of
Australia (MBA) through the Australian Health Practitioner Regulation Agency
(AHPRA) to gain registration as a medical practitioner;
n the Australian
Government Department of Immigration and Citizenship (DIAC) to arrange
permanent or temporary migration to Australia;
n the Australian
Government Department of Health and Ageing (DoHA) for information on Districts
of Workforce Shortage (DWS) if they are seeking to work in a DWS;
n Medicare Australia to
acquire a Medicare Provider Number;
n state governments for
advice on Area of Need (AoN) if seeking an AoN position;
n employment and
recruitment agencies; and
n employers (depending
on visa class and the type of registration).
The sequence in which an IMG needs to engage with each of these
organisations depends on a range of individual circumstances. Typically, an IMG
commences the process of attaining full Australian medical registration with
the following initial steps:
n sourcing all of the
documentation required for immigration, accreditation and registration
n if not in English, ensuring
that all relevant documentation has been translated by a certified interpreter;
n having all the
necessary documents verified in accordance with the requirements of the
relevant organisation or agency;
n passing prescribed
English language proficiency exams;
n completing a number
of forms relevant to their selected immigration, accreditation and registration
pathway in the exact prescribed format; and
n paying the relevant
Failure to complete any of these steps adequately can result in an
increase in costs associated with the program, as well as increasing the total
amount of time expended applying to work in Australia and gaining registration.
This Chapter outlines the accreditation and registration processes that
an IMG must follow when seeking employment in Australia. This Chapter does not
provide an analysis of the issues arising from these processes. Consideration
of issues presented in submissions and raised by witnesses in relation these processes
can be found in later Chapters of the report.
Under the National Registration and Accreditation Scheme (NRAS) the AMC
is the national authority responsible for the accreditation of medical
professionals. It is also responsible for the accreditation of
university medical schools and the specialist colleges that deliver medical
The functions of the AMC are to:
n develop accreditation
standards, policies and procedures for medical programs of study based predominantly
in Australia and New Zealand and for assessment of international medical
graduates for registration in Australia.
n assess, using the
approved accreditation standards, undergraduate medical programs (the
specialist medical colleges assess postgraduate programs) and the institutions
that provide them – both those leading to General Registration and those
leading to Specialist Registration of the graduates to practise medicine in
n assess other
countries’ examining and accrediting authorities to decide whether persons who
successfully complete the examinations or programs of study conducted or
accredited by those authorities have the knowledge, clinical skills and
professional attributes necessary to practise medicine in Australia.
n assess the knowledge,
clinical skills and professional attributes of overseas qualified medical
practitioners seeking registration to practise medicine in Australia.
Depending on individual circumstances and the type of registration
sought, there are a number of pathways which IMGs can follow. Regardless of the
pathway selected however, the AMC requires all IMGs to undergo the process of
primary source verification of qualifications and provide proof of identity.
Primary source verification of qualifications and proof of identity
The Medical Board of Australia (MBA) has established a national policy
for all IMGs for the assessment of qualifications by the International
Credentials Service of the Educational Commission for Foreign Medical Graduates
(ECFMG) of the United States. The AMC administers the process for primary
source verification (also known as EICS) which involves:
... the medical qualifications documents of all IMGs being electronically
scanned and sent to the Educational Commission for Foreign Medical Graduates of
the United States (ECFMG) for verification. The ECFMG forwards the documents on
to the original issuing authorities for confirmation that they were issued to
the IMG concerned. The ECFMG maintain an annually updated list of designated officials
who are authorised to verify qualifications.
In addition to primary source verification, IMGs are also required to
fulfil proof of identity requirements to verify that they are in fact the
person they claim to be. This requires an applicant to supply a certified copy
of his/her passport, plus one other certified copy of identification from a
list provided, which includes drivers licence, credit card or current
registration. At least one of the
submitted documents must include both a recent photograph and the applicant’s
As noted below, the AMC’s proof of identity process which is an integral
part of the accreditation process, is separate and distinct from the MBA/AHPRA proof
of identity process which is needed for registration:
All applicants for medical registration will be required to
satisfy the Proof of Identity Framework and Requirements of the Medical Board
of Australia, which is separate to the AMC's requirements, in order to obtain
Please note that some of the identification requirements set
out by the Medical Board of Australia cannot be met by applicants applying from
overseas. The AMC has therefore developed its own proof of identity
requirements that can be met by doctors applying from overseas for assessment
through the AMC.
AMC pathways to registration
All IMGs need to commence the process of registration by applying to the
AMC to have their medical training accredited. There are a number of pathways
available including the following:
n Competent Authority
performance assessment (minimum of 12 months).
n Standard Pathway
n Specialist Pathway
IMGs seeking registration for independent practice; and
-> Area of
Need (AON) Specialist Pathway.
It is at the IMG’s discretion which pathway they apply for. The outcome
of the AMC process is the provision of the AMC certificate which enables an IMG
to apply for either Provisional or Limited Registration
depending of the pathway chosen, and to commence work in the Australian medical
It is also important to note that once an IMG’s medical training has
been accredited by the AMC, they must also satisfy all of the MBA’s
registration requirements in order to be eligible for registration. The
registration requirements are outlined later in this Chapter.
