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Staff Analysis of the Redetermination Submitted by Australia and New Zealand

 
Prepared April 2016
 
Background
 
At its Spring 1995 meeting, the National Committee on Foreign Medical Education and Accreditation (NCFMEA) initially determined that the standards of the Australian Medical Council (AMC) used to evaluate medical schools in Australia and New Zealand were comparable to those used to evaluate medical schools in the United States. The AMC's standards were again found comparable in Spring 2001 and Fall 2007. At its Fall 2007 NCFMEA meeting, the Committee asked the country to provide a report on its accrediting activities for consideration at the Fall 2009 meeting. At the Fall 2009 meeting that report was accepted and the AMC was requested to submit an additional update for consideration at the Fall 2011 NCFMEA meeting. Following this meeting, (due to requested delays and adjustments in the review schedule) the country's redetermination has been postponed until this meeting. The redetermination of the country is the subject of this analysis.
 
Summary of Findings
 
Additional information is requested for the following questions. These issues are summarized below and discussed in detail under the Staff Analysis section.

-- NCFMEA may wish to ask for clarification on how it is determined that the objectives of the educational program will be formally adopted by the faculty, as a whole, and through its recognized governance process if the process is not formally in place. [Mission and Objectives, Question 3]

-- NCFMEA may wish to ask for the actual documentation of this job description to ensure compliance relative to this guideline. [Chief Academic Official, Question 1]

-- NCFMEA may wish to request clarification on the selection process of academic officials for the institution it serves. [Chief Academic Official, Question 2]

-- NCFMEA may wish to ask for clarification to verify that faculty are involved in the decision making relative to this guideline. [Faculty]

-- NCFMEA may wish to request a status update regarding this program and documentation that demonstrates how it reviews the curriculum to ensure that it is equivalent. [Remote Sites, Question 1]

-- NCFMEA may wish to request that the agency develop a policy for a minimum number of weeks instruction to ensure compliance under this guideline. [Program Length, Question 1]

-- NCFMEA may wish to request additional information from AMC regarding if it plans to adopt policy to specifically address this guideline. [Admissions, Recruiting, and Publications, Question 1]

-- NCFMEA may wish to request additional information from AMC regarding if they intend to develop standards for this criterion. [Admissions, Recruiting, and Publications, Question 2]

-- Department Staff request additional information be provided for the NCFMEA regarding whether the AMC has any plans to establish written policy to address this question. [Admissions, Recruiting, and Publications, Question 6]

-- NCFMEA may wish to ask the country for more details regarding the process for reviewing the size and qualifications of faculty members. [Faculty, Question 1]

-- NCFMEA may wish to request for AMC to provide updated information of the progress that is being made to address having a standard for preventing conflict of interest.
[Faculty, Question 2]

-- NCFMEA may wish to request the official copies of the documentation to verify the information in the affiliation agreement.
[Clinical Teaching Facilities, Question 1]

-- NCFMEA may wish to ask for clarification regarding how soon new sites are visited once it id determined that they are candidates for accreditation.
[Onsite Review, Question 3]

-- NCFMEA may wish to request the official copies of the documentation to verify the information in the affiliation agreement.
[Onsite Review, Question 4]

-- NCFMEA may wish to ask AMC to provide additional details about the appeals panel members to ensure qualifications and backgrounds are appropriate. [Qualifications of Evaluators, Decision-makers, Policy-makers]

-- AMC may wish to request additional documentation including an institutional application for substantive change and AMC’s review of this information.
[Substantive Change]

-- NCFMEA may wish to request have to develop a process for collection of signed statements from all of its decision makers and site visitors acknowledging that they are not acting in an unbiased way. It is Department Staff understanding that additional work is already being considered as it relates to this topic.
[Conflicts of Interest, Inconsistent Application of Standards, Question 1]

-- NCFMEA may wish to request documentation that demonstrates the institution’s goals for compliance under this guideline.
[Accrediting/Approval Decisions, Question 4]

 
Staff Analysis
 
PART 1: Entity Responsible for the Accreditation/Approval of Medical Schools
 
Approval of Medical Schools, Question 1
 
Country Narrative
A list of the 21 approved and accredited medical schools in Australia and New Zealand is available on the Australian Medical Council website: http://www.amc.org.au/accreditation/primary-medical-education/schools

The process for approval of medical schools in Australia and New Zealand has not changed since the AMC last reported to the NCFMEA in 2012.
In Australia and New Zealand, all medical programs are offered in universities.

In Australia, the operation of higher education providers including universities, is regulated by legislation. The Australian Government’s Tertiary Education Quality and Standards Agency (TEQSA www.teqsa.gov.au) is an independent authority established in 2011 to regulate and assure the quality of Australia’s higher education providers. TEQSA is responsible for the registration and re-registration of providers. It evaluates the performance of higher education providers against the Higher Education Standards Framework (Threshold Standards) 2011. Its role and authority is explained on its website and the legislation concerning its operation is also available.

TEQSA’s National Register of higher education providers is searchable and available at www.teqsa.gov.au/national-register. This shows that the nineteen Australian medical schools are all located in approved universities.

Under New Zealand legislation, Universities New Zealand – Te Pokai Tara has primary responsibility for quality assurance in the university sector. Its committee on University Academic Programmes undertakes its program approval and accreditation functions. The Academic Quality Agency for New Zealand Universities conducts regular institutional audits APPENDIX 1 outlines the process of Academic Quality Assurance of New Zealand Universities, including the role of its Committee on University Academic Programmes.

In both Australia and New Zealand, generally the governing body of each university approved to operate as a higher education provider can determine what programs the university offer, but medical programs and medical schools must go through additional approval processes.

In Australia, the National Government must approve programs that are seeking to take commonwealth supported student places through its Commonwealth Grant Scheme. Of the Australian medical schools, all but one (Bond University) offer commonwealth supported places and are approved through this process.
In Australia, medicine is a regulated health profession. The Health Practitioner Regulation National Law as in force in each Australian state and territory regulates the practice of medicine. The legislation is adopted in each state and territory, evidence of this adoption is available on the website www.ahpra.gov.au/About-AHPRA/What-we-do/Legislation.aspx. The National Law requires medical programs in Australia to be accredited by an accreditation entity (the Australian Medical Council) and approved by the regulation (licensing) body, the Medical Board of Australia. Section 6 of the National Law which deals with accreditation is at APPENDIX 2.

In New Zealand, the Medical Council of New Zealand registers medical practitioners and is responsible for standards of medical practice, medical education, and doctor conduct and competence. Its roles are defined under The Health Practitioners Competence Assurance Act 2003. Under section 12 of this legislation, the Medical Council of New Zealand is responsible for prescribing the qualifications for practice of medicine in New Zealand. An extract from The Health Practitioners Competence Assurance Act concerning these powers is at APPENDIX 3.

In both Australia and New Zealand, the Australian Medical Council assesses and accredits medical programs. The AMC makes accreditation decisions which are referred to the Medical Board of Australia and the Medical Council of New Zealand. As required under their legislation, these bodies make the decision to approve the qualification and the medical school and university offering the program.

Documents:
APPENDIX 1: Academic Quality Assurance of New Zealand Universities
APPENDIX 2: Extract from the Health Practitioner Regulation National Law: Part 6 Accreditation.
APPENDIX 3: Extract from the New Zealand Health Practitioners Competence Assurance Act

Links to relevant websites:
Australian Medical Council: list of accredited medical programs http://www.amc.org.au/accreditation/primary-medical-education/schools
Tertiary Education Quality and Standard Agency www.teqsa.gov.au
Medical Board of Australia - the national registration board www.medicalboard.gov.au
Medical Council of New Zealand NZ www.mcnz.org.au
 
Analyst Remarks to Narrative
Based on legislation, the country states in its narrative that the Government's Tertiary Education Quality and Standards Agency (TEQSA) have the authority and responsibility to regulate and assure the quality of Australia's higher education providers.

In Australia, the Health Practitioner Regulation National Law is the countries legal authority for the practice of medicine. The National Law requires medical programs in Australia to be accredited by an accreditation entity (in this case the Australian Medical Council or AMC) and approved by the regulation (licensing) body, the Medical Board of Australia. In New Zealand, the Health Practitioners Competence Assurance Act of 2003 establishes the qualifications and requirements for medical practice for the country.. The country states in its narrative that, in both Australia and New Zealand, the Australian Medical Council assesses and accredits medical programs. The AMC makes accreditation decisions which are referred to the Medical Board of Australia and the Medical Council of New Zealand.

The agency has included documentation (appendix 2) the law that requires Australia and New Zealand to have a designated authority for medical programs. While not including in this section, there is additional information in another section (Part 1, Accreditation of Medical Schools) guideline that contains an MOU agreement which identifies the Australian Medical Council (AMC) as the approved entity. The agency also provided a copy of the MOU (suggested in section 44 of the Health Practitioner Regulation National Law) between the National agency and National Board that demonstrates the AMC's authority in these countries.
 
Approval of Medical Schools, Question 2
 
Country Narrative
The entities responsible for the monitoring and continued certification of the medical schools are those detailed at Question 1i (above), as responsible for approving the operation of the medical school.
Documents:
Documentation of functional authority of these entities is provided under 1 (a)

Documents:

APPENDIX 2: Extract from the Health Practitioner Regulation National Law: Part 6 Accreditation.
APPENDIX 3: Extract from the New Zealand Health Practitioners Competence Assurance Act
 
Analyst Remarks to Narrative
The country has provided documentation of the AMC's monitoring and continued accreditation role in ensuring quality in academic programs. Specifically, this process is explained in the Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015. This document explains that the AMC conducts onsite inspection visits and requires that institutions conduct self-assessments and set goals/objectives relative to their program of study. Once an institution has accredited an education provider and its program of study, the AMC states that they monitor to ensure continuation of adherence for meeting AMC's standards.
 
Approval of Medical Schools, Question 3
 
Country Narrative
The bodies described in response to question 1a (response 1) as responsible for approval of medical schools are also involved in decisions that would lead to removal of a medical school’s capacity to operate.

Higher education providers in Australia must have their registration reviewed regularly by the Tertiary Education Quality and Standards Agency. If it was not operating in accordance with the relevant national standards, a university in which a medical school operates may have its continued registration as a higher education provider rejected by the relevant national higher education standards body.

In Australia, under the Health Practitioner Regulation National Law (section 49 and 51), the Medical Board of Australia may refuse to approve a medical program as providing a qualification for the purposes of the National Law.

In New Zealand, under The Health Practitioners Competence Assurance Act 2003 (section 14) the Medical Council of new Zealand may amend, revoke, or replace the list prescribing the qualifications for practice of medicine in New Zealand.

The Australian Medical Council, is the accreditation authority for medicine. Its accreditation procedures allow it to withdraw or revoke accreditation
The AMC may make a decision to withdraw or revoke accreditation in accordance with the AMC Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 (at APPENDIX 4). Please see the Procedures at section 3.3.10 ‘Decision on accreditation’ which states:

Accreditation may be withdrawn where the education provider has not satisfied the AMC that the complete program is or can be implemented and delivered at a level consistent with the accreditation standards. The AMC would take such action after detailed consideration of the impact on the healthcare system and on individuals of withdrawal of accreditation and of other avenues for correcting deficiencies.

If the AMC withdraws accreditation, it will give the education provider written notice of the decision, and its reasons; and the procedures available for review of the decision within the AMC.

An organisation that has its accreditation revoked may re-apply for accreditation. It must first satisfy the AMC that it has the capacity to deliver a program of study that meets the accreditation standards by completing a Stage 1 accreditation submission.

See also section 4.4 concerning decisions following ‘Unsatisfactory progress procedures’. These describe the option for withdrawal of accreditation after an unsatisfactory progress review as:

The team reports to the Medical School Accreditation Committee, which may recommend to the AMC Directors:
...
(iii) that the concerns are not being addressed and/or are unlikely to be addressed within a reasonable timeframe and the education provider and its program do not satisfy the accreditation standards. In this case the AMC will revoke the accreditation.


The AMC reports any changes to the accreditation status of programs to the Medical Board of Australia and to the Medical Council of New Zealand. Under the National Law which operates in Australia, the Medical Board of Australia is unable to approve a program that is not accredited.

Documents:
APPENDIX 4: Procedures for the Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 section 3.3.1. Decision on accreditation; and section 4.4 Unsatisfactory Progress Procedures
See also:
APPENDIX 2 extract from the Health Practitioner Regulation National Law; and APPENDIX 3 extract from the New Zealand Health Practitioners Competence Assurance Act
APPENDIX 3: Extract from the New Zealand Health Practitioners Competence Assurance Act
 
Analyst Remarks to Narrative
In Australia, the Health Practitioner Regulation National Law is the specific regulator for the practice of medicine. In New Zealand, the Health Practitioners Competence Assurance Act of 2003 regulates the medical practice qualifications for the country. In both Australia and New Zealand, the legislation dictates the authority responsible for accrediting entities is also the responsible party for closing or refusing to approve a medical school. In these countries, the Australian Medical Council has been given the authority to carry out these decisions. The AMC makes accreditation decisions under section 3.3.10 of the agency's procedures titled 'Decisions on accreditation.'
 
Accreditation of Medical Schools
 
Country Narrative
In Australia, the Australian Medical Council (www.amc.org.au) remains the one entity that accredits medical programs, and its status has not changed since the AMC last reported to the NCFMEA in 2012. The AMC also remains the accreditation body for New Zealand, through an agreement with the Medical Council of New Zealand.

