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Response to Registration Concerns by Foreign Trained Applicants

The HPCSA and the University of KwaZulu-Natal (UKZN) have noted media reports that refer to concerns, especially by foreign qualified medical applicants, also through their organisational representatives, particularly the South African Internationally Trained Health Professionals Association (SAITHPA), regarding the administration of medical examinations for foreign qualified applicants. Not only are these egregious distortions, but they are also harmful and defamatory. There are no grounds for the outlandish and brazen misinformation peddled, especially by SAITHPA. The medical examinations, administered by UKZN, one of South Africa’s most prestigious institutions, on behalf of the HPCSA, are organised and managed with stringent adherence to both South African and international standards. Although, we hardly ever respond to spurious diatribe as that spawned by SAITHPA as is the case here, we have chosen to take the public into our confidence and rebut this attack unleashed on us.

  1. Foreign Qualified Applicants qualifications are ratified by the Education Commission for Foreigners Medical Graduates (ECFMG), regarded as the standard-bearers in authentication and verification of qualifications, still the foreign qualified applicants are forced to repeat certain steps when they attempt to integrate into the SA system.
    • The Education Commission for Foreigners Medical Graduates (ECFMG) helps with verification of the legitimacy of an institution where an applicant may have trained. It however does not confirm equivalence of curricula content to that recognised by the Medical and Dental Professions Board (MDB) for South African institutions. The HPCSA and the UKZN have a cardinal responsibility to ensure that, only applicants deemed competent are allowed to practise without causing harm to the South African citizens. It is for that reason that credible examinations are organised to confirm if indeed applicants meet the highest standards of competence.
    • South Africa is not beholden to any standards of curricula or training other than those determined within the country through its established institutions and mechanisms, including those from the regulatory bodies such as the Health Professions Council of South Africa (HPCSA), the National Qualifications Framework (NQF) as managed by the South African Qualifications Authority (SAQA) and the Council on Higher Education (CHE).
    • Foreign qualified applicants are not entitled for automatic registration, that is, until their competency levels are ascertained by the HPCSA, in this case through theory and practical examinations, currently administered by the UKZN.
  1. HPCSA delayed the scheduling of Board exams from January 2023 to October 2023.
    • The Memorandum of Agreement (MOA) that was entered into between the HPCSA and Sefako Makgatho Health Sciences University (SMU) expired on 31st March 2023, after some extensions. The HPCSA had, even before the expiry of the MOA started a supply chain management (SCM) process to seek a replacement service provider, with initial bids advertised in March 2022, the UKZN was the sole respondent.
    • Due to some procedural technicalities with the initial bid process, a closed bid was subsequently advertised in July 2022 to all universities with medical schools, inclusive of SMU. Again, the UKZN was still the sole respondent. The HPCSA and the UKZN subsequently entered into a MOA on 18 September 2023, and thereafter, the first exam was administrated by the UKZN in October 2023.
  1. Candidates are not provided with the scope for the exams.
    • The Medical and Dental Professions Board (MDB) has issued Medical Board Exam Guidelines that indicate the subject areas that each exam would cover.
    • These guidelines (appended herewith) are available, both on the HPCSA’s website and issued with invitation letters to prospective candidates, that is, ahead of the sitting for each exam.
  2. UKZN increased the “field of study”/scope, without informing the candidates.

The UKZN did not increase the field of study as alleged. The scope, as outlined in the guidelines, is the sole responsibility of the HPCSA’s MDB. UKZN only advocated for the inclusion of the latest editions of textbooks, purely for the benefit of candidates.

  1. Exam Time Duration: Three (3) hours changed to Two (2) hours and candidates not informed.
    • Although in the past, candidates were allowed 3 hours for writing their theory exams, this changed following the revision of the guidelines by the MDB. The MDB does undertake such reviews from time-to-time, to factor in new existing conditions. For example, unlike in the past where exam questionnaires were answered manually, they are now computerised, which has made the process much more efficient.
    • The change to cap exam time at 2 hours was communicated in advance, including through the HPCSA’s website and invitation letters. It is disingenuous to lament the reduced time after exams have been concluded.
  1. Format of the Board Exam.

The format of the Board Exam is clearly detailed within the Medical Exam Guidelines, placed on the website, and shared with candidates on dissemination of invitation letters. The guidelines do indicate that: “The online written examination is a Multiple-Choice examination. (Single best answers) There is no negative marking. It has two components. The first component consists of 75 items assessing clinical knowledge, and the second component consists of 25 items testing ethical and legal knowledge. The test is set in English. Examination time is Two (2) hours”.