The Competent Authority Pathway
The Competent Authority Pathway is for non-specialist IMGs who have
obtained their medical qualifications in a country that is considered to have a
comparable medical education system to Australia and is listed by the AMC as an
approved competent authority. At present, competent authorities that are
n United Kingdom
(General Medical Council);
n Canada (Medical Council
n United States (United
States Education Commission for Foreign Graduates, the Accreditation Council of
Graduate Medical Education);
n New Zealand (Medical
Council of New Zealand); and
n Republic of Ireland
(Medical Council of Ireland).
In addition to the five countries listed above, the AMC has indicated
that is actively considering extending competent authority status to other
countries with substantially comparable systems of medical education and
training. Extending the list of competent authorities is considered by the
Committee in more detail in Chapter 4.
In being assessed through the Competent Authority Pathway an IMG is
eligible for ‘advanced standing’ towards the AMC Certificate. An IMG with
‘advanced standing’ may apply for Provisional or Limited Registration through
the MBA/AHPRA. The IMG is generally then required to undertake a minimum of
twelve months workplace performance assessment in a designated position prior
to being eligible to receive the AMC Certificate.
Upon successful completion of this pathway the IMG is awarded an AMC Certificate
and is eligible to apply for General Registration through the MBA/AHPRA.
The Standard Pathway (2-part assessment)
IMGs that completed their medical training at institutions not presently
on the AMC Competent Authority List are required to undertake screening and
examination of their medical knowledge and skills. IMGs who are not seeking Specialist
Registration may be eligible to gain registration through the Standard Pathway.
To gain the AMC Certificate through the Standard Pathway an IMG must successfully
complete the following sequential components:
n the AMC Multiple
Choice Question (MCQ) Examination; and
n the AMC Structured Clinical
The AMC Examinations are designed to assess the medical knowledge and
clinical skills of IMGs whose basic medical qualifications are not recognised
by the MBA; that is, doctors trained in medical schools that have not been
formally reviewed and accredited by the AMC.
The AMC MCQ Examination was a computer-administered multiple choice
question examination that was used at the commencement of the inquiry. It
contained 300 items (240 of which were scored) and was available on secure
computer sites both in Australia and offshore.
In 2011 the AMC MCQ Examination was replaced by the AMC Computer
Adaptive Testing Multiple Choice Question (AMC CAT MCQ) Examination, a
computer-administered fully integrated examination delivered in one (3 ½ hour)
session that consists of:
n 150 multiple choice
questions (where there is one correct response from five options); and
n 120 scored multiple
choice questions and 30 pilot (non-scored) multiple choice questions.
The AMC CAT MCQ Examinations are conducted in examination centres in
Australia and worldwide.
The SCE assesses clinical skills
and is conducted in teaching hospitals in Australia. The SCE is a multi-station
16 component test including three obstetrics/gynaecology stations and three
Once these examinations have been passed the IMG is issued with an AMC
Certificate and is eligible to apply to the MBA/AHPRA for Provisional or Limited
Registration. To achieve General Registration, the IMG is usually also required
to complete 52 weeks of supervised practice. During these 52 weeks IMGs are generally
expected undertake the following hospital based components:
n 10 weeks of surgery;
n 10 weeks of medicine;
n 8 weeks of Emergency
Applicants for General Registration who have not completed any part of
the core rotations in Australia must be able to demonstrate to MBA/AHPRA that
they have achieved the learning outcomes expected in the rotation/s they have
The Standard Pathway (Workplace-based Assessment)
The Standard Pathway (Workplace-based Assessment) has been established
as an alternative pathway to the AMC Clinical Examination and tests clinical
skills in the actual environment of doctors' everyday practice.
According to AMC guidelines, an IMG must pass the AMC CAT MCQ to be
eligible for the Standard Pathway Workplace-based Assessment, and must:
n provide evidence of English
n provide evidence of Primary
Source Verification (this does not need to be completed prior to commencing the
pathway, but is needed to obtain the AMC Certificate); and
n have obtained Limited
Registration through MBA/AHPRA; and
n be currently employed
in a clinical position with an AMC-accredited authority.
The AMC advised the Committee that although this pathway was included in
the original 2007 COAG IMG Assessment Initiative proposals, it was not endorsed
and signed off by all Australian jurisdictions at that time. As a result,
implementation of this pathway has been delayed. Presently this pathway is not
available nationwide and is currently being trialled in four state (NSW, Vic,
Tas and WA). IMGs that successfully complete
this pathway are entitled to apply for General Registration.
The Committee comments further on the value of the workplace-based
assessment pathway and its availability in Chapter 4 of the report.
IMGs who are deemed to be specialists or who have trained as a
specialist in their country of origin may pursue one of the pathways towards
registration as a specialist medical practitioner in Australia.