The AMC is established as an independent corporation in Australia. The AMC’s functions under its Constitution (APPENDIX 5) include:
• to act as an external accreditation entity for the purposes of the Health Practitioner Regulation National Law;
• to 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;
• to assess programs of study based predominantly in Australia and New Zealand leading to general or specialist registration of the graduates of those programs to practise medicine in Australia to determine whether the programs meet approved accreditation standards, and to make recommendations for improvement of those programs;
• to assess education providers based predominantly in Australia and New Zealand that provide programs of study leading to general or specialist registration of the graduates of those programs to practice medicine in Australia, to determine whether the providers meet approved accreditation standards.

The AMC reports to the Medical Board of Australia on how it conducts its accreditation functions. The Health Practitioner Regulation National Law requires that programs of study for regulated health professions be accredited (refer to APPENDIX 2). Medicine is a regulated health profession. The National Law legislates the process for appointment of an accreditation authority and for reporting by that authority to the national regulation board for the profession, the Medical Board of Australia. Confirmation of the AMC’s appointment as the accreditation authority for medicine is at APPENDIX 6.

In New Zealand, the AMC accredits medical programs so that the programs can be approved in Australia and graduates of these programs are able to be registered as medical practitioners in Australia. This process has not changed since the AMC last reported to the NCFMEA. The AMC also accredits New Zealand medical programs for New Zealand. The AMC has a Memorandum of Understanding with the Medical Council of New Zealand (refer to APPENDIX 7) under which the two bodies agree to work together:
• to assess programs of study based mainly in Australia and New Zealand leading to general or specialist registration of the graduates of those programs to practise medicine in Australia and New Zealand to determine whether the programs meet approved accreditation standards, and to make recommendations for improvement of those programs;
• to assess education providers based mainly in Australia and New Zealand that provide programs of study leading to general or specialist registration of the graduates of those programs to practise medicine in Australia and New Zealand, to determine whether the providers meet approved accreditation standards; and
• to collaborate in other areas of mutual interest relating to assessment and standards of medical education and training.

Documents:
APPENDIX 2 - Extract from the Health Practitioner Regulation National Law: Part 6 Accreditation.
APPENDIX 5 – Constitution of the Australian Medical Council
APPENDIX 6 - Letter from the Medical Board of Australia to the AMC concerning its most recent reappointment as the accreditation authority for medicine
APPENDIX 7 – Australian Medical Council and Medical Council of New Zealand Memorandum of Understanding

Relevant website: Australian Medical Council - description of accreditation functions: http://www.amc.org.au/accreditation/primary-medical-education
 
Analyst Remarks to Narrative
The country indicates in its narrative that the AMC has the authority and responsibility for evaluating the quality of medical education. The country provided documentation that includes the governing legislation, a copy of its constitution, a written letter demonstrating reappointment of the authority of the AMC through 2018, and a copy of the MOU. While not specifically included in this narrative section, the country has provided documentation (appendix 6) that it relies on a defined set of AMC standards when it conducts its accreditation review of the medical school.
 
Accreditation of Medical Schools, Question 2
 
Country Narrative
The entities identified in (a) and (b) above have discrete responsibilities in setting standards for higher education and medical education and for assessing education providers against those standards.

The processes for oversight of the quality of higher education providers in Australia and New Zealand are the responsibility of authorities which operate under a governmental education portfolio or education departments in Australia and New Zealand: the Australian Government’s Tertiary Education Quality and Standards Agency (TEQSA) (www.teqsa.gov.au) in Australia, and Universities New Zealand – Te Pokai Tara in New Zealand.

The accreditation of medical programs offered in universities is part of the government’s health portfolio and operates under separate legislation. The system for establishment and oversight of quality medical education programs is strongly developed in the heath portfolio and backed by legislation. In Australia, the Health Practitioner Regulation National Law gives legal authority to the accreditation authority (the Australia Medical Council) to assess and accredit medical programs, and to monitor accredited programs to ensure they continue to meet standards (see APPENDIX 2 Extract from the National Law section 6).
In New Zealand, the system for quality assurance of medical programs is the responsibility of the Medical Council of New Zealand under the The Health Practitioners Competence Assurance Act 2003 (APPENDIX 3). While the Australian Medical Council does not have a legal relationship with the Medical Council of New Zealand, the agreement between the two councils is strong, and the joint accreditation process has worked smoothly since 1992. The Medical Council of New Zealand is represented on AMC accreditation committees to ensure that the system of accreditation works well.

There is no formal legal link between the system for quality assurance of medical programs and decision-making made about quality assurance of the universities in which the programs are delivered, but there are a number of other links to share information between higher education quality assurance processes and medical program accreditation processes and to minimise duplication of accreditation roles. The Australian Government’s Tertiary Education Quality and Standards Agency has developed a statement concerning its relationships with professional bodies such as the Australian Medical Council, and the Tertiary Education Quality and Standards Agency and the AMC have signed a memorandum of understanding to facilitate information sharing. Evidence of this approach is provided at www.teqsa.gov.au/regulatory-approach/engagement-with-professional-bodies.

This webpage states:

TEQSA and professional bodies with links to the higher education sector have a mutual interest in maintaining and improving quality in the provision of higher education in Australia.

TEQSA has agreed that the following principles should guide its engagement with professional bodies:

- the development of a complementary approach to course accreditation processes and requirements
- the use of professional bodies as a source of expert advice
- the sharing of information with professional bodies to inform TEQSA’s regulatory activity and to protect the interests of students and the higher education sector;
- encouraging alignment of professional outcomes with learning outcome requirements of the Australian Qualifications Framework (AQF); and
- fostering communication between TEQSA and professional bodies regarding each other’s respective roles.

....

TEQSA has signed Memorandums of Understanding (MOUs) with the following organisations, to facilitate the sharing of information and reduce regulatory burden on higher education providers:

Australian Medical Council (23 September 2015)

Samples of letters communicating an AMC accreditation decision to the Medical Board of Australia and to the Medical Council of New Zealand are provided at APPENDICES 8 and 9 respectively.

Documents:

APPENDIX 2 - Extract from the Health Practitioner Regulation National Law: Part 6 Accreditation
APPENDIX 3 - Extract from the New Zealand Health Practitioners Competence Assurance Act
APPENDIX 8: Sample AMC letter to Medical Board of Australia reporting on an accreditation decision
APPENDIX 9: Sample AMC letter to Medical Council of New Zealand reporting on an accreditation decision
 
Analyst Remarks to Narrative
Based on legislation, the country states in its narrative that the Government's Tertiary Education Quality and Standards Agency (TEQSA) have the authority and responsibility to regulate and assure the quality of Australia's higher education providers. For the Universities in New Zealand -the Te Pokai Tara has similar authority.

In Australia, the Health Practitioner Regulation National Law is the specific regulator for the practice of medicine. The National Law requires medical programs in Australia to be accredited by an accreditation entity (in this case the Australian Medical Council or AMC) and approved by the regulation (licensing) body, the Medical Board of Australia. In New Zealand, the Health Practitioners Competence Assurance Act 2003 regulates the medical practice qualifications for the country. In both Australia and New Zealand, the legislation dictates the authority responsible for accrediting entities is also the responsible party for closing or refusing to approve a medical school. In these countries, the Australian Medical Council has been given the authority to carry out these decisions.

The Australian Government's Tertiary Education Quality and Standards Agency has developed a MOU regarding its professional relationships and information sharing with other entities such as the AMC. The country has demonstrated this process through including sample letters that report accreditation decisions. While AMC serves as the official entity for the accreditation decisions, the other groups serve an oversight role in which they are made aware of decisions.
 
Part 2: Accreditation/Approval Standards
 
Mission and Objectives, Question 1
 
Country Narrative
Yes, the AMC requires that medical schools have an educational mission (purpose) that serves the public interest.

The AMC assesses and monitors medical schools against the approved Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (APPENDIX 10). Medical schools provide an accreditation submission to the AMC that addresses the accreditation standards. Where the AMC finds that the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met to the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set.

Standard 2.1 addresses this requirement:
‘2.1 Purpose
2.1.1 The medical education provider has defined its purpose, which includes learning, teaching, research, societal and community responsibilities.
2.1.2 The medical education provider’s purpose addresses Aboriginal and Torres Strait Islander peoples and/or Maori and their health.
2.1.4 The medical education provider relates its teaching, service and research activities to the health care needs of the communities it serves.’

Examples of conditions set by the AMC against Standard 2.1 from the period 2010 – 2015 are provided in APPENDIX 11 as evidence that the AMC assesses against these standards.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (Standard 2)
APPENDIX 11: List of accreditation conditions 2010 to 2015
 
Analyst Remarks to Narrative
The county states in its narrative that the AMC has an educational mission that supports the public interest. The AMC's standards stipulate that the medical schools purpose is for serving the community. This information is included in Standard 2.1 (Appendix 10).

In addition, the AMC has included documentation titled Accreditation Conditions from Medical School Assessments (July 2010 to December 2015). This documentation demonstrates that the agency has continued to evaluate its standards relative to the requirements stipulated in Standard 2.1.
 
Mission and Objectives, Question 2
 
Country Narrative
The AMC assesses and monitors medical schools against the approved Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (APPENDIX 10).
Medical schools provide an accreditation submission to the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set.
The conditions set by the AMC for this standard are provided in APPENDIX 11 as evidence that the AMC assesses against these standards.
The following standards are relevant:

Medical school faculty define the objectives
1.1.2 The governance structures set out, for each committee, the composition, terms of reference, powers and reporting relationships, and allow relevant groups to be represented in decision-making.
1.1.3 The medical education provider consults relevant groups on key issues relating to its purpose, the curriculum, graduate outcomes and governance.
1.3.1 The medical education provider has a committee or similar entity with the responsibility, authority and capacity to plan, implement and review the curriculum to achieve the objectives of the medical program.
The glossary to the standards indicates:
‘Relevant groups involved in decision making includes include internal stakeholders (which is defined as stakeholders internal to the education provider such as medical students and those contributing to the design and delivery of training and education functions including, but not limited to, program directors, academic staff, supervisors and committees), and external stakeholders who contribute to the design and delivery of training and education.’

Objectives serve as the guide for establishing curriculum content
2.2.1 The medical education provider has defined graduate outcomes consistent with the AMC Graduate Outcome Statements and has related them to its purpose.
3.2 The curriculum content ensures that graduates can demonstrate all of the specified AMC graduate outcomes.
3.2.1 Science and Scholarship: The medical graduate as scientist and scholar
The curriculum includes the scientific foundations of medicine to equip graduates for evidence-based practice and the scholarly development of medical knowledge.
3.2.2 Clinical Practice: The medical graduate as practitioner
The curriculum contains the foundation communication, clinical, diagnostic, management and procedural skills to enable graduates to assume responsibility for safe patient care at entry to the profession.
3.2.3 Health & Society: The medical graduate as a health advocate
The curriculum prepares graduates to protect and advance the health and wellbeing of individuals, communities and populations.
3.2.4 Professionalism and Leadership: The medical graduate as a professional and leader
The curriculum ensures graduates are effectively prepared for their roles as professionals and leaders.


Objectives serve as the basis for evaluating the effectiveness of the program
6.2.1 The medical education provider analyses the performance of cohorts of students and graduates in relation to the outcomes of the medical program.
6.2.2 The medical education provider evaluates the outcomes of the medical program.
6.3.2 The medical education provider makes evaluation results available to stakeholders with an interest in graduate outcomes, and considers their views in continuous renewal of the medical program.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (Glossary and Standards 1, 2, 3 and 6)
APPENDIX 11: List of accreditation conditions 2010 to 2015
 
Analyst Remarks to Narrative
The country indicates in its narrative, that the AMC has set standards for medical schools titled Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. The agency's standards have objectives that are set for medical school faculty, curriculum content, and for evaluating effectiveness of the program. The AMC also states that they review these standards annually through reporting mechanisms. However, the agency did not provide a copy of an example annual report.

Additional Information Requested:
The AMC has policies relative to this question, but has not provided documentation to demonstrate the application of its policies relative to setting standards for curriculum content and evaluating effectiveness. Department staff request the agency provide documentation such as a copy of the annual report or an onsite evaluation team report that demonstrates the application of its policy relative to this guideline.
 
Country Response
The sample reaccreditation report provided at Appendix 24 shows the assessment of a medical school program against these standards. In particular section 2 shows an assessment of the medical program's objectives, section 3 describes how the objectives link to the curriculum and section 6 details evaluation of the program and objectives. The executive summary of the report lists the conditions placed on the accreditation, and any commendations for good practice as well as quality improvement recommendations made to the medical school.

The list of conditions set on medical schools (Appendix 11) shows all the areas where the AMC has set a condition on a medical school's accreditation for non compliance. As the sample accreditation report provided at Appendix 24 shows, conditions are set as part of the accreditation report. The list at APPENDIX 11 shows that the AMC has set conditions relating to these standards in several instances in the period 2010 to 2015:

Conditions listed under Standard 2.2 shows that the AMC has required medical schools to align their graduate outcomes to those of the AMC, and conditions set under Standard 3.2 shows that the AMC has required medical schools to map their program content and graduate outcomes statements, for example Condition 14 under
3.2 requires that medical school to Provide evidence the MD course structure, including the mapping of Phase 2 to the Graduate Outcome Statements, is completed for the full MD program (3.2).
15
 
Analyst Remarks to Response
AMC has set standards for medical schools that comply with their Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. The agency states that they review these standards annually through reporting mechanisms. The agency has included a site visit report that demonstrates how they review for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Mission and Objectives, Question 3
 
Country Narrative
The AMC does not have a standard requiring that the education program be formally adopted by the faculty but it would expect this as part of its assessment against the following accreditation standards:

1.1.3 The medical education provider consults relevant groups on key issues relating to its purpose, the curriculum, graduate outcomes and governance.
1.3.1 The medical education provider has a committee or similar entity with the responsibility, authority and capacity to plan, implement and review the curriculum to achieve the objectives of the medical program.

