An Open letter to CPG approved organisations

February 2008

Dear Colleague,

The Pre-Hospital Emergency Care Council (PHECC) wish to raise awareness of its concerns in relation to possible compromises to patient safety for registered practitioners whose first language or primary language of expression is not English and who are engaged in pre-hospital emergency care practice in Ireland.

PHECC is the designated competent authority under the Recognition of Professional Qualifications (2005/36/EC) Regulations 2007. Applications are thus received from Emergency Medical Technicians, Paramedics and Advanced Paramedics from EU Member States and elsewhere. Under European legislation, PHECC is prohibited from carrying out any systematic English language assessment for persons from EU Member States.

Unlike nursing applications to An Bord Altranais or medical practitioner applications to the Medical Council who are bound by additional Sectoral Directives, there is no direct recognition of qualifications in pre-hospital emergency care. PHECC will consider every application based on its individual merits. The applicant’s professional education and training is compared with that currently required in Ireland at the different levels. If deficiencies are found in the comparison, compensation measures apply. Such measures include aptitude testing and periods of adaptation and may go some way to identify an individual whose English language skills are inadequate but these measures are not necessarily designed to assess competency in the English language.

The provision of safe and effective pre-hospital emergency care requires a registered practitioner who is safe and competent to practice according to his/her level of qualifications. Competence in the English language is required to support communication and enable theregistrant to practice safely. Every successful registrant is reminded in writing by the Registrar that a registered practitioner must adhere to the Code of Professional Conduct and Ethics. PHECC’s Professional Code of Conduct and Ethics clearly indicates the individual responsibility for practitioners. The following are four relevant requirements of PHECC’s Code:

Each PHECC registered practitioner shall:-
  • Communicate effectively with patients and their families, seeking informed consent whilst maintaining strict professional confidentiality.
  • Continually evaluate the effectiveness of practice in consultation with other health professionals.
  • Ensure that their practice is congruent with agreed standards/Clinical Practice Guidelines (CPGs).
  • Use the patient care report (PCR) as an account of pre-hospital care provided and clear consecutive evidence of the assessment, decisions made, the care delivered and the response to care.
A PHECC registered practitioner may be subject to a Fitness to Practise enquiry by reason of professional misconduct on the grounds of lack of English language competence. Yet investigations under Fitness to Practise can only occur after a complaint or an adverse event and is not therefore the most efficient mechanism to reduce or eliminate the risks to patients’ safety.

Another vital safety link is the provision of Clinical Practice Guidelines (CPGs) training, to Council’s satisfaction, by CPG approved organisations to existing and new employees including those from overseas. This training shall take place early, for example during induction, and such service providers must ensure that registered practitioners they employ shall only provide care management according to their division on the Register and corresponding CPGs.

Employers have a responsibility to the public to ensure that the EMTs, Paramedics and Advanced Paramedics they employ have the necessary English language competence to engage in safe competent practice and to use and adhere to PHECC’s CPGs. PHECC’s policy to guide the implementation and use of CPGs in Ireland requires satisfactory evidence from organisations who apply, that employees/ volunteers have the linguistic knowledge at the level appropriate to the professional activities to be carried out.

Council policy for CPG approval, the rigorous recognition of qualifications process, the Code of Professional Conduct and Ethics and Fitness to Practise alluded to in this letter are Council strategies to reduce the risks for the pre-hospital patient. It is imperative that employers and individual Practitioners are mindful of their responsibilities in this regard.

Regards,