Assessment of an IMG’s claims for Specialist Registration is conducted
by one of Australia’s sixteen specialist medical colleges. Once an IMG’s
qualifications are verified through primary source verification, the AMC refers
the IMG to the relevant specialist medical college to receive specialist
assessment of their qualifications. The AMC is responsible for the
accreditation of specialist medical colleges.
There are two pathways an IMG may follow to achieve specialist
n Specialist Pathway
(Full recognition); and
n Specialist Pathway
(Area of Need).
The Specialist Pathway (Full Recognition)
This section provides an overview of what ‘generally’ occurs when a
specialist IMG uses the Specialist Pathway to seek Specialist Registration in
Australia. However, it should be noted that each specialist medical college has
its own assessment process.
The AMC noted the challenges faced in reviewing overseas specialist
training, noting that it presented:
... an even more complex challenge for recognition and
registration than basic or primary medical training. There are substantial differences
in the format and content of specialist training and practice between
countries. Some adopt a formal postgraduate training program administered on
completion of a primary (or undergraduate) medical course. Other countries
integrate specialisation into the primary (or undergraduate) training with a shorter
period of postgraduate specialist training than would be considered generally appropriate
in Australia or other countries with developed specialist training schemes. In
other countries again, there may be no formal postgraduate specialist training
as such, but relevant work experience may lead to licensure to provide
‘specialist’ medical services.
As with the Competent Authority Pathway and the Standard Pathways, the
AMC has a significant role in administering the process. Essentially, specialist
medical colleges assess IMGs by comparing each applicant to an
Australian-trained specialist. In assessing the applicants, specialist medical colleges
make an initial assessment that the applicant is either:
comparable with an Australian-trained practitioner, in which case the applicant
is considered suitable for recognition as a specialist. The applicant is eligible
to apply for admission to Fellowship of the relevant specialist medical college,
subject to up to 12 months work under oversight to confirm the initial
assessment, and to ensure the practitioner's satisfactory integration into the
Australian health system (this is sometimes termed ‘peer review’); or
n partially comparable with
an Australian-trained practitioner, where the applicant requires up to two
years further up-skilling in aspects of the discipline to reach the standard of
an Australian-trained practitioner; or
n not comparable with
an Australian-trained practitioner, in which case it is necessary for the
applicant to enter the relevant specialist college training program on a
competitive basis with Australian-trained graduates, possibly with some
recognition of previous specialist training undertaken overseas or pursue
Table 1.1 presents the 11 step Specialist Pathway to registration as a
specialist medical. It details actions undertaken by the AMC, the applicant,
the MBA and the relevant specialist college.
Table 3.1 Eleven step specialist pathway to registration
as a specialist medical
The AMC receives forms and documentation from applicant
The application is assessed through AMC Primary Source
Referral is sent to the relevant college and the applicant
is advised that this has happened
The applicant completes and sends Form SC
and initial assessment fee to specialist college
The college assesses the application against college
standards to determine compatibility to an Australian-trained specialist
The AMC receives a report from the specialist medical
college advising of applicant’s level of comparability. The report forwarded
Note: at this stage in the specialist assessment process
an applicant who has been determined to be substantially
comparable to an Australian trained specialist proceed to step 9.
an applicant who has been determined to be partially comparable
to an Australian-trained specialist and to require additional components of
the assessment procedure proceed to step 7.
an applicant who has been determined to be not comparable to an
Australian-trained specialist has their application for specialist assessment
The applicant advises the AMC in writing of their
intentions to comply with the requirements set out in the specialist medical
college’s initial assessment (termed Report 1)
The AMC then advises the specialist medical college of the
applicant’s intention to comply with the requirements set out in Report 1,
for example undergo 24 months of peer review.
Following the applicant’s completion of Report 1
requirements the Specialist Medical College advise the AMC of final
assessment decision via the second assessment by the specialist medical
college (termed Report 2)
The AMC receives Report 2 from the college and forwards a
copy to the applicant.
Note: at this stage in the specialist assessment
an applicant who has been determined to be substantially
comparable to an Australian trained specialist proceeds to step 11
an applicant who has been determined not to be comparable to an
Australian trained specialist has their application for specialist assessment
The AMC advise the relevant medical board of the
applicant’s eligibility to present for registration as a specialist.
Medical Council, Submission No 42, p 15.
The Specialist Pathway (Area of Need)
Specialist IMGs who wish to practice their specialty in a position that
has been designated as an Area of Need (AoN) position are able to apply to the
AMC through the Specialist AoN Pathway.
AoNs are declared by the relevant state and territory governments.
Although methods of defining them vary between jurisdictions, essentially an
AoN is any location in which there is a lack of specific medical practitioners,
or where medical positions have remained unfilled following various recruitment
efforts. AoNs may apply to specialist positions in both public and private
Because of the identified need, the accreditation process is fast-tracked
by all parties involved in this pathway. The AMC website details the
application process for those seeking to work in an AoN as follows:
The documentation requirements and arrangements for
processing ‘Area of Need’ Specialist Applications are similar to those for
applications through the standard Australian Medical Council (AMC) Specialist
Pathway for overseas-trained specialists.