The glossary to the standards indicates:
‘Relevant groups involved in decision making includes include internal stakeholders (which is defined as stakeholders internal to the education provider such as medical students and those contributing to the design and delivery of training and education functions including, but not limited to, program directors, academic staff, supervisors and committees), and external stakeholders who contribute to the design and delivery of training and education.’

The AMC does have specific requirements when a medical school makes a major change to its medical program (and a major change includes a change to the program objectives). In the submission concerning the major change, it requires evidence of engagement of stakeholders. As noted earlier, academic staff are defined in the AMC glossary to the accreditation standards as part of the internal stakeholders. When the AMC assesses major changes to programs, evidence of academic faculty support and engagement in the changes is required. For example, the AMC Accreditation Submission Guide Major Change to an Established Program (APPENDIX 12) requires the medical school to:

“Describe any changes to the purpose since the last AMC accreditation and the contribution of academic staff and students, the university, government agencies, the medical profession, health service providers, bodies involved with postgraduate medical training, health consumer organisations and the community, to the development of the education provider’s purpose and objectives.”

Concerning formal adoption of the objectives through the governance processes, accreditation Standard 1.3.1, quoted earlier in this section is relevant.

Documents:

APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (Standard 6)
APPENDIX 12: Accreditation Submission Guide Major Change to an Established Medical Program (see Standard 2)
 
Analyst Remarks to Narrative
The AMC states that it does not have standards requiring that the education program be formally adopted by the faculty, While the agency does indicate that the information in its educational program has consultant input from relevant groups and a committee that reviews this information, there is no confirmation that either of these groups includes faculty members. The specific guidance in this section requires that the education curriculum must be adopted by the faculty as a whole. Since the agency does not have a policy regarding this process, Department Staff is unable to determine comparability in this section.

Additional Information Requested:
NCFMEA may wish to request clarification regarding the faculty involvement as it relates to establishing objectives of the education program.
 
Country Response
The sample accreditation report at Appendix 24, as well as the extract from the accreditation report at Appendix 16 show the governance structures for two medical programs. These indicate that a mix of program leaders, faculty staff, students and external stakeholders sit on the committees responsible for design, management and evaluation of the programs.

The glossary to the Standards for Assessment of Primary Medical Programs by the AMC (Appendix 10) defines stakeholders. Academic staff are included in the definition of internal stakeholders. Where standards require stakeholder engagement, this definition requires the medical school to have included academic staff in the engagement processes.
 
Analyst Remarks to Response
AMC indicates that the medical schools currently do not have a process in which the objectives of the educational program are formally adopted by the faculty members. However, AMC has provided documentation (exhibit 12) that indicates that the information in its educational program has consultant input from relevant groups and a committee that reviews this information, including academic staff (faculty).

NCFMEA may wish to ask for clarification on how it is determined that the objectives of the educational program will be formally adopted by the faculty, as a whole, and through its recognized governance process if the process is not formally in place.
 
Staff Conclusion: Additional Information requested
 
Mission and Objectives, Question 4
 
Country Narrative
The AMC assesses and monitors medical schools against the approved Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (APPENDIX 10). Medical schools provide an accreditation submission to the AMC that addresses the accreditation standards. Where the accreditation standards are not met and graduate outcomes not in alignment with the AMC graduate outcome statements, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met to the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set.

The conditions set by the AMC for this standard are provided in an appendix as evidence that the AMC assesses against these standards (APPENDIX 11).

The following are relevant:
The AMC defines AMC Graduate Outcome Statements (see pages 1 to 4 of the Standards).
The AMC Graduate Outcome Statements are grouped in four domains to provide a framework of the requirements that medical students must demonstrate at graduation. The Australian Medical Council standards require the medical education provider to demonstrate how their medical program enables their graduates to meet the outcomes. The four domains are:
1. Science and Scholarship: the medical graduate as scientist and scholar
2. Clinical Practice: the medical graduate as practitioner
3. Health and Society: the medical graduate as a health advocate
4. Professionalism and Leadership: the medical graduate as a professional and leader

The following standards relate to an outcomes-based educational program:

2.2.1 The medical education provider has defined graduate outcomes consistent with the AMC Graduate Outcome Statements and has related them to its purpose.

2.2.2 The medical program outcomes are consistent with the AMC’s goal for medical education, to develop junior doctors who are competent to practise safely and effectively under supervision as interns in Australia or New Zealand, and who have an appropriate foundation for lifelong learning and for further training in any branch of medicine.
3.2 The curriculum content ensures that graduates can demonstrate all of the specified AMC graduate outcomes.
4.1 The medical education provider employs a range of learning and teaching methods to meet the outcomes of the medical program.
5.2.1 The medical education provider assesses students throughout the medical program, using fit for purpose assessment methods and formats to assess the intended learning outcomes.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of accreditation conditions 2010 to 2015
 
Analyst Remarks to Narrative
The county indicates in its narrative that the medical school must follow the AMC’s educational program standards for medical schools( see appendix 10) Specifically, the AMC’s policies fall into four domains that it uses to establish outcomes for the students once they graduate from medical school. The AMC also has standards that are used for evaluating outcomes of the medical schools. The agency indicates that they monitor this information through annual reports, however documentation was not included that demonstrates this review.

Additional Information Requested:
NCFMEA may wish to request documentation demonstrating ACM’s review and assessment of an institution for compliance relative to this guideline.
 
Country Response
The list of conditions set on medical schools (Appendix 11) shows all the areas where the AMC has set a condition on a medical school's accreditation for non compliance.

The list at APPENDIX 11 shows that the AMC has set conditions relating to these standards in the period 2010 to 2015. Specifically it has set conditions concerning the content of medical school outcomes statements (Standard 2.2), mapping of curriculum and outcomes statement (conditions set at standard 3.2) and alignment of outcomes statements and assessment of student performance (see conditions 14 and 16) at standard 5.1.

Documentation is included relating to the review of annual progress reports. The progress report guide at Appendix 27 shows the AMC's instructions to medical schools about their annual progress reports. A new Appendix, (Appendix 37) shows an extract from an agenda of a meeting of the Medical School Accreditation Committee, which shows the consideration of progress reports at a meeting. Page 46 of the sample Accreditation Report shows an example of an assessment of a medical program's compliance with the requirements that assessment is mapped to the program's graduate learning outcomes.
 
Analyst Remarks to Response
The AMC indicates that the medical school must follow the educational program standards for medical schools that comply with their standards (exhibit 10). The agency indicates that they monitor this information through annual reports and has now provided documentation of the guide that is given to institutions for completing this reporting (exhibit 17). The agency has also included documentation (appendix 37) that has meeting minutes demonstrating a review of information relative to this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Mission and Objectives, Question 5
 
Country Narrative
The Australian Medical Council operates under the Health Practitioner Regulation National Law. This defines an accreditation standard, for a health profession, as a standard used to assess whether a program of study, and the education provider that provides the program of study,
provide persons who complete the program with the knowledge, skills and professional attributes necessary to practise the profession in Australia. This means that in setting accreditation standards, the Australian Medical Council must relate the standards to the students eventual role as medical practitioners.

The approved Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012 also include specifically require that the medical programs prepare graduates for competent and safe medical practice. The following standard is relevant:

2.2.2 The medical program outcomes are consistent with the AMC’s goal for medical education, to develop junior doctors who are competent to practise safely and effectively under supervision as interns in Australia or New Zealand, and who have an appropriate foundation for lifelong learning and for further training in any branch of medicine.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (Standard 2)
 
Analyst Remarks to Narrative
The Health Practitioner Regulation National Law requires that students who are in medical fields develop the professional attributes needed to work as a professional in the medical field. In addition, AMC standards under section 2.2.2, requires that training and lifelong learning of its students occurs. While the agency has policies that address this guideline, they have not demonstrated the application of this policy.

Additional Information Requested:
NCFMEA may wish to request documentation demonstrating review and assessment of an institution for compliance relative to this guideline.
 
Country Response
Section 2 of the sample reaccreditation report provided at Appendix 24 shows an AMC assessment of a medical school's purpose against this requirement.
 
Analyst Remarks to Response
AMC has set standards for medical schools that comply with their Standards (appendix 10) . The agency states that they review these standards annually through reporting mechanisms. The agency has included a site visit report that demonstrates how they review for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Governance, Question 1
 
Country Narrative
Yes. Medical schools and their higher education providers (universities) must be legally authorised to provide a program of medical education. As stated in the answers to Section 1, there is a system of regulation of higher education providers in Australia and New Zealand, and additional government processes for approval to offer medical program places. This has not changed since the AMC’s last NCFMEA report.

The Australian Medical Council, as the accreditation body, requires evidence that the medical school and its medical program have the support of the relevant state/territory and federal governments. This requirement is found in the AMC Procedures for Assessment and Accreditation of Medical Schools by the AMC 2015 (APPENDIX 4) at section 3.2.1, First stage assessment of a new medical program:

Institutions contemplating the establishment of a primary medical program should conduct independent negotiations with the appropriate state/territory and national authorities concerning student places and clinical facilities. If a decision is made by the relevant authorities to support the establishment of a new medical program, the AMC undertakes the assessment against the approved accreditation standards.

Universities require the support and authorisation of their state/territory health department in order to provide clinical placements for medical students in the local public health/hospital system. These agreements are negotiated individually between the university and the appropriate government health department.
When a new medical school is planned, the Australian Medical Council requires the university to provide written authorities from the relevant federal and state/territory health departments to support the initial case for assessment of the proposed medical program. AMC assessment teams meet representatives of these health departments when assessing medical programs.

An example of this is the proposed Curtin Medical School, Curtin University in Western Australia. The University first contacted the AMC regarding its intention to commence a new medical school three years before it received government support, and as such, the AMC did not consider its Stage 1 proposal for a new medical school and program until it had evidence of state and federal government support. As evidence, please see APPENDIX 13 for the AMC’s letter and APPENDIX 14 Stage 1 Guide provided to Curtin Medical School in 2015 following confirmation of government support.

Documents:
APPENDIX 4: AMC Procedures for Assessment and Accreditation of Medical Schools by the AMC 2015
APPENDIX 13: Letter to new medical school approvals required to offer program
APPENDIX 14: New medical school stage 1 submission guide
 
Analyst Remarks to Narrative
The country indicates in its narrative, that the AMC requires medical schools to be legally authorized for medical education by the appropriate state/territory and national authorities. Section 3.2.1 of AMC standards (appendix 4) includes processes for new medical schools that require this authority. Additionally, the country provided documentation from a proposed medical school in Western Australia, demonstrating that the agency requires government approval of a medical school before it allows the institution to move forward in the AMC process. The agency states that there have not been any changes to this process since its last review before NCFMEA.
 
Governance, Question 2
 
Country Narrative
As noted above (Part 1 section1), all medical schools in Australia and New Zealand are located in an approved university. .The medical schools are responsible to the governing body of their university, report to the national higher education quality assurance agency and through the legislation governing the university, the state and national government. These processes have not changes since the AMC last reported to the NCFMEA, although the names of the higher education quality assurance agencies have changed (these are listed in Part 1).

As an example of these requirements, the AMC cites the National Higher Education Standards Framework, which is provided as APPENDIX 15.
These standards require:

1.3 The higher education provider takes responsibility for the quality of every course of study leading to the higher education award it is accredited to award.

Documents:
APPENDIX 15: Higher Education Standards Framework (Threshold Standards) 2011
 
Analyst Remarks to Narrative
As stated in the country's narrative, the medical schools are accountable to the external and independent body, the AMC. AMC standards require compliance and assurance of educational quality. The agency has provided documentation demonstrating the application of its standards relative to this question in Appendix 14. Additionally, the country states the medical schools have responsibility for accountability to their own governing bodies, to the national higher education quality assurance agency and other stakeholders in the government.
 
Administrative Personnel and Authority, Question 1
 
Country Narrative
The AMC assesses and monitors medical schools against the approved Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (APPENDIX 10). Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set.
The conditions set by the AMC for this standard are provided in APPENDIX 11 as evidence that the AMC assesses against these standards.

The relevant accreditation standards which describe the requirements for various aspects of administration, including governance, leadership, budget, and interaction with the health sector and with external stakeholders are listed below.

1.1.1 The medical education provider’s governance structures and functions are defined and understood by those delivering the medical program, as relevant to each position. The definition encompasses the provider’s relationships with internal units such as campuses and clinical schools and with the higher education institution.
1.1.2 The governance structures set out, for each committee, the composition, terms of reference, powers and reporting relationships, and allow relevant groups to be represented in decision-making.
1.5.1 The medical education provider has an identified line of responsibility and authority for the medical program.
1.5.2 The medical education provider has autonomy to direct resources in order to achieve its purpose and the objectives of the medical program.
1.5.3 The medical education provider has the financial resources and financial management capacity to sustain its medical program.
1.8.1 The medical education provider has the staff necessary to deliver the medical program.
1.8.2 The medical education provider has an appropriate profile of administrative and technical staff to support the implementation of the medical program and other activities, and to manage and deploy its resources.

The governance structure and management of medical schools in Australia and New Zealand are considered in detail by the AMC during the accreditation process. This requires examination of all structures and functions including the school’s relationships with its campuses and clinical schools, and within the university. As an example, an extract from an accreditation report, showing the assessment of a medical school’s structures is provided as APPENDIX 16.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
APPENDIX 16: Example – Extract from AMC accreditation report showing assessment of the medical school’s administration and governance
 
Analyst Remarks to Narrative
The AMC’s Standards (see appendix 10) AMC's standards require its medical institutions to have "governance structures and functions that are defined and understood by those delivering the medical program. The ACM’s standards also require that the institution have the staff and faculty necessary to deliver the medical program." The agency has included an extract of one of its onsite visits of an institution that demonstrates the application of its standards at the institution.
 