  1. Hindrances caused by the HPCSA: Curriculum Review Process. There is a view that applicants are generally trained at internationally well-reputed medical universities, ratified by the Education Commission for Foreigners Medical Graduates (ECFMG), regarded as the standard-bearers in authentication and verification of qualifications, still the curricula are subjected to review by the HPCSA.

It is a requirement for foreign qualified applicants to submit the curriculum they followed abroad for review by the Professional Boards. This enables the relevant Professional Board to establish whether the education and training standards and the duration of study undertaken is equivalent to those offered by the accredited South African educational institutions. The HPCSA cannot make decisions about curriculum equivalence informally, hence the rigorous reviews that get conducted. Just saying the foreign institutions at which applicants studied at are “well-reputed” simply does not cut when it relates to the important task of protecting the South African public. Again, the role of the ECFMG is to confirm the legitimacy of an institution, and not the appropriateness and equivalence of the curriculum offered.

  1. October 2023 Theory Exam, 70 % Failed, 30% passed. How does the HPCSA explain that?
    • The Medical Board Exam is a rigorous form of evaluation used by the Medical Professional Board to establish and ensure whether the foreign qualified health professionals entering the system possesses adequate professional knowledge, skill, values, and competence to practise their health professions.
    • Failure to pass the medical board exam may imply among other things that the quality of training obtained by the foreign qualified candidates does not meet the required standards as set by the Medical and Dental Professions Board.
    • Also, cohorts of candidates sitting for exams are never the same, especially considering that they receive training in different parts of the world under different circumstances. For example, applicants training in Ukrainian universities were severely impacted by the ongoing war in that country. It is therefore irrational to expect a similar pass rate each time an exam is taken.
    • It should also be remembered that the format of the exam is in the form of multiple-choice questions (MCQ), where manipulation is virtually non-existent. The candidate who knows the answer to the question will make a proper choice, accordingly.
  1. There is an agreement between the HPCSA and UKZN to always ensure that a pass rate exceeding 40% is never achieved.

To suggest that the HPCSA and the UKZN go into cahoots and artificially manipulate the pass rate for each exam not to exceed 40%, with no evidence, is not only outrageous, but insulting. The allegation is not supported by facts at all. In as much as most applicants under perform on the theory exams, the performance on the practical exam is more than satisfactory most of the time. Pass rates of 94% and 61% were achieved for the practical exams held respectively on the 5th and 6th December 2023 and the 7th and 8th May 2024.

  1. SAITHPA believed that the availability of exam records will assist understand the high failure rate. SAITHPA maintains that the HPCSA should release the examination records (question papers, memoranda, and video recordings) so graduate should know where they have gone wrong.
    • The HPCSA has a mandate of protecting the public and it is therefore essential for the HPCSA to administer the Medical Board Examination as a form of evaluation to assess whether the foreign qualified applicants possess the knowledge, skill, values, and minimum competence to practise their professions.
    • Also, the HPCSA believes that “education and training” should equip candidates with the requisite knowledge, skills/abilities, attitudes and values and minimum competence to practise their professions as opposed to “drills by question papers and memoranda”.
    • Candidates are allowed to view and/or have their scripts remarked, but according to the policies and procedures of the examining institution (UKZN).
  1. The HPCSA should avail exam documents (question papers, memorandum and OSCE video recordings)
    • UKZN, as the party having intellectual property of the exam documents, advanced the following reasons for decline of requests based on section 29(3) of the PAIA –
      • “If a requester has requested access in a particular form, access must, subject to section 28, be given in that form, unless to do so would –
      • interfere unreasonably with the effective administration of the public body concerned.
      • be detrimental to the preservation of the record; or
      • amount to an infringement of copyright not owned by the State or the public body concerned”.
    • The intellectual property of the information requested is owned by the University of KwaZulu-Natal (UKZN) as appointed by the HPCSA and providing access in a printed and electronic format would undermine the effectiveness of the examination system.
    • The Health Professions Council of South Africa (HPCSA) therefore is in a position to refuse access to the examination records in a form of printed and electronic format, however, the HPCSA is offering the parties supervised access to view the records at the appointed institution.
    • The university has a responsibility to protect the integrity of its examination system, as it is the case in all universities in the country.

Last Updated on 30 July 2024 by HPCSA Corporate Affairs