However, there are some differences because the AMC and the
assessing college process area of need applications in parallel to save time.
To pursue the Specialist AoN Pathway, an IMG must have already been
selected by an employer and deemed suitable for an AoN specialist position. The
AMC verifies documentation related to the specific job requirements and at the
same time, the relevant specialist medical college assesses the applicant
against the detailed position description provided by the jurisdiction, rather
than the standards required of an Australian-trained specialist in that
If the outcomes of the AMC and special college assessment processes are
satisfactory, the specialist college advises the MBA and the employer that the
IMG is suitable to fill the AoN. The assessing college also proposes any limitations
it deems necessary in relation to the extent and nature of the IMG’s practice. On
the basis of this information the MBA/AHPRA proceeds with an AoN Limited Registration.
This registration is linked to ongoing monitoring and assessment undertaken by
the college over a defined period. Reports are provided to the employer and the
MBA, with continued registration being depended on satisfactory performance.
It should be noted that specialist IMGs assessed as suitable to work in
a specific AoN may not be assessed as substantially comparable to an Australian-trained
specialist and suitable for independent practice. This can drastically reduce
the mobility of specialist IMGs employed under the AoN scheme. It is expected
that IMGs working in AoN positions should be working towards qualifying for General
or Specialist Registration, or planning to return to their country of origin
after gaining experience in Australia.
The purpose of registration of IMGs is to ensure that all doctors
practising medicine in Australia meet a minimum standard equivalent to their
Australian counterparts. This ensures that the Australian health system
maintains its high standard of quality and safety.
The Medical Board of Australia (MBA) is responsible for the registration
and regulation of medical practitioners. Once medical practitioners are
registered they are able to practise medicine in Australia.
Categories of registration
The MBA can register medical practitioners including IMGs (provided they
meet the registration requirements) under several categories. These categories include:
n General Registration;
n Provisional Registration;
n Limited Registration;
n Specialist Registration.
General Registration allows medical practitioners to practice independently
in all fields of medicine. Most medical practitioners
in Australia practice under General Registration.
General registration (s 52 of the National Law) is available to medical
n who have completed a
medical degree and an approved internship in Australia or New Zealand; or
n who have had their
eligibility assessed through the Competent Authority Pathway and have completed
a period of supervised training in accordance with the MBA/AHPRA registration
n who have qualified
outside of Australia or New Zealand, and demonstrated equivalence by obtaining
the AMC certificate via the AMC examination process and completed a period of
Provisional Registration is granted to Australian or New Zealand
graduates who are applying to undertake an approved intern position. Intern
positions are approved by the MBA and are of usually 12 months duration. After
successful completion of the intern year, practitioners working under
Provisional Registration may apply for General Registration.
IMGs who have obtained the AMC certificate through the AMC Standard Pathway
are also eligible for Provisional Registration. As noted in the preceding
section, IMGs applying for General Registration are generally expected to have
undertaken a period of supervised practice.
Limited Registration is available to medical practitioners whose medical
qualifications are from a medical school outside of Australia or New Zealand.
Limited Registration is available for both specialists and non-specialists. It allows
a medical practitioner to practise under supervision. Practise under this form
of registration may be limited in scope, duration or by location.
The purpose of providing Limited Registration is to ensure that IMGs
work within a framework that ensures public safety and which encourages them to
reach the Australian standard.
The MBA reported in its submission that Limited Registration is always
granted for a specific purpose, namely:
n to allow for work in
a designated AoN position;
n for postgraduate
training or supervised practice;
n to allow practise in
the public interest; and
n for non-practising
registration for teaching or research.
Limited Registration for Area of Need
IMGs who are working under Limited Registration to work in an AoN
position (s 67 of the National Law) are usually working under supervision in an
area of medical workforce shortage. As noted earlier, while definitions for AoN
differ between state and territory jurisdictions, IMGs practising medicine
under this category must comply with the relevant MBA Registration Standards
n compliance with a
n compliance with a
professional development plan;
n authorising and
facilitating regular reports from their supervisors about their safety and
competence to practise; and
Limited Registration for Postgraduate Training or Supervised Practice
Limited Registration for Postgraduate Training or Supervised Practice (s 66
of the National Law) is for IMGs who are undertaking supervised medical
training in Australia. IMGs practising medicine under this category of
registration must comply with relevant MBA Registration Standards which include:
n compliance with a
n compliance with a
n authorising and
facilitating regular reports from their supervisors about their safety and
competence to practice; and
IMGs with Limited Registration wishing to practise medicine in Australia
in the longer term are expected to make progress towards gaining full General
or Specialist Registration.
Other types of Limited Registration
While the MBA allows for Limited Registration to be granted for other
purposes (eg for the public interest or for teaching and research) these are
not examined as the focus of the inquiry is on IMGs wishing to practise and
qualify for full Australian registration (either General or Specialist
Specialist Registration allows independent practise in an approved area
of medical specialty. When registering specialist
IMGs, the MBA/AHPRA takes advice from the AMC and specialist medical colleges
on the qualifications and comparability of individual IMGs.