Administrative Personnel and Authority, Question 2
 
Country Narrative
The AMC assesses and monitors medical schools against the approved Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 9 (APPENDIX 10). Medical schools provide an accreditation submission to the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met to the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set. The conditions set by the AMC for this standard are provided in an appendix as evidence that the AMC assesses against these standards.

The following standards are relevant:
1.2.1 The medical education provider has autonomy to design and develop the medical program.
1.2.2 The responsibilities of the academic head of the medical school for the medical program are clearly stated.
A key initial component of the accreditation site visit includes discussions with the chief academic officer of the medical school (the dean) to establish that there is authority and capacity to implement the program. There are also discussions about budgeting in the medical school and lines of authority between the dean of the medical school and the central university to establish that there is appropriate structural support to deliver the medical program. AMC accreditation teams meet senior staff of the university in which the medical school is located to give them feedback on their findings concerning the resources and authority to support delivery of the program, and to validate the information received via the dean with the university senior officers.

Where the AMC sets accreditation conditions in relation to authority of the chief academic officer of the medical school, it usually sets a short timeframe for these to be addressed, as they are critical to the success of the medical program.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
 
Analyst Remarks to Narrative
The country discusses in its narrative the responsibility of the Chief Academic Officer (CAO) of the medical school. The AMC has a standard that states the responsibilities of the academic head of the medical school be clearly stated by the institution. The agency also explains that they verify the authority of the CAO during the site visit, ongoing budget conversations with the CAO and other appropriate parties, and conversations with senior staff. However, while the AMC explained its verification actions, it has not included documentary evidence of these reviews or conversations.

Additional Information Requested:
NCFMEA may wish to request documentation that shows the onsite inspection team review of the institution's compliance under this guideline.
 
Country Response
The list of conditions set on medical schools (Appendix 11) shows all the areas where the AMC has set a condition on a medical school's accreditation for non compliance. As the sample accreditation report provided at Appendix 24 shows, conditions are set as part of the accreditation report. The list at APPENDIX 11 shows that the AMC has set one condition relating to these standards in in the period 2010 to 2015:

This was a requirement that the school provide evidence of academic leadership with sufficient autonomy and capacity to deliver the medical program: either a new Dean, in post by 1 February 2011 or alternative effective leadership, supported by effective senior clinical leaders.

The sample reaccreditation report, Appendix 24, shows a team's assessment of the reporting lines in a medical school. The report on the chief academic officer (dean)'s reporting relationships.
 
Analyst Remarks to Response
AMC has a standard that states the responsibilities of the academic head of the medical school for the medical program are clearly stated. The terminology that is used in this instance is Dean instead of Chief Academic Officer. AMC has included documentation of an accreditation report (exhibit 12) that demonstrates how the site team reviews for compliance relative to this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Administrative Personnel and Authority, Question 3
 
Country Narrative
The AMC assesses and monitors medical schools against the approved Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (APPENDIX 10). Medical schools provide an accreditation submission to the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met to the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set. The conditions set by the AMC for this standard are provided in an appendix as evidence that the AMC assesses against these standards (APPENDIX 11).

The following standards are relevant:
1.2.1 The medical education provider has autonomy to design and develop the medical program.
1.5.2 The medical education provider has autonomy to direct resources in order to achieve its purpose and the objectives of the medical program.
1.8.1 The medical education provider has the staff necessary to deliver the medical program.

The format of AMC accreditation assessment includes searching review of the medical school’s operating structures, policies and procedures against the accreditation standards, as shown by the information collected in the appended Reaccreditation Submission Guide 2016 (see section 1 of the Guide) (APPENDIX 17). The AMC has provided an extract from a recent accreditation report, which shows the discussion in that report concerning the authority and resources available to key units and academic staff in the medical school to deliver the medical program (APPENDIX 16).

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
APPENDIX 16: Example – Extract from AMC accreditation report showing assessment of the medical school’s administration and governance
APPENDIX 17: Reaccreditation Submission Guide 2016
 
Analyst Remarks to Narrative
As stated in the country's narrative, AMC sets the broad standards for the medical education providers at the institution relative to ensuring that they have adequate authority and resources to conduct the program. This information is documented in the agency’s Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. The agency included an assessment report that demonstrates a review of the governance and administration at an institution relative to the standards under this guideline.
 
Chief Academic Official, Question 1
 
Country Narrative
Standards for appointment of senior academic staff are set through university quality assurance mechanisms. The Higher Education Standards Framework (APPENDIX 15) require Australian higher education providers to meet requirements regarding staff, including at section 5:

5 The higher education provider’s higher education operations are well-managed and human resources are appropriate.

5.1 The higher education provider has sufficient appropriately qualified personnel to manage and to provide academic leadership for the higher education provider’s higher education operations.

5.2 The higher education provider has the necessary staff positions, filled by appropriately qualified and experienced personnel, and access to other human resources, to achieve its higher education objectives, which include the achievement of expected student learning outcomes.

The AMC does not stipulate particular qualifications or experience for the dean / chief academic official of a medical school. The AMC asks medical schools to provide, and AMC teams assess the position description of the dean during assessments to ensure the dean’s responsibilities are appropriate to the standards.

A list of the names and qualifications of the Deans of the Australian and New Zealand Medical Schools is provided as APPENDIX 18 to demonstrate that although there is no specific accreditation standards concerning their qualifications and experience, all are well qualified academically with specialist qualifications in medicine or medical sciences, and all but one are experienced in patient care as specialist practitioners. The one medical dean who is not a medical practitioner is a biomedical scientist.

Documents:

APPENDIX 15: Higher Education Standards Framework (Threshold Standards) 2011
APPENDIX 18: List of the Deans of Australian and New Zealand Medical Schools showing qualifications and field of medical practice (where relevant)
 
Analyst Remarks to Narrative
The AMC’s standards ensure the competency and qualifications of medical school staff. Section 5 of the Higher Education Standards Framework discusses the appropriateness of these personnel but does not set specific qualifications for the chief academic official as required by this section or positions for each. The qualifications for staff and the chief academic officer are reviewed by the onsite inspection team. The agency has also included a list of the deans for the Australian and New Zealand medical schools that displays their experience and qualifications to include the assigned medical school for each individual. However, the agency has not demonstrated the onsite inspection team review of an institution for compliance relative to these standards.

Additional Information Requested:
NCFMEA may wish to request documentation demonstrating the AMC’s review and assessment of the appropriateness of the qualification of the chief medical officer and other educational staff and faculty.
 
Country Response

At Appendix 42, the AMC has provided a screen shot that shows the documentation provided by one medical school as evidence of meeting this standard. As shown, the position description for the dean of the medical school is provided. as well as information on the educational staff of the program.
 
Analyst Remarks to Response
The AMC's standards ensure the competency and qualifications of medical school staff. Section 5 of the Higher Education Standards Framework discusses the appropriateness of these personnel but does not set specific qualifications for the chief academic official as required by this section or positions for each. AMC has provided a screenshot as documentation from one of its medical schools displaying that show position descriptions for the head of the medical schools. However, the actual position description must be uploaded to be included in the official record of documentation submitted with the agency’s comparability petition. .

NCFMEA may wish to ask for the actual documentation of this job description to ensure compliance relative to this guideline.
 
Staff Conclusion: Additional Information requested
 
Chief Academic Official, Question 2
 
Country Narrative
In Australia and New Zealand appointment to senior academic posts is by an international search and open selection process against a defined position description. Appointments to such positions require the approval of the university governing body.

Appointment to the position of chief academic official (dean) require: a higher degree, demonstrating advanced scholarship in a relevant area; a record of published research; and and service component, such as membership of professional or academic committees or policy bodies at national and international level.

As indicated in the answer to b i) The Higher Education Standards Framework require higher education providers to have the necessary staff positions, filled by appropriately qualified and experienced personnel… to achieve its higher education objectives.

Documents:

APPENDIX 15: Higher Education Standards Framework (Threshold Standards) 2011
 
Analyst Remarks to Narrative
The AMC has provided its (Threshold Standards) 2011 see appendix 15. Section 5 of this document, contains the agency’s standards which requires that only appropriately qualified personnel manage the educational providers operations. The agency also explains that the chief academic official must have "a higher degree, demonstrating advanced scholarship in a relevant area; a record of published research; and service component, such as membership of professional or academic committees or policy bodies at national and international level." However, the Higher Education Standards Framework does not discuss the same level of details explained about the chief academic official qualifications that is discussed and outlined in the narrative.

Additional Information Requested:
NCFMEA may wish to request that the country adopt formal standards for the qualifications of the chief academic official. This would ensure that standards are in place for evaluating candidates through a consistent process and would align current practice with agency standards.
 
Country Response
The Higher Education Standards referred to in this response and elsewhere in the AMC's response are not a document of the Australian Medical Council, but are administered by the Tertiary Education Quality and Standards Agency, explained in section 1. This is a separate Government established quality assurance mechanism for higher education providers (universities). The AMC has not required a standard relating to the qualifications of the chief academic official because this quality assurance process and the competitive nature of appointments to medical school dean positions has meant additional standards are not necessary.

The list of qualifications of the medical deans of the Australian and New Zealand medical schools (shown at Appendix 18) demonstrates that all have higher degree qualifications (doctoral/research studies) and that those deans who are clinicians have specialist qualifications or fellowships in their relevant specialty.
 
Analyst Remarks to Response
AMC states that they believe having an AMC standard relating to the qualifications of the chief academic official are not necessary. AMC relies on the information that is established by the Tertiary Education Quality and Standards Agency for standards on this topic. AMC has provided documentation that demonstrates the qualifications of the Deans of its medical schools.

NCFMEA may wish to request clarification on the selection process of academic officials for medical schools.
 
Staff Conclusion: Additional Information requested
 
Faculty
 
Country Narrative
The AMC assesses and monitors medical schools against the approved Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (APPENDIX 10). The accreditation standards define internal and external stakeholder groups that must be consulted and engaged in the academic decision making processes of the medical school. Academic staff are defined in the glossary to the standards as internal stakeholders who must be involved in decision making.

The following accreditation standards relate to engagement in decisions related to the curriculum, and the hiring, retention, promotion, and discipline of faculty.

1.1.2 The governance structures set out, for each committee, the composition, terms of reference, powers and reporting relationships, and allow relevant groups to be represented in decision-making.
1.1.3 The medical education provider consults relevant groups on key issues relating to its purpose, the curriculum, graduate outcomes and governance.
1.3.1 The medical education provider has a committee or similar entity with the responsibility, authority and capacity to plan, implement and review the curriculum to achieve the objectives of the medical program.

When it assesses a medical school for accreditation, the AMC seeks information on the school’s committee structure and considers whether all appropriate groups are involved in the decision making on key matters. All medical schools have a senior academic body such as a faculty board or committee, which enables academic staff making into decision making.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
The AMC states that the faculty is involved in decisions related to this guideline. The agency states that they have standards related to engagement in decisions related to the curriculum, hiring, retention, promotion, and discipline of faculty. However, the standards themselves are not specific to faculty and list broad terms like 'relevant groups or committees'. Department staff has no way of knowing if the composition of these groups includes faculty members. In addition, the agency states that they conduct a review of the senior academic body such as a faculty board or committee at each institution but has not provided documentation of this review.

Additional Information Requested:
NCFMEA may wish to request documentation that shows how AMC demonstrates the review of elements required by this guideline.
 
Country Response
The sample reaccreditation report provided at APPENDIX 24 (section 1) and the extract from an Accreditation report provided at Appendix 16 describe AMC accreditation assessments of the governance structures of medical schools. These show that the AMC does review the structures for decision making about admissions, appointment of academic staff and curriculum design. They show that a mix of senior academic managers (such as program coordinators) as well as staff and students and external stakeholders contribute to academic decision making. The sample report at Appendix 24 proved at page 16 a commendation of the inclusiveness of the Faculty's academic governance. It states "The team commends the degree of coherence in and functionality of the programme governance structure. This is a reflection of outstanding leadership at University, Faculty, School, Head of Medical Programme and departmental levels, and a hugely collaborative approach from all staff within the Faculty and externally."
 
Analyst Remarks to Response
AMC has included documentation of an accreditation report (exhibit 12) that demonstrates how the site team reviews for compliance relative to this guideline. Specifically it is stated that the team met with the Faculty of Medical and Health Science staff including the Chair and Director of Medical Admissions. AMC has also included documentation of sample findings relative to department structure (exhibit 15). It is stated in the narrative that faculty are active in the roles of academic governance. However, while reviewed during these instances, none of the information in these documents confirm that it is faculty (not senior staff) that are involved in decisions related to admissions, the curriculum, and the hiring, retention, promotion, and discipline of faculty as required by this guideline.

NCFMEA may wish to ask for clarification to verify that faculty is involved in the decision making relative to this guideline.
 
Staff Conclusion: Additional Information requested
 
Remote Sites, Question 1
 
Country Narrative
The scope of AMC accreditations regarding dispersed sites is stated in the Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 (APPENDIX 4) at section 2.3:
The AMC accredits only complete medical programs that result in the award of an academic qualification of an education provider located predominantly in Australia or New Zealand. Accreditation is awarded to the provider for the specific medical program, identified by its degree title. By complete medical program, the AMC means that the education provider awarding the qualification is responsible for delivery of the entire program to the accreditation standards.

The AMC assesses programs offered jointly by two or more education providers which result in the award of a qualification by more than one provider as one program, but it accredits all the institutions which award a qualification for the program.

For example, the Joint Medical Program is offered as a joint program by both the University of Newcastle and the University of New England and the AMC accredits both providers and the program as one accreditation.