As noted in the submission from DoHA:
Specialist registration is available to medical practitioners
that are assessed by AMC accredited specialist colleges as being eligible for
Fellowship. AMC accredited Specialist Medical Colleges in Australia are
responsible for setting and administering programs relating to specialist
medical training and examinations including the assessment of IMGs. Where
components of the college examination and assessment procedures are applied,
they are the same as, or derived from, those that apply to local specialist
trainees. The colleges provide the AMC and the MBA with advice on the outcome
All medical practitioners must meet certain requirements before they are
registered and permitted to provide medical services in Australia. This applies
to medical practitioners trained in Australia, as well as to IMGs, who must
also meet some additional requirements.
In addition to fulfilling the necessary AMC accreditation requirements
as outlined earlier, IMGs must also fulfil a number of MBA registration
requirements. According to the MBA’s submission:
The National Law requires that applicants for registration
are eligible, qualified and suitable for the particular type of registration
being applied for. The requirements help the Board to ensure that an IMG
applying to practise medicine in Australia:
n is the person they
are claiming to be - Proof of identity and all supporting documentation is that
of the same person applying for registration;
n is medically
qualified - holds a primary medical qualification from a recognised medical
n is able to
communicate effectively in English to a standard expected of medical
practitioners practising in Australia.
n meets the recency of
practice standard as required by the National Law which identifies whether the
IMG's skills and knowledge are up-to-date with current medical practice in the
area the IMG intends to practise medicine.
n is a suitable person
to practise as a medical practitioner. That is, the IMG has no previous or
on-going criminal history or disciplinary action taken by another registering
authority which may impact on the ability of the individual to provide
competent, safe and ethical care to the public.
n does not have a
mental or physical impairment that may impact their ability to practise
n will be employed in a
position that is suitable for his or her level of knowledge, skills and
experience and that the appropriate supervision and support mechanisms will be
Specific registration requirements and processes will vary depending on
the registration pathway selected by the applicant, and the category of
registration sought. However, there are mandatory registration requirements
which apply to all applications for medical registration and to registered
medical practitioners, with the exception of students and non-practicing
registrants. Registration Standards which have been approved by the Australian
Health Workforce Ministerial Council, define the requirements that applicants
need to meet.
In brief, before registering any medical practitioner the MBA must:
n verify the
n verify the
n ensure that the
applicant has undertaken an internship or period of supervised practise;
n ensure that the
applicant is a suitable person to practise medicine in Australia; and
n confirm that the
applicant complies with registration standards for:
professional development (CPD)
indemnity insurance (PII)
As noted earlier in this report, AHPRA was established under the
National Law to administer these processes on behalf of the MBA. AHPRA
commenced operating in July 2010.
Proof of identity
Proof of identity is required for any new application for registration. The
MBA/AHPRA provides detailed information on what documentation need to be
provided as proof of identity, noting that the documents provided must meet the
n All documents must be
true certified or notarized copies of the original.
n At least ONE document
must include a recent photograph ...
n At least ONE document
must be in the applicant’s current name.
n All documents must be
officially translated in English.
n All documents must be
current /valid at the date of submission.
The requirement includes special provisions for applicants seeking
registration from overseas or who have recently (less than 6 weeks previously)
arrived in Australia and who may have difficulty in supplying some documents.
As noted earlier, the MBA/AHPRA proof of identity process is separate to that
required by the AMC.
Evidence of qualifications
IMGs are required to provide information of medical qualifications and
evidence of having undertaken an internship (or equivalent). Documentary
evidence (certified copies of original documents) must be provided in
accordance with AHPRA’s guidelines. Applicants must also demonstrate that they
have had primary source verification from the AMC.
Registration and work history
In addition to evidence of their qualifications, IMGs also need to
provide information relating to their registration history. Specifically the
MBA/AHPRA requires a Certificate of Registration Status or Certificate of Good
Standing from every jurisdiction where the applicant has been registered
(including overseas registrations) during the last 10 years. According to the
AHPRA guidelines original certificates must forwarded directly from the
licensing or registration authority to the relevant state office of the MBA.
Certificates submitted must be dated within three months of the application
Applicants are also required to provide a comprehensive curriculum vitae
(CV) detailing their work practice history, including information on any gaps
in practice history of more than three months. MBA/AHPRA provides guidance on
standard format that the CV should take.
Applicants for Limited Registration are also required to provide written
confirmation of an offer of employment. The sponsoring employer is required to
provide a statement including a detailed position description, information on
proposed clinical supervisors and a detailed supervision and training plan for
Other registration requirements
In addition to the information above, IMGs also need to meet a number of
suitability requirement standards including:
n English language skills
need to be demonstrated by all medical practitioners who have qualified overseas
or received their secondary education overseas. All applicants must be able to
demonstrate English language skills at IELTS academic level 7 or equivalent.