The AMC Procedures also indicate at section 2.3 that the AMC does not grant separate accreditation to branch campuses or clinical schools unless the programs at the campuses or schools result in distinct qualifications, and the delivery and management of the programs differs from campus to campus or school to school. This requirement is to ensure that if there are distinct medical programs, they are both accredited with equal care. There is one University in Australia that has more than one accreditation by the Australian Medical Council. The University of Notre Dame Australia offers medicine at its Sydney and Fremantle (Western Australia) campuses. The University has two, distinct Schools of Medicine with separate administrative structures. The Schools were established in different years. The two Schools are 4,000 kms apart. After considering the University structure, the AMC decided assess the Schools as separate entities, and to grant separate accreditations for the two separate programs.

Documents:
APPENDIX 4: Procedures for the Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 section 2.3.
 
Analyst Remarks to Narrative
The Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council require that the education provider awarding the qualification is responsible for delivery of the entire program. AMC further articulates that some programs have joint accreditation from other education providers in addition to the AMC recognition.

Additional Information Requested:
NCFMEA may wish to request information about even if the programs are dually accredited, if the basic science courses are taught within the country.
 
Country Response
One medical program in Australia, Monash University, has a medical program that allows a cohort of the medical students to complete a component of preclinical studies outside Australia. The AMC has reported on this previously to NCFMEA. Monash University has a campus in Malaysia that has provided preclinical medical education to an annual intake of 90 to 100 Monash medical students since 2005.

The MBBS program offered at in Malaysia and in Australia is considered the same program, and the AMC accredits it as one entity. In order to achieve accreditation, the medical school has had to demonstrate that the curriculum is equivalent to that offered in Australia, that Monash University Australia is responsible for the academic standard and quality assurance of the Malaysian program and has had to report on the assessment outcomes of the two programs to demonstrate equivalence. The AMC conducted full site accreditations before the program in Malaysia took its first students, and again after the program had been operating for two years.
 
Analyst Remarks to Response
AMC has stated that they have one program that is offered outside of Australia and has previously reported this information to the NCFMEA. While AMC has explained that they have conducted reviews of the program, they have not provided documentation of this review.

NCFMEA may wish to request a status update regarding this program and documentation that demonstrates how it reviews the curriculum to ensure that it is equivalent.
 
Staff Conclusion: Additional Information requested
 
Remote Sites, Question 2
 
Country Narrative
Yes all medical schools in Australia and New Zealand have clinical teaching across a range of sites.

The AMC has considerable experience in assessing medical schools with widely dispersed geographic sites. The Australian federal government supports a ‘rural clinical schools’ program which has provided for medical schools to establish clinical schools in rural locations, frequently at great distance from the main campus of the university.

Since this development in 2001, the AMC has strengthened the accreditation standards concerning consistency in experience across teaching sites and strengthened its requirements of accreditation teams assessing distributed programs. These requirements have been reported in previous AMC reports to the NCFMEA.

See APPENDIX 10 Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. The relevant accreditation standards are:

2.2.3 The medical program achieves comparable outcomes through comparable educational experiences and equivalent methods of assessment across all instructional sites within a given discipline.
5.4.2 The medical education provider ensures that the scope of the assessment practices, processes and standards is consistent across its teaching sites.
6.2.1 The medical education provider analyses the performance of cohorts of students and graduates in relation to the outcomes of the medical program.
8.1.1 The medical education provider ensures students and staff have access to safe and well-maintained physical facilities in all its teaching and learning sites in order to achieve the outcomes of the medical program.

The assessment team asks the same questions of students and faculty members at different sites, to triangulate information and assess comparability across all standards. When the AMC team assesses a medical program by site visit, it visits all the major teaching sites, videoconferences into smaller teaching sites, and meets students and staff to gather information about the implementation of the medical school’s policies and processes at specific sites, the resources available to support curriculum delivery, and to identify any difficulties with the delivery of the educational program locally. The AMC also seeks a student submission prior to any assessment process which offers the student body opportunity to comment on any standard, including equivalence across sites.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
The AMC has standards (appendix10, Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012) and policies regarding educational program conducted at sites that are geographically separated from the main campus of the medical school which addresses all of the elements of this guideline. Specifically, sections 2.2.3 and 5.4.2 requires that consistent practice occurs across sites.

Additional Information Requested:
NCFMEA may wish to request additional documentation demonstrating that the country has conducted reviews for ensuring consistency of student's knowledge and comparable evaluation across all locations.
 
Country Response
The list of conditions set on medical schools (Appendix 11) shows all the areas where the AMC has set a condition on a medical school's accreditation for non compliance. As the sample accreditation report provided at Appendix 24 shows, conditions are set as part of the accreditation report. The list at APPENDIX 11 shows that the AMC has set conditions relating to these standards in eight instances in the period 2010 to 2015:

Standard 1.1. Governance
Condition 1 on the list requires evidence of processes to address issues of variation in curriculum delivery and student experience across the School’s dispersed clinical sites

Condition 2 requires evidence by 2012 of clear and effective clinical school and academic discipline support structures to maintain a high quality teaching and learning experience for teaching staff and students across all University-affiliated clinical teaching sites

Standard 2.2 medical program outcomes

Condition1, 2, 4, 9 under this standard all require that the program achieves comparable outcomes through comparable education experience and equivalent methods of assessment across all instructional sites.

Standard 5.4 Assessment quality

Condition 4 and 10 under this standard both require evidence of development of an plan to ensure consistency of student assessment across all sites.
 
Analyst Remarks to Response
The country has explained its standards for those locations that are geographically separated locations in their Standards (appendix 10). Specifically, sections 2.2.3 and 5.4.2 address that consistent practice across sites. In response to the draft analysis, AMC has provided documentation demonstrating during the accreditation site visit report (exhibit 12) that a review for ensuring consistency across sites has occurred.
 
Staff Conclusion: Comprehensive response provided
 
Program Length, Question 1
 
Country Narrative
Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. The relevant accreditation standard is:
3.1 The medical program is of sufficient duration to ensure that the defined graduate outcomes can be achieved.

The accreditation standards for medical programs do not mandate program length by weeks or hours of instruction. This has not changed in the time the AMC has been reporting to the NCFMEA.

The AMC’s explanatory notes accompanying the accreditation standards (currently under review) indicate that, ‘based on international reference standards, a minimum course length of five calendar years for an undergraduate-entry course, and four years for a graduate-entry course, would normally be expected’.

All the accredited medical programs in Australia and New Zealand include four years graduate medical programs and five to six years medical programs for school-leavers.
There are no accredited programs of less than four years duration or less than 130 weeks of instruction.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
The country states in its narrative that the AMC does not have a minimum number of weeks of instruction to obtain an M.D. degree. However, they also state that there are no accredited programs of less than four years duration or less than 130 weeks of instruction.

Additional Information Requested:
NCFMEA may wish to request addition information as to whether the AMC will develop a standard requiring a minimum number of weeks of instruction to ensure compliance under this guideline.
 
Country Response
There has been no instance of a medical school seeking accreditation or approval in Australia with a program that is less than 130 weeks. The list of accredited medical schools available on the AMC website, http://www.amc.org.au/accreditation/primary-medical-education/schools/status

shows that all medical programs are four, five or six years in total length.

The AMC has not needed a standard regarding a minimum number of weeks of instruction because it has not had to consider a proposal for a shorter program.
 
Analyst Remarks to Response
In response to the draft analysis, AMC has stated that there have not been any instances of a program with less than 130 weeks of instruction. However, the guideline under this section requires that this timeframe must be met. Department Staff is concerned that without a standard for the amount of the program length, that a new program may submit a request to be less than that standard and that AMC will not have a way to enforce it if no standard exists.

NCFMEA may wish to request that the agency develop a policy for a minimum number of weeks instruction to ensure compliance under this guideline.
 
Staff Conclusion: Additional Information requested
 
Curriculum, Question 1
 
Country Narrative
Please refer to the graduate outcome statements (Domain 1) and Standards 3.6 and 4.5 in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The AMC Graduate Outcome Statements are grouped in four domains to provide a framework of the requirements that medical students must demonstrate at graduation. The Australian Medical Council standards require the medical education provider to demonstrate how their medical program enables their graduates to meet the outcomes. The four domains are:
1. Science and Scholarship: the medical graduate as scientist and scholar
2. Clinical Practice: the medical graduate as practitioner
3. Health and Society: the medical graduate as a health advocate
4. Professionalism and Leadership: the medical graduate as a professional and leader

Domain 1: Science and Scholarship: the medical graduate as scientist and scholar requires that, on entry to professional practice, Australian and New Zealand graduates are able to:
1.1 Demonstrate an understanding of established and evolving biological, clinical, epidemiological, social, and behavioural sciences.
1.2 Apply core medical and scientific knowledge to individual patients, populations and health systems.
1.3 Describe the aetiology, pathology, clinical features, natural history and prognosis of common and important presentations at all stages of life.
1.4 Access, critically appraise, interpret and apply evidence from the medical and scientific literature.
1.5 Apply knowledge of common scientific methods to formulate relevant research questions and select applicable study designs.
1.6 Demonstrate a commitment to excellence, evidence based practice and the generation of new scientific knowledge.

Relevant accreditation standards include:

2.2.1 The medical education provider has defined graduate outcomes consistent with the AMC Graduate Outcome Statements and has related them to its purpose.
2.2.2 The medical program outcomes are consistent with the AMC’s goal for medical education, to develop junior doctors who are competent to practise safely and effectively under supervision as interns in Australia or New Zealand, and who have an appropriate foundation for lifelong learning and for further training in any branch of medicine.

AMC accredited medical programs are required to provide a sound grounding in basic medical sciences, and students must have sufficient knowledge and understanding of basic sciences to support their mastery of the principles and practice of clinical medicine. It is essential that basic science teaching is relevant to the overall objectives of the medical program and that its relevance is apparent to students. The Graduate Outcomes required in the domains of Clinical Practice, and Professionalism and Leadership ensure that students acquire skills of critical and clinical judgement, and develop the professional skills to practice safely and wisely as a doctor. The Health and Society domain requires students to develop knowledge regarding the place of health and disease in society and in health care systems.

Documents:
APPENDIX 10: Graduate Outcome Statements and Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
In the country's narrative, AMC standards (Appendix 10) specify that each medical school to ensure that the acquisition of knowledge and skills for basic medical training are adequate for student learning. However, while the agency has standards relative to this guideline, they have not provided documentation of the application of this policy.

Additional Information Requested:
NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The reaccreditation assessment report provided at Appendix 24 shows an AMC assessment against these standards. The AMC has also provided a new appendix (Appendix 38) that provides an extract from another accreditation report showing the assessment of the curriculum content and teaching and learning methods.
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) require each medical school to ensure that the acquisition of knowledge and skills for basic medical training are adequate for student learning. AMC has provided documentation (appendix 38 and exhibit 12) that demonstrates how the site team reviews the curriculum for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Curriculum, Question 2
 
Country Narrative
Please refer to the graduate outcome statements (Domain 1) and Standards 3.2.1 in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The requirements for basic sciences are specified in the AMC Graduate Outcome Statements 1.1 – 1.6, under the domain of ‘Science and scholarship – the medical graduate as scientist and scholar. These require that on entry to professional practice, Australian and New Zealand graduates are able to:
1.1 Demonstrate an understanding of established and evolving biological, clinical, epidemiological, social, and behavioural sciences.
1.2 Apply core medical and scientific knowledge to individual patients, populations and health systems.
1.3 Describe the aetiology, pathology, clinical features, natural history and prognosis of common and important presentations at all stages of life.
1.4 Access, critically appraise, interpret and apply evidence from the medical and scientific literature.
1.5 Apply knowledge of common scientific methods to formulate relevant research questions and select applicable study designs.
1.6 Demonstrate a commitment to excellence, evidence based practice and the generation of new scientific knowledge.

In the standards, the following is relevant:
3.2.1 Science and Scholarship: The medical graduate as scientist and scholar
The curriculum includes the scientific foundations of medicine to equip graduates for evidence-based practice and the scholarly development of medical knowledge.

Documents:
APPENDIX 10: Graduate Outcome Statements and Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
The AMC's Graduate Outcome Statements and Standards for Assessment and Accreditation of Primary Medical Programs contain the requirements for basic sciences leading to the M.D. and address this guideline. These requirements are also discussed in the narrative However, while the agency has standards relative to this guideline, they have not provided documentation of the application of its policy.

Additional Information Requested:
NCFMEA may wish to request documentation(such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The sample accreditation report at APPENDIX 24 shows an assessment by an AMC accreditation team against these standards (see section 2 and 3 of the report). In addition, the new Appendix 38, shows an assessment of a different medical school.
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contains the requirements for basic sciences leading to the M.D. and address this guideline. AMC has provided documentation (appendix 38 and exhibit 12) that demonstrates how the site team reviews the curriculum for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Curriculum, Question 3
 
Country Narrative
Please refer to the graduate outcome statements (Domain 1) and Standards 1.7.1, 3.6 and 4.5 in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The Graduate Outcome Statements that relate to research and scholarly activity include:
1.4 Access, critically appraise, interpret and apply evidence from the medical and scientific literature.
1.5 Apply knowledge of common scientific methods to formulate relevant research questions and select applicable study designs.
1.6 Demonstrate a commitment to excellence, evidence based practice and the generation of new scientific knowledge.

The accreditation standards that relate to research and scholarly activities include:
1.7.1 The medical education provider is active in research and scholarship, which informs learning and teaching in the medical program.
3.6 There are opportunities for students to pursue studies of choice that promote breadth and diversity of experience.
This standard often relates to student choice in research projects, and opportunities to work with varied research teams, and sometimes, to attend conferences to present their research findings.

4.5 The medical program promotes role modelling as a learning method, particularly in clinical practise and research.

Documents:
APPENDIX 10: Graduate Outcome Statements and Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
Research, role modeling, and scholarly activity are embedded in the standards for the medical degree. The county explains in its narrative that students are assigned research projects and are given opportunities for presenting their findings at conferences. However, while the agency has standards relative to this guideline, they have not provided documentation of the application of its standards.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The sample accreditation report provided at Appendix 24 shows the AMC's review of a medical school against this standard. (see section 1.7 and section 3.6 of the report).
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements for research, role modeling, and scholarly activity. AMC has provided documentation (exhibit 12) that demonstrates how the site team reviews the curriculum for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Curriculum, Question 4
 
Country Narrative
Please refer to the graduate outcome statements (Domain 4, point 4.9) and Standards 2.2.2 and 4.2 in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

Domain 4.9
4.9 Self-evaluate their own professional practice; demonstrate lifelong learning behaviours and fundamental skills in educating colleagues. Recognise the limits of their own expertise and involve other professionals as needed to contribute to patient care.

The relevant accreditation standards are:

2.2.2 The medical program outcomes are consistent with the AMC’s goal for medical education, to develop junior doctors who are competent to practise safely and effectively under supervision as interns in Australia or New Zealand, and who have an appropriate foundation for lifelong learning and for further training in any branch of medicine.
4.2 The medical program encourages students to evaluate and take responsibility for their own learning, and prepares them for lifelong learning.

Documents:
APPENDIX 10: Graduate Outcome Statements and Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
The AMC's standards document (see appendix 10) specifically, standard 4.2 which states: "The medical program encourages students to evaluate and take responsibility for their own learning, and prepares them for lifelong learning." However, while the agency has standards relative to this guideline, they have not provided documentation of the application of its standards.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The sample reaccreditation report, provided at Appendix 24, demonstrates review of an institution's compliance with this standard (see section 4 of the report, and particularly section 4.2)
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements for lifelong learning. AMC has provided documentation (exhibit 12) that demonstrates how the site team reviews the curriculum for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Curriculum, Question 5
 
Country Narrative
Please refer to the graduate outcome statements (Domain 3 – health and society) and Standards 3.6 in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

Domain 3 Health and society, includes Graduate Outcome Statements that incorporate factors that contribute to diversity of cultural, spiritual and community values; to allocation of finite resources to meet community health needs, and to understand the diversity of cultures and communities of Aboriginal and Torres Strait Islander peoples.

The relevant accreditation standard is:
3.6 There are opportunities for students to pursue studies of choice that promote breadth and diversity of experience.

The AMC Standards do not prescribe ‘service-learning’ per se or how medical schools should include this in their programs. Accredited medical programs incorporate many aspects of service-learning in their programs, such as in community placements, reflective journals or e-portfolios.
The medical student societies include community service in their role, or have a separate society with this as its focus, which may include fundraising and engagement with community-based services and groups.

Documents:
APPENDIX 10: Graduate Outcome Statements and Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
In the country's narrative, they provide The AMC's standards document (appendix 10) specifically standard 3.6, states "there are opportunities for students to pursue studies of choice that promote breadth and diversity of experience." while the standard does not mention 'service learning' the students are given opportunities that include community placements, reflective journals or e-portfolios. However, while the agency has standards relative to this guideline, they have not provided documentation of the application of this policy.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The sample reaccreditation report provided as Appendix 24 outlines team's assessment of the personal and professional skills domain in this medical program, which encompasses service-related learning (see page 31). As this is a report on a New Zealand medical school, it also shows a strong focus on Maori (indigenous health) which is often an area of additional reflective exercises and learning about culture, diversity and health inequity.

Section 4.1 of this report (page 39) provides the team's assessment of reflective student exerices that link to the work in this theme of the course.
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements for service learning. AMC has provided documentation (exhibit 12) that demonstrates how the site team reviews the curriculum for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Curriculum, Question 6
 
Country Narrative
Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The relevant Standard 3.2.1 requires that the curriculum includes the scientific foundations of medicine to equip graduates for evidence-based practice and the scholarly development of medical knowledge, ensuring that graduates can demonstrate all of the specified AMC graduate outcomes.

The relevant Graduate Outcome Statements are:
1.1 Demonstrate an understanding of established and evolving biological, clinical, epidemiological, social, and behavioural sciences.
1.2 Apply core medical and scientific knowledge to individual patients, populations and health systems.
1.3 Describe the aetiology, pathology, clinical features, natural history and prognosis of common and important presentations at all stages of life.
1.4 Access, critically appraise, interpret and apply evidence from the medical and scientific literature.
1.5 Apply knowledge of common scientific methods to formulate relevant research questions and select applicable study designs.

The accreditation standards are normally accompanied by explanatory notes that give additional guidance on the meaning of the standards. The notes are currently under review, and so are not included in the accreditation standards provided by the AMC with this submission. The notes indicate that the biomedical sciences- including anatomy, biochemistry, genetics, immunology, microbiology, pathology, pharmacology, physiology and related disciplines – are the foundation of clinical medicine.

Documents:
APPENDIX 10: Graduate Outcome Statements and Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
The AMC provided its standards document (appendix 10) which includes standards for basic science reviews such as "established and evolving biological, clinical, epidemiological, social, and behavioural sciences." In addition, the AMC explains that classroom time is given to exploring the biomedical sciences- including anatomy, biochemistry, genetics, immunology, microbiology, pathology, pharmacology, physiology and related disciplines - are the foundation of clinical medicine. However, while the agency has standards relative to this guideline, they have not provided documentation of the application of its standards.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The AMC has provided as a new appendix (appendix 38) an extract from an accreditation report that shows a typical assessment of the content and structure of a curriculum and the related teaching and learning methods.
 
Analyst Remarks to Response
The AMC provided its standards document (appendix 10) which includes standards for basic science reviews such as "established and evolving biological, clinical, epidemiological, social, and behavioral sciences." In addition, the AMC explains that classroom time is given to exploring the biomedical sciences- including anatomy, biochemistry, genetics, immunology, microbiology, pathology, pharmacology, physiology and related disciplines - are the foundation of clinical medicine. However, while the agency has standards relative to this guideline, they have not provided documentation of the application of its standards.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC's review of an institution's compliance with its standards relative to this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Curriculum, Question 7
 
Country Narrative
Please refer to the graduate outcome statements (Domain 1, Science and scholarship) and Standards 4.1 in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
Domain 1, Science and Scholarship requires that the medical graduate can on entry to professional practice:
1.1 Demonstrate an understanding of established and evolving biological, clinical, epidemiological, social, and behavioural sciences.
1.2 Apply core medical and scientific knowledge to individual patients, populations and health systems.

Standard 4, teaching and learning methods indicates:

4.1 The medical education provider employs a range of learning and teaching methods to meet the outcomes of the medical program.
While the accreditation standards, as outcomes-based standards do not specify that laboratory and practical exercises are required as part of the medical curriculum. In practice, these requirements amount to an expectation that schools will include appropriate instruction for the biomedical sciences, including laboratory and practical instruction.

AMC assessment teams include faculty with medical program expertise in the sciences basic to medicine and the team meets with the committee who programs the sciences components, with the faculty and tutors, and with students to assess the adequacy of the medical program to meet the standards. The team inspects the laboratory facilities to ensure that they are safe and well-maintained in order to achieve the program outcomes (Standard 8.1)

Documents:
APPENDIX 10: Graduate Outcome Statements and Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
The AMC’s standards manual (see appendix 10) specifically standard 4.1, which states "The medical education provider employs a range of learning and teaching methods to meet the outcomes of the medical program." However, this standard is not clear as to if it encompasses laboratory experiences as outlined in this guideline.

NCFMEA may wish to request clarification on whether students are exposed to laboratory or other practical exercises that facilitate the ability to make accurate quantitative observations of biomedical phenomena and critical analyses of data and if the AMC has plans to create a standard specific to this guideline data.
 
Country Response
The AMC has provided an additional extract from an accreditation report (appendix 38) which shows an assessment of the curriculum content and teaching and learning methods used in a medical program.

Section 3.2 and section 4.1 of the document are relevant.
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements for laboratory sciences leading to the M.D. and address this guideline. AMC has provided documentation (appendix 38) that demonstrates how the site team reviews the curriculum for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Clinical Experience, Question 1
 
Country Narrative
Refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
Part 1
Domain 1, Science and Scholarship, and Domain 2, Clinical Practice require that the medical graduate can :
1.1 Demonstrate an understanding of established and evolving biological, clinical, epidemiological, social, and behavioural sciences.
1.2 Apply core medical and scientific knowledge to individual patients, populations and health systems.
1.2 Apply core medical and scientific knowledge to individual patients, populations and health systems.
1.3 Describe the aetiology, pathology, clinical features, natural history and prognosis of common and important presentations at all stages of life.
12.1 Demonstrate by listening, sharing and responding, the ability to communicate clearly, sensitively and effectively with patients, their family/carers, doctors and other health professionals.
2.2 Elicit an accurate, organised and problem-focussed medical history, including family and social occupational and lifestyle features, from the patient, and other sources.
2.3 Perform a full and accurate physical examination, including a mental state examination, or a problem-focused examination as indicated.
2.4 Integrate and interpret findings from the history and examination, to arrive at an initial assessment including a relevant differential diagnosis. Discriminate between possible differential diagnoses, justify the decisions taken and describe the processes for evaluating these.
2.5 Select and justify common investigations, with regard to the pathological basis of disease, utility, safety and cost effectiveness, and interpret their results.
2.6 Select and perform safely a range of common procedural skills.
2.7 Make clinical judgements and decisions based on the available evidence. Identify and justify relevant management options alone or in conjunction with colleagues, according to level of training and experience.
2.10 Integrate prevention, early detection, health maintenance and chronic condition management where relevant into clinical practice.
2.11 Prescribe medications safely, effectively and economically using objective evidence. Safely administer other therapeutic agents including fluid, electrolytes, blood products and selected inhalational agents.

Relevant accreditation standards:
3.2.1 The curriculum includes the scientific foundations of medicine to equip graduates for evidence-based practice and the scholarly development of medical knowledge.
3.2.2 The curriculum contains the foundation communication, clinical, diagnostic, management and procedural skills to enable graduates to assume responsibility for safe patient care at entry to the profession.

As outcome based standards, these standards do not specify particular clinical science subjects, but require that medical schools meet the AMC Graduate Outcome Statements . To acquire these outcomes medical programs should include family medicine (general practice), surgery, internal medicine, paediatrics, obstetrics and gynaecology, and psychiatry, as well as experience in other areas of medical practice such as rehabilitation, palliative medicine, geriatrics, emergency medicine, dermatology, ophthalmology. The glossary to the standards includes an extended definition of clinical experience/clinical attachments, which lists these requirements.

Part 2
In an accreditation assessment, the medical school must demonstrate that its outcomes align with the AMC graduate outcome statements, and that the curriculum, assessment and teaching and learning methods including clinical teaching allow these outcomes to be met. The relevant accreditation standards are:

3.2 The curriculum content ensures that graduates can demonstrate all of the specified AMC graduate outcomes.
5.2.1 The medical education provider assesses students throughout the medical program, using fit for purpose assessment methods and formats to assess the intended learning outcomes.
5.2.2 The medical education provider has a blueprint to guide the assessment of students for each year or phase of the medical program.
8.3.1 The medical education provider ensures that the clinical learning environment offers students sufficient patient contact, is appropriate to achieve the outcomes of the medical program and to prepare students for clinical practice.

In its accreditation submission, the medical school must provide a detailed description of the curriculum, assessment and, in relation to clinical teaching a table for each clinical teaching site (urban and rural, hospital and community) with a breakdown for each year of the numbers of students placed and in what departments/units, together with projected student numbers in these sites over each year of the coming period of accreditation. (APPENDIX 17, section 8)

Together, this information allows the AMC to confirm that medical schools require clinical experience in all of the required disciplines to ensure that their students possess the knowledge and clinical abilities to enter any field of graduate medical education.

Part 3

Relevant Graduate Outcome Statements :

1.3 Describe the aetiology, pathology, clinical features, natural history and prognosis of common and important presentations at all stages of life.
2.2 Elicit an accurate, organised and problem-focussed medical history, including family and social occupational and lifestyle features, from the patient, and other sources.
2.3 Perform a full and accurate physical examination, including a mental state examination, or a problem-focused examination as indicated.
2.10 Integrate prevention, early detection, health maintenance and chronic condition management where relevant into clinical practice.
2.12 Recognise and assess deteriorating and critically unwell patients who require immediate care. Perform common emergency and life support procedures, including caring for the unconscious patient and performing CPR.
2.13 Describe the principles of care for patients at the end of their lives, avoiding unnecessary investigations or treatment, and ensuring physical comfort including pain relief, psychosocial support and other components of palliative care.
3.5 Explain and evaluate common population health screening and prevention approaches, including the use of technology for surveillance and monitoring of the health status of populations. Explain environmental and lifestyle health risks and advocate for healthy lifestyle choices.

Relevant accreditation standard
8.3.2 The medical education provider has sufficient clinical teaching facilities to provide clinical experiences in a range of models of care and across metropolitan and rural health settings.