Test results will generally need to be obtained less than two years prior to
applying for registration. Exceptions are made for IMGs who obtained their
qualifications in the following countries: Canada; New Zealand; Republic of
Ireland; South Africa, United States of America; and United Kingdom.
n criminal history is
checked for all new applicants for registration and applicants seeking
registration renewal. Specific factors are considered to determine whether the
criminal history of health practitioners is relevant to the practice of their
n recency of practice standards
requires that all practitioners must have undertaken a certain number of hours
of practice, as specified by the MBA, within preceding years of registration.
This ensures that medical practitioners have recent practice in the fields in
which they intend to work during the period of registration for which they are
professional development (CPD) is required for all registered medical
practitioners, including all applicants for initial registration who are not
new graduates. According to the CPD standards the purpose is to maintain,
develop, update and enhance their knowledge, skills and performance to ensure
that they deliver appropriate and safe care.
indemnity insurance (PII) standard applies to all medical practitioners who
seek to undertake any form of practice. It requires all medical practitioners
to have PII which covers all aspects of their intended practice and for the
whole period of the registration.
In assessing suitability for registration applicants are also requested
to provide information on any disqualifications from practice, suspensions or
cancellations of registration. Information on any physical or mental impairment
which may detrimentally affect an individual’s capacity to practise is also
Pathway specific requirements
In addition to these general requirements, there are additional
requirements for Provisional or Limited Registration depending on the pathway
through which they seek to qualify for General or Specialist Registration.
For example, IMGs on the Competent Authority Pathways are required to
provide the AMC’s Certificate of Advanced Standing and may also be required to
satisfactorily complete a Pre-employment Structured Clinical Interview (PESCI).
IMGs on the Standard Pathway are required to have passed the AMC CAT MCQ,
the SCE (or workplace-based assessment) and may also be required to
satisfactorily complete a PESCI. This will qualify the applicant for
Provisional or Limited Registration for postgraduate or supervised training. An
additional period of approximately 12 months supervised practice is usually
required before the applicant can apply for General Registration.
Applicants for Limited Registration pursuing the Specialist Pathway are
required to provide confirmation of the specialist college assessment
(co-ordinated by the AMC) identifying them as substantially or partially
comparable. Where possible, the college should also provide recommendations
about additional training needed for specialist recognition. Applicants require
the specialist college to confirm that additional training has been
satisfactorily completed to qualify for college Fellowship and Specialist
Applicants for Limited Registration AoN are also required to provide evidence
of an area of need declaration for the geographical area and/or type of health
service for which there is a need. This declaration is issued from the relevant
state or territory Minister for Health or delegate for the jurisdiction in
which the designated area of need position is located.
IMGs working under Limited Registration for postgraduate training or
supervised practice, or for those working in AoN positions, are expected to work
towards General or Specialist Registration if they intend to continue to practise
The MBA is also responsible for registration renewals. Under the
National Law, initial registration as a medical practitioner is granted for a
period of up to 12 months and is then renewed annually.
The registration renewal date for medical practitioners with General or Specialist
Registration is 30 September.
The registration renewal date for practitioners with Provisional or Limited
Registration is determined on a case by case basis. This is generally on the
anniversary of 12 months but may be at an earlier expiry date as determined by
Registration renewal for Limited Registration
Until such time as they qualify for General or Specialist Registration,
IMGs generally qualify for Limited Registration. When considering an IMG’s
application for renewal of registration, the MBA considers whether the IMG is
safe to continue to practise and whether they meet the requirements for
registration. Specifically the MBA takes into account:
n work reports from
n evidence of progress
towards qualifying for General or Specialist Registration;
n whether all other
registration standards have been met (CPD, PII etc); and
declarations regarding impairment, criminal activity etc.
The requirement for IMGs to renew Limited Registration allows the MBA to
identify any potential risks to public health and safety which may result from
an IMG continuing to practise. The MBA may refuse to renew Limited Registration
if the practitioner’s employment ceases or is terminated; if the practitioner
fails to comply with supervision requirements; or if significant deficiencies
are identified in the practitioner’s practise.
Alternatively, the MBA may decide to impose additional conditions on the
applicant’s Limited Registration. Additional conditions which may be imposed on
the IMG include modified levels of supervision, amended training and
professional development requirements, or additional requirements to undergo
additional assessment or examination.
Under s 72(3) of the National Law, 12 month Limited Registration cannot
be renewed more than three times. After this time the IMG needs to reapply for new
As noted earlier, in addition to accreditation and registration processes,
most IMGs wishing to practise in Australia are also required to interact with a
series of other organisations and agencies. The following section briefly outlines
some of the additional processes that IMGs may need to undertake.
Obtaining a visa
The Department of Immigration and Citizenship (DIAC) manages the entry
and stay of people in Australia. According to information on the DIAC website a
key objective is to promote a society which values Australian citizenship,
appreciates cultural diversity, and enables migrants to participate equitably.
IMGs who wish to migrate for the purpose of employment are required to
make contact with DIAC for a visa to enter Australia and for the right to seek
paid employment. For many IMGs, as with other skilled workers, this will
require seeking entry under the auspices of Australia’s skilled migration
program. As outlined by DIAC:
The Department’s skilled migration program provides a number
of temporary and permanent pathways for OTDs including;
n General Skilled
Migration (GSM) (permanent)
n Regional Sponsored
Migration Scheme (RSMS) (permanent)
n Employer Nomination
Scheme (ENS) (permanent)
n Temporary Business
(Long Stay) – Subclass 457.
Permanent residency options
Permanent residency options are available for doctors who have achieved
full medical registration in Australia. The General Skilled
Migration (GSM) pathway allows medical practitioners with full Australian
registration to live permanently in Australia and work in independent practice.
The Regional Sponsored Migration Scheme (RSMS) and Employer Nomination Scheme
(ENS) also provide options for permanent residency for highly skilled workers
on the basis of employer sponsorship.
Temporary residency options
The vast majority of IMGs are initially eligible for temporary residency
only, generally through the Temporary Business (Long Stay) Visa (the 457 visa).
As outlined by DIAC:
Australian organisations (businesses, communities or
government agencies) can sponsor overseas doctors to work in Australia for up
to 4 years.
Temporary visas are the usual pathway to permanent residence
for doctors who do not yet hold full medical registration in Australia.
Overseas trained doctors can commence a period of supervised practice and
formal assessment in Australia to meet the requirements for full medical
To be eligible for a 457 visas applicants must:
n be sponsored by an
employer to fill a nominated position
n have skills,
qualifications, experience and an employment background which match those
required for the position
n demonstrated English
n be eligible for any
relevant licences or registration required for the nominated position.
Mr Kruno Kukoc, First Assistant Secretary, Migration and Visa Policy
Division, DIAC, informed the Committee that in the 2010–11 financial year,
Australia’s skilled migration program delivered approximately 4 000 doctors to
Australia, with close to 3 000 of these doctors granted temporary skilled
As with all temporary visa categories, there are obligations associated
with the 457 visa. Notably, if an IMG ceases employment, he or she is obliged
n find another employer
who is willing to nominate you
n apply for another
type of substantive visa
n leave Australia
within 28 days unless your visa expires before that time, in which case you
must leave Australia prior to visa expiry.
IMGs who are unsuccessful in obtaining full Australian registration in
the required period, or who have been deregistered for whatever reason, have to
leave Australia within 28 days or earlier, if their visa expires before that
Accessing Medicare practitioner benefits
To work as a medical practitioner in Australia, IMGs may need access to
a Medicare provider number. The Medicare provider number is a unique identifier
linked to the individual medical practitioner and the location from which they
practise. The Medicare provider number is used by medical practitioners to:
n raise referrals for
specialist services; and
n make requests for
pathology or diagnostic imaging services.
A Medicare provider number may also be used to claim Medicare rebates
for professional services rendered – that is, to treat private patients. 
Section 19AB of the Health Insurance Act 1973
However, under the Health Insurance Act 1973 (the Act), many IMGs
are subject to restrictions which limit the circumstances under which they can
apply for a Medicare provider number. For IMGs who are not permanent residents
or Australian citizens, including most IMGs with Limited Registration, the
following restriction applies:
Section 19AB of the Act applies to overseas trained doctors
(OTDs) and foreign graduates of an accredited medical school (FGAMS) who gained
their first medical registration on or after 1 January 1997. Section 19AB of
the Act restricts their access to Medicare benefits and requires them to work
in a 'district of workforce shortage' (DWS) for a minimum period of ten years
from the date of their first medical registration.
This legislative provision, often referred to as the s 19AB restriction or
the 10 year moratorium, is intended to ensure equitable distribution of medical
services across Australia, including services in outer-metropolitan, regional,
rural and remote locations. The incentive to attract IMGs to work in districts
of workforce shortage (DWS) locations is to offer
access to Medicare professional benefits by exempting them from the s 19AB
restriction if they choose to work in a DWS.
DWS are determined by DoHA and are geographical areas in Australia where
the population's needs for healthcare have not been met.
The process for determining DWS is described by DoHA as follows:
Districts of Workforce Shortage (DWS) are areas where the
general population has less access to GPs when compared to the national
average. The Department uses the latest Medicare billing statistics, which
account for all active Medicare billing, and Australian Bureau of Statistics
(ABS) population to determine which areas are a DWS. This information is used
to create a doctor to population ratio which is used as the basis for calculating
DWS. If an area has a lower doctor to population ratio (i.e. less full time equivalent
doctors) than the national average, the area is a DWS.
DoHA provides a locator map which can be used by those intending to work
in general practice to check whether a potential job is located in a DWS.
Information on DWS status of an area with respect to specialist positions is
obtained by contacting DoHA’s Workforce Regulation Section.