The Accreditation Standards are usually accompanied by explanatory see previous AMC submissions to NCFMEA). These are under review. The relevant notes say “Students need to gain adequate coverage of common clinical problems in both acute and chronic settings with relevant exposure to continuity of care and interaction with community-based services. The concepts of patient-centred care and and chronic condition self-management are important in contemporary practice.”
The notes also indicate: “Students need broad exposure to patients with a range of common medical, surgical, paediatric, gynaecological and psychiatric problems. They should have have the opportunity to work in rural, suburban, community and priva
 
Analyst Remarks to Narrative
The AMC’s standards manual (see appendix 10) specifically, standards 1 and 2 require core medical subject training. In addition, standard 3 discusses requirements for clinical experiences that include opportunities based on outcomes. In addition to the existing standards, the country explains in its narrative that a standard is under review that states "Students need to gain adequate coverage of common clinical problems in both acute and chronic settings with relevant exposure to continuity of care and interaction with community-based services. The concepts of patient-centered care and chronic condition self-management are important in contemporary practice." However, while the agency has standards relative to this guideline, they have not provided documentation of the application of this policy.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The sample accreditation report provided at Appendix 24 shows commentary on a medical school's clinical teaching. In this report, the existence of the relevant clinical departments (relating to required areas of internal medicine, obstetrics and gynecology, pediatrics, surgery, and psychiatry and, preferably, family medicine) are confirmed in section 1 of the report (see page 10) The availability of staff in these areas is confirmed on page 23 (table 2) . Section 8, (page 61 onwards) discusses the facilities and teaching opportunities in the various clinical disciples and modes of care.

The list of conditions set on accreditation (appendix 11) shows the areas where the AMC has had concerns about clinical teaching and has set conditions to ensure compliance with accreditation standards. These include:

Under Standard 3,2 (page 5 of the list), a school was required to complete the planned review of teaching content of orthopaedics, ENT, and dermatology to ensure all students have appropriate learning opportunities in these curriculum areas.

Under Standard 8.3, page 15 of the list the AMC requires a medical school to provide a breakdown of clinical learning placements for all clinical disciplines for Years 3 and 4 of the MD program.
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements for medical programs to require core medical subject training and to address this guideline. AMC has provided documentation (appendix 38) that demonstrates how the site team reviews the clinical experience for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Clinical Experience, Question 2
 
Country Narrative
The AMC assesses and monitors medical programs against the Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (APPENDIX 10). Medical schools provide an accreditation submission to the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met to the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set. The conditions set by the AMC for this standard are provided in APPENDIX 11 as evidence that the AMC assesses against these standards.

The following standard is relevant
2.2.2 The medical program outcomes are consistent with the AMC’s goal for medical education, to develop junior doctors who are competent to practise safely and effectively under supervision as interns in Australia or New Zealand, and who have an appropriate foundation for lifelong learning and for further training in any branch of medicine.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
 
Analyst Remarks to Narrative
The AMC’s standards manual (see appendix 10) specifically, standard 2.2.2 which states "The medical program outcomes are consistent with the AMC's goal for medical education, to develop junior doctors who are competent to practice safely and effectively under supervision as interns in Australia or New Zealand, and who have an appropriate foundation for lifelong learning and for further training in any branch of medicine." However, while the agency has standards relative to this guideline, they have not provided documentation of the application of these standards.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The sample accreditation report provided at Appendix 24 shows the AMC assessment of a program against this requirement. See in particular section 2.2 of the report, which provides the following assessment of this program:

While comprehensive Graduate Learning Outcomes have been defined, these are not fully consistent with the AMC Graduate Outcome Statements. The Faculty states that the AMC Graduate Outcome Statements are met through a combination of its Graduate Learning Outcomes and module and course learning outcomes across Phases 1 to 3, associated with specific learning activities within the medical programme.

The Faculty should undertake further work to demonstrate the consistency of its Graduate Learning Outcomes with all of the AMC Graduate Outcome Statements as required by the accreditation standards. This would communicate the graduate outcomes of the programme to students and other stakeholders with an interest in the programme.

Numerous anecdotal reports attested to the high quality of graduates from the programme. These reports need to be supported by systematic outcome evaluation data. The team is encouraged by the active plan of evaluation using correlation with the Medical Schools’ Outcomes Database and other forms of postgraduate evaluation data.

Section 3 of the sample accreditation report shows how the AMC assesses that learning outcomes and curriculum content align.

The list of conditions set on accreditations (at Appendix 11) shows instances where the AMC has set a condition on a medical program for non compliance with the standards listed in the AMC response above. There have been five instances (reported under standard 2.2) between July 2010 and December 2015 when the AMC has set a condition concerning alignment between a medical schools' learning outcomes and the outcomes the AMC states as relating to a graduate being prepared for safe and competent medical practice.
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements for ensuring students possess the knowledge and clinical abilities to enter any field of graduate medical education to address this guideline. AMC has provided documentation (exhibit 12) that demonstrates how the site team reviews the clinical experience for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Clinical Experience, Question 3
 
Country Narrative
Part 1
The AMC assesses and monitors medical programs against the Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012 (APPENDIX 10). Medical schools provide an accreditation submission to the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met to the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set. The conditions set by the AMC for this standard are provided in APPENDIX 11 as evidence that the AMC assesses against these standards.
The relevant accreditation standards are:
4.7 The medical program ensures that students work with, and learn from and about other health professionals, including experience working and learning in interprofessional teams.
8.3.2 The medical education provider has sufficient clinical teaching facilities to provide clinical experiences in a range of models of care and across metropolitan and rural health settings.

Graduate Outcome Statement 4.8 requires that graduates can describe and respect the roles and expertise of other health care professionals, and demonstrate ability to learn and work effectively as a member of an inter-professional team or other professional group.

Part 2

The AMC Graduate Outcome Statements that are most relevant are listed below.

On entry to professional practice, Australian and New Zealand graduates are able to:
1.3 Describe the aetiology, pathology, clinical features, natural history and prognosis of common and important presentations at all stages of life.
2.2 Elicit an accurate, organised and problem-focussed medical history, including family and social occupational and lifestyle features, from the patient, and other sources.
2.3 Perform a full and accurate physical examination, including a mental state examination, or a problem-focused examination as indicated.
2.10 Integrate prevention, early detection, health maintenance and chronic condition management where relevant into clinical practice.
2.12 Recognise and assess deteriorating and critically unwell patients who require immediate care. Perform common emergency and life support procedures, including caring for the unconscious patient and performing CPR.
2.13 Describe the principles of care for patients at the end of their lives, avoiding unnecessary investigations or treatment, and ensuring physical comfort including pain relief, psychosocial support and other components of palliative care.
3.5 Explain and evaluate common population health screening and prevention approaches, including the use of technology for surveillance and monitoring of the health status of populations. Explain environmental and lifestyle health risks and advocate for healthy lifestyle choices.

The relevant accreditation standard is:
8.3.2 The medical education provider has sufficient clinical teaching facilities to provide clinical experiences in a range of models of care and across metropolitan and rural health settings.

The Accreditation Standards are usually accompanied by explanatory notes (see previous AMC accreditation submissions to the NCFMEA). These are currently under review. The notes concerning these requirements say “Students need to gain adequate coverage of common clinical problems in both acute and chronic settings with relevant exposure to continuity of care and interaction with community-based services. The concepts of patient-centred care and chronic condition self-management are important in contemporary practice.”

In addition, the notes indicate: “Students need broad exposure to patients with a range of common medical, surgical, paediatric, gynaecological and psychiatric problems. They should have the opportunity to work in rural, suburban, community and private hospitals, in general practice, in community health centres, in nursing homes and in centres for those with chronic intellectual or physical disability. Since many hospitals now have only limited outpatient facilities, medical schools should consider the use of specialist private practices to provide the necessary clinical experience of ambulatory care.”

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
 
Analyst Remarks to Narrative
The AMC’s standards manual (appendix 10) specifically standard 8.3.2, requires that students are given "sufficient clinical teaching facilities to provide clinical experiences in a range of models of care and across metropolitan and rural health settings." More information is needed from the country to clarify the AMC’s requirements related to understanding the standards for assessing medical schools in the context of their delivery of instruction and experience in patient care provided in both ambulatory and hospital settings.

NCFMEA may wish to request clarification and documentation that demonstrates AMC's review of the institution for adherence relative to the requirements of this guideline, specifically if students are provided opportunities for experience in both ambulatory and hospital settings.
 
Country Response
The sample reaccreditation report at Appendix 24 shows that students have experience in hospitals (through allocation to clinical schools) and general practices. Section 1 lists the clinical academic areas that teach into the program. Section 3 of the report describes the curriculum content. Geriatrics and emergency teaching are mentioned specifically in the report under curriculum content as areas where teaching has been increased. section describes the clinical school structure.
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements for ensuring students have experiences in both outpatient and inpatient settings and to address this guideline. AMC has provided documentation (exhibit 12) that demonstrates how the site team reviews the clinical experience for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Supporting Disciplines
 
Country Narrative
Please refer to Domain 4 of the graduate outcome statements in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
The AMC Graduate Outcome Statements that are most relevant to this question are as follows:

1.1 Demonstrate an understanding of established and evolving biological, clinical, epidemiological, social, and behavioural sciences.
1.4 Access, critically appraise, interpret and apply evidence from the medical and scientific literature.
2.5 Select and justify common investigations, with regard to the pathological basis of disease, utility, safety and cost effectiveness, and interpret their results.
2.7 Make clinical judgements and decisions based on the available evidence. Identify and justify relevant management options alone or in conjunction with colleagues, according to level of training and experience.
2.11 Prescribe medications safely, effectively and economically using objective evidence. Safely administer other therapeutic agents including fluid, electrolytes, blood products and selected inhalational agents.
2.14 Place the needs and safety of patients at the centre of the care process. Demonstrate safety skills including infection control, graded assertiveness, adverse event reporting and effective clinical handover.
4.8 Describe and respect the roles and expertise of other health care professionals, and demonstrate ability to learn and work effectively as a member of an inter-professional team or other professional group.

Accreditation Standard 3.2 requires the curriculum content to enable graduates to achieve these outcomes.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
The country explains in its narrative that the AMC has standards that address disciplines that support general medical practice, including clinical pathology. While the AMC has standards for these types of discipline, no documentation was included that demonstrates that these standards have been applied at the medical school.

Additional Information Requested:
NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The AMC has provided an extract from an accreditation report that shows an accreditation team's assessment of the curriculum content of a medical program (appendix 38).
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements for addressing disciplines that support general medical practice, including clinical pathology and to address this guideline. AMC has provided documentation (appendix 38) that demonstrates how the site team reviews the supporting disciplines for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Ethics, Question 1
 
Country Narrative
Question i (I)

Please refer to Domain 4 of the graduate outcome statements in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

Domain 4 Professionalism and leadership incorporates medical ethics and human values.
4.1 Provide care to all patients according to “Good Medical Practice: A Code of Conduct for Doctors in Australia” and “Good Medical Practice: A Guide for Doctors” in New Zealand (APPENDIX 19 and 20).
4.2 Demonstrate professional values including commitment to high quality clinical standards, compassion, empathy and respect for all patients. Demonstrate the qualities of integrity, honesty, leadership and partnership to patients, the profession and society.
4.4 Explain the main principles of ethical practice and apply these to learning scenarios in clinical practice. Communicate effectively about ethical issues with patients, family and other health care professionals.
4.7 Demonstrate awareness of and explain the options available when personal values or beliefs may influence patient care, including the obligation to refer to another practitioner.

Standard 3.2 requires the curriculum content to enable graduates to achieve these outcomes.

Question i (ii) The AMC assesses and monitors medical programs against The Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. Medical schools provide an accreditation submission the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set. The conditions set by the AMC for this standard are provided in an appendix as evidence that the AMC assesses against these standards.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
APPENDIX 19: Good Medical Practice – Australia
APPENDIX 20: Good Medical Practice – New Zealand
 
Analyst Remarks to Narrative
As outlined in the country's narrative, requirements regarding medical ethics and human values are embedded throughout the AMC’s standards and policies, particularly in competencies of compassion, empathy, and respect for all patients. The country has also included documentation of its Code of Conduct for good medical practice (appendix 19 and 20).
 
Communication Skills, Question 1
 
Country Narrative
Question m (i)
Please refer to Standard 3.2 and the graduate outcome statements in APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The Graduate Outcome Statements that are most relevant to instruction in communication skills include:
2.1 Demonstrate by listening, sharing and responding, the ability to communicate clearly, sensitively and effectively with patients, their family/carers, doctors and other health professionals.
2.8 Elicit patients’ questions and their views, concerns and preferences, promote rapport, and ensure patients’ full understanding of their problem(s). Involve patients in decision-making and planning their treatment, including communicating risk and benefits of management options.
2.9 Provide information to patients, and family/carers where relevant, to enable them to make a fully informed choice among various diagnostic, therapeutic and management options.
3.3 Communicate effectively in wider roles including health advocacy, teaching, assessing and appraising.
3.4 Understand and describe the factors that contribute to the health and wellbeing of Aboriginal and Torres Strait Islander peoples and/or Maori, including history, spirituality and relationship to land, diversity of cultures and communities, epidemiology, social and political determinants of health and health experiences. Demonstrate effective and culturally competent communication and care for Aboriginal and Torres Strait Islander peoples and/or Maori.

The relevant Accreditation Standard is
3.2 The curriculum content to ensure that graduates can demonstrate all of the specified AMC graduate outcomes.

Question m (ii)
The AMC assesses and monitors medical programs against The Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. Medical schools provide an accreditation submission the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set. The conditions set by the AMC for this standard are provided in an appendix as evidence that the AMC assesses against these standards.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
 
Analyst Remarks to Narrative
The AMC standards (appendix 10) stress the significance of communication. For example, standard 2.8 states that students, "elicit patients' questions and their views, concerns and preferences, promote rapport, and ensure patients' full understanding of their problem(s), involve patients in decision-making and planning their treatment, including communicating risk and benefits of management options." Standard 3.3, further states that the student should be able to "communicate effectively in wider roles including health advocacy, teaching, assessing and appraising."
 