To obtain a Medicare provider number an IMG working in a DWS needs to complete
a standard application form and lodge it with Medicare Australia. Medicare
Australia provides the information to DoHA which determines whether a s 19AB
exemption is approved, and then notifies Medicare Australia accordingly. The
Committee heard from Medicare Australia about the process of obtaining a
Medicare provider number for IMGs practising in a DWS. Once an exemption has
been approved, Medicare Australia provides the applicant with a Medicare
provider number and the information they need to make claims for professional
services. According to Medicare
Much of that process, although it does involve the two departments,
is seamless to the doctor.
There are options for IMGs to reduce the period of their obligation to
work in DWS under the s 19AB restriction. One option is to complete the
requirements of the Five Year Overseas Trained Doctor Scheme run by DoHA. Eligible
locations are usually those where recruitment and retention of medical
practitioners has been particularly problematic.
The scheme requires IMGs to complete a period of service within an
eligible rural or remote area of between three and five years. It also requires
IMGs to obtain permanent Australian residency and Fellowship with either the Royal
Australian College of General Practitioners or the Australian College of Rural
and Remote Medicine.
Alternatively, reductions on the period of the 10 year moratorium can be
obtained through a ‘scaling mechanism’ available to IMGs who establish private
practice in eligible regional, rural and remote areas as defined under the
Australian Standard Geographical Classification – Remoteness Areas (ASGC-RA).
In addition to working in an eligible location, the practice must meet a
Medicare billing threshold of $5 000 per month. Table 1.2 shows the moratorium
reductions available under this arrangement.
Table 1.2 Scaling of period of 19AB restriction according
ASGC RA 1 Major Cities
ASGC-RA 2 Inner Regional
ASGC-RA 3 Outer Regional
ASGC-RA 4 Remote
ASGC-RA 5 Very Remote
Period of restriction
of Health and Ageing, Submission No 84.1, p 6.
Section 19AA of the Health Insurance Act 1973
Australian medical graduates and IMGs who are permanent residents or
Australian citizens and who do not hold continued recognition by the Royal
Australian College of General Practitioners, or the Australian College of Rural
and Remote Medicine, or by a recognised specialist college, are subject to
restrictions s 19AA of the Health Insurance Act 1973 (the Act). According
to information on DoHA’s website:
Section 19AA of the Health Insurance Act 1973 (the Act) was
introduced to recognise and support general practice as a vocational specialty,
as well as to provide a framework for achieving long term improvements in the
quality of doctors working in Australia.
All medical practitioners restricted by s 19AA are unable to access
Medicare benefits unless they participate on an approved training or workforce
program under s 3GA of the Act. Programs approved under s 3GA are:
n Rural Locum Relief
n Queensland Country
n Approved Medical
Deputising Service Program;
n Prevocational General
Practice Placements Program;
n Australian General
Practice Training Program;
n Approved Private
Emergency Department Program;
n Special Approved
n Temporary Resident
Other Medical Practitioners Program; and
n Specialist Medical
Colleges in Australia.
Alternatively, the doctor can be placed in a workforce program where
workforce shortages have occurred.
IMGs that have completed their commitment to s 19AB are subject to the
restrictions under s 19AA of the Act. This means that if a doctor completes
their 10 year moratorium but has not gained Fellowship or specialist
recognition, they will still be subject to the restrictions.
Once again, although the specifics will vary depending on the individual
circumstances of IMGs (eg visa type, selected registration pathway etc),
finding a suitable employment opportunity is often a prerequisite to initiating
accreditation and registration processes.
There are many sources of information on employment opportunities that
IMGs seeking to practise in Australia might access. These include:
n newspapers and some
Australian medical journals (many of which are available online);
n some specialist
medical college websites;
n state and territory
government websites which list medical vacancies in public health sector
organisations, including hospitals;
n medical recruitment
agencies representing public and private employers, which actively seek
appropriately qualified medical practitioners, including IMGs, to fill
vacancies all around Australia; and
n state and territory
based Rural Workforce Agencies (RWA) which focus on recruitment and retention
of general practitioners in rural and remote areas of Australia.
Although the process of locating potential employment opportunities may
be relatively straight forward, for many IMGs ascertaining the suitability of a
specific position not only requires a good understanding of the myriad of
processes outlined above, but also a holistic understanding of how these
processes can interact and impact on one another.
For example, in addition to considering the professional merits of a
specific medical position, an IMG may also need to consider whether the
position has an AoN classification if he or she intends to pursue an AoN
registration pathway, and whether it is located in a DWS if seeking access to a
Medicare provider number. In turn, the scope of employment opportunities will
be influenced the applicant’s visa type, residency status and selected
registration pathway. Personal considerations such as access to social
networks, to services and other supports for IMGs and their family members are
also important factors.
As outlined at the beginning of this Chapter, IMGs wanting to practise
in Australia are faced with a complex array of processes. While some IMGs may
seek assistance with navigating these processes, others may attempt to ‘go it
alone’. The remaining Chapters of this report examine issues that have been
raised in evidence, based on the experiences of IMGs who have attempted to
navigate the various processes, as well as other stakeholders involved with
accreditation and registration of medical practitioners, or involved in medical