Design, Implementation, and Evaluation, Question 1
 
Country Narrative
Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The relevant accreditation standards are:

1.3.1 The medical education provider has a committee or similar entity with the responsibility, authority and capacity to plan, implement and review the curriculum to achieve the objectives of the medical program.
6.1.1 The medical education provider regularly monitors and reviews its medical program including curriculum content, quality of teaching and supervision, assessment and student progress decisions. It manages quickly and effectively concerns about, or risks to, the quality of any aspect of medical program.
6.1.2 The medical education provider systematically seeks teacher and student feedback, and analyses and uses the results of this feedback for monitoring and program development.
6.3.1 The results of outcome evaluation are reported through the governance and administration of the medical education provider and to academic staff and students.


Documents:
• APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
 
Analyst Remarks to Narrative
According to AMC standards (appendix 10) the "medical education provider regularly monitors and reviews its medical program including curriculum content, quality of teaching and supervision, assessment and student progress decisions. It manages quickly and effectively concerns about, or risks to, the quality of any aspect of medical program." The narrative also explains that information is systematically reported and the results are used as feedback for further program development. However, while the agency has standards relative to this guideline, they have not provided documentation of the application of its standard.

NCFMEA may wish to request documentation(such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The list of conditions set on medical schools (Appendix 11) shows all the areas where the AMC has set a condition on a medical school's accreditation for non compliance. As the sample accreditation report provided at Appendix 24 shows, conditions are set as part of the accreditation report.

The list at APPENDIX 11 shows that the AMC has set conditions relating to these standards in three instances in the period 2010 to 2015:

Standard 6.1. Monitoring
Condition 1 on the list requires evidence that teacher

.....
 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements ensuring that the faculty regularly monitor and reviews medical programs curriculum content and for this guideline. AMC has provided documentation (exhibit 12 and appendix 11) that demonstrates how the site team reviews the curriculum for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Design, Implementation, and Evaluation, Question 2
 
Country Narrative
Question o (i)
Yes each medical school is required to regulay evaluate the effectiveness of its own medical program. See APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

Standard 6 relates to monitoring of the curriculum. In relation to evaluation of effectiveness of the curriculum, the relevant standards are:
6.2.1 The medical education provider analyses the performance of cohorts of students and graduates in relation to the outcomes of the medical program.
6.2.2 The medical education provider evaluates the outcomes of the medical program.
6.2.3 The medical education provider examines performance in relation to student characteristics and feeds this data back to the committees responsible for student selection, curriculum and student support.
6.3.1 The results of outcome evaluation are reported through the governance and administration of the medical education provider and to academic staff and students.

In addition, all universities in Australia and New Zealand have internal academic review processes, which require regular program reviews. The AMC cites the Higher Education Standards as evidence of this process and requirement:

3.8 The higher education provider’s corporate and academic governance arrangements demonstrate:
• the effective development, implementation and review of policies for all aspects of the higher education provider’ academic activities including delivery of the higher education provider’ courses of study by other entities;
• the maintenance of academic standards, with appropriate mechanisms for external input, in accordance with international conventions for good academic practice; and,
• effective quality assurance arrangements for all the higher education provider?s higher education operations, encompassing systematic monitoring, review and improvement

Question o(ii)

Neither Australia or New Zealand have a national curriculum or centralised medical curriculum authority.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
APPENDIX 15: Higher Education Standards Framework (Threshold Standards) 2011
 
Analyst Remarks to Narrative
The requirements for medical school curricula are delineated in Standard 6 and Standard 3.8 (appendix 10). However, while the agency has standards relative to this guideline, they have not provided documentation of the application of this policy.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The AMC has provided as a new appendix (Appendix 40) an extract from a number of accreditation reports that demonstrate that good practices in evaluation of curriculum effectiveness are commended, and conditions are set where standards are not met and or quality improvement recommendations where the AMC considers practices could be improved.
 
Analyst Remarks to Response
The requirements for medical school curricula are delineated in Standard 6 and Standard 3.8 (appendix 10). AMC has provided documentation extracts (appendix 40) that demonstrate how they evaluate the effectiveness of the curriculum and how they establish conditions to ensure if standards are not being met, they are successfully addressed.
 
Staff Conclusion: Comprehensive response provided
 
Design, Implementation, and Evaluation, Question 3
 
Country Narrative
Question p (i)
See APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The relevant accreditation standards are:
1.3.1 The medical education provider has a committee or similar entity with the responsibility, authority and capacity to plan, implement and review the curriculum to achieve the objectives of the medical program.
1.4.1 The medical education provider uses educational expertise, including that of Indigenous peoples, in the development and management of the curriculum
3.3 There is evidence of purposeful curriculum design which demonstrates horizontal and vertical integration and articulation with subsequent stages of training.
6.2.2 The medical education provider evaluates the outcomes of the medical program.
6.2.3 The medical education provider examines performance in relation to student characteristics and feeds this data back to the committees responsible for student selection, curriculum and student support.

P 2
The relevant accreditation standards concerning program monitoring and evaluation are listed in the response to the previous question.

In its Guide to medical schools preparing for accreditation (APPENDIX 17) the AMC provides the following instructions:

Address the standards
In this guide the approved accreditation standards are presented together with a series of explanatory instructions and questions. For each set of accreditation standards, education providers are asked to respond to specific enquiries which indicate the type of information the AMC is seeking. The response to the enquiry should include a summary of the education provider’s steps to maintain the standard, including comments on changes and development since the last AMC assessment and the evaluation and review processes that led to the decision to make changes, and critical review of the success of any developments or changes implemented, together with description of plans for change during the coming period of accreditation and the timing of those plans.
The AMC team will be interested in the provider’s plans for the program against the standards. The education provider should seek to identify in each area of its submission relevant strengths, challenges and the processes for addressing the challenges, with relevant examples and data. Self-reflection and appraisal, with evidence of consideration of evaluation data, and an appreciation of strengths and weaknesses should characterise both the submission and the accreditation process.

During assessment visits and monitoring, the AMC seeks evidence from medical schools that they are evaluating the curriculum and program and implementing quality improvement as necessary. The AMC findings included with an accreditation decision also include recommendations for improvement for when a standard is found to be met but continuous improvement ideas are suggested.

APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
APPENDIX 17: Reaccreditation Submission Guide 2016
 
Analyst Remarks to Narrative
AMC standards (appendix 10) set the requirements for determining the appropriateness of identified outcomes. The AMC requires each medical provider to document a review of the how they meet established standards, feedback on the changes, and evaluation/critical review since its last review. They country states that the evaluation of the information shared by the medical provider occurs during onsite visits. However, no documentation was included that demonstrates this review.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The sample reaccreditation report at Appendix 24 shows an AMC assessment team's assessment of a medical program against these standards - see sections 1.3 and 1.4, 3.3 and 6.2 of the report.

 
Analyst Remarks to Response
AMC specifies that its standards (appendix 10) contain the requirements ensuring that it regularly monitors and reviews medical programs design, implementation, and evaluation of a medical school’s curriculum and relative to this guideline. AMC has provided documentation (exhibit 12) that demonstrates how the site team reviews the curriculum for compliance under this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Admissions, Recruiting, and Publications, Question 1
 
Country Narrative
Question a (i)
The AMC provides the following information, which was included in the recent accreditation submission by one medical school that takes international students that include US citizens, nationals, and eligible permanent resident, (Sydney Medical School) and also information in a recent update from anotehr medical school taht takes these students, (the University of Queensland).
Sydney Medical School, University of Sydney:
“For the new MCAT from April 2015, international applicants who meet the minimum overall score of 500 (and the minimum GPA requirement) will be invited for interview. Applicants who achieve an overall score between 496 and 499 will be placed on a reserve list which we will consider as further MCAT scores are available. (Note: No minimum section score is required.)

Additionally for US citizens/nationals/permanent residents:

If you are applying for the Doctor of Medicine and you are a US citizen/national/permanent resident (regardless of whether you are also a citizen or permanent resident of a country other than USA), you are required to submit MCAT results. The MCAT results are required so that Sydney Medical School can comply with US Department of Education requirements to participate in the US direct loan scheme. The University is required to provide the Department with lists containing MCAT results and the number of times that US students sat MCAT (but without students' names).

Please note that:
- If you are an eligible domestic applicant AND a US citizen or national or permanent resident, you must supply both MCAT and GAMSAT results and your GAMSAT score will be used in the admission process. There is no minimum requirement for MCAT results and if you wish you may supply the required MCAT results at the time of enrolment.

- If you are a US citizen or national or permanent resident (but NOT an eligible domestic applicant), you must submit MCAT results at the time of application. Alternatively, you may submit both MCAT and GAMSAT results at the time of application if they both meet the minimum requirements and the admission procedure will use whichever results in the higher ranking.

The Sydney Medical School advised the AMC in 2015 that the threshold score varies from year to year depending on the number of applicants, and tends to rise each year. Applicants who meet the GPA and GAMSAT or MCAT thresholds are invited to an interview, currently a five--station multiple mini interview (MMI).Following the MMI, students are ranked on the combined equally--weighted GAMSAT/MCAT and MMI scores and they are then ranked. Finally, students are progressively offered places down the rank.

The University of Queensland, School of Medicine admission process require the following:

Direct entry for graduates
If you have already completed a bachelor degree or equivalent, you can apply for direct entry to the MD, if you meet the following minimum entry requirements:
- minimum grade point average of 5 on a 7-point scale in a key degree (bachelor, honours, masters or PhD) completed in the last 10 years
- minimum score of 50 in each sections of the Graduate Medical School Admissions Test(GAMSAT) completed in the last two years or minimum score of 8/8/8 in the Medical College Admission Test (MCAT) completed in the last three years
- at least 7 overall and a minimum of 7 in each sub-band of the International English Language Testing System (IELTS) or equivalent.

The key degree may be undertaken in any discipline, although strong scientific knowledge is required for a better GAMSAT score and a biomedical background is recommended for this reason.

Where an applicant has also completed an approved honours program, graduate diploma, postgraduate diploma, masters or doctoral program, the most recent of these will be used as the key degree.

If an applicant’s most recent academic qualification was completed more than 10 years prior to the proposed study commencement date, it will not be accepted for assessment unless the applicant has passed the equivalent of one full-time semester (four full-time subjects) of postgraduate coursework study in the 10 years preceding the proposed commencement date.

Applicants are assessed on a case-by-case basis. Meeting the minimum entry requirements does not guarantee acceptance.

Successful applicants are selected through an order of merit based on their overall GAMSAT score. The GPA from the most recently completed acceptable academic qualification is then used as a differentiator between applicants with the same GAMSAT scores.

Question a (ii)
See APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The relevant accreditation standards are:
7.2.1 The medical education provider has clear selection policy and processes that can be implemented and sustained in practice, that are consistently applied and that prevent discrimination and bias, other than explicit affirmative action.
6.2.3 The medical education provider examines performance in relation to student characteristics and feed this data back to the committees responsible for student selection, curriculum and student support.

In its guide to medical schools preparing for accreditation (APPENDIX 17), the AMC provides the following instructions for information concerning selection of international students (non-Australian and New Zealand students) :

Provide a summary table of the selection steps, instruments, weightings and timelines. Describe separately the steps, instruments, weightings and timelines for selection of international students.
Provide details and the rationale for processes that deal with particular groups of students differently in the selection process. This should include information on any quotas, access/feeder programs or reserved places.

Medical schools which select US citizens or nationals or permanent residents to their programs are aware of the requirement to provide information on the MCAT results as part of their submissions.
During an accreditation assessment visit, the AMC team interviews the Admissions Committee, reviews the admissions / selection data and also talks to students and stakeholders regarding the selection process to evaluate quality.
An extract from an AMC accreditation report, which shows the accreditation team’s assessment of the medical program against the admission accreditation standards is provided as an APPENDIX 21.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
APPENDIX 17: Reaccreditation Submission Guide 2016
APPENDIX 21: Sample accreditation report – standard 7 student selection
 
Analyst Remarks to Narrative
As stated in the country's narrative, the AMC has broad standards for evaluation of MCAT scores. Standard 7.2.1, requires that "The medical education provider ha clear selection policy and processes that can be implemented and sustained in practice, that are consistently applied and that prevent discrimination and bias, other than explicit affirmative action." It should be noted that standard 7.2.1 is not explicit in its requirements for a review of the MCAT score and is silent regarding the number of times a student has taken the exam. The country discusses and provided additional information from the Sydney Medical School explaining how their processes follow the procedures outlined in standard 7.2.1. The country has also included documentation (an AMC reaccreditation report) that demonstrates the AMC’s review of an institution’s compliance with its standards. While it is clear that the AMC applies its standard, it is also clear the standard does not specifically address this guideline. As noted previously there is no specific requirement or guidance for reviewing MCAT scores as part of the decision to admit students related to standard 7.

NCFMEA may wish to request additional information from AMC regarding if it plans to adopt policy to specifically address this guideline.
 
Country Response
No further response
 
Analyst Remarks to Response
The country has no further response on this section. To that end, Department Staff wishes to reiterate that the AMC has no specific requirement or guidance for reviewing MCAT scores as part of the decision to admit students related to standard 7.

NCFMEA may wish to request additional information from AMC regarding if it plans to adopt policy to specifically address this guideline.
 
Staff Conclusion: Additional Information requested
 
Admissions, Recruiting, and Publications, Question 2
 
Country Narrative
Question b(i)

Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The relevant accreditation standards are:

7.2.1 The medical education provider has clear selection policy and processes that can be implemented and sustained in practice, that are consistently applied and that prevent discrimination and bias, other than explicit affirmative action.
7.2.2 The medical education provider has policies on the admission of students with disabilities and students with infectious diseases, including blood-borne viruses.
7.2.3 The medical education provider has specific admission, recruitment and retention policies for Aboriginal and Torres Strait Islander peoples and/or Maori.
7.2.4 Information about the selection process, including the mechanism for appeals is publicly available.


Question b (ii)

Admission requirements are not specified nationally. Each medical education provider is able to establish their own admission standards, provided they are in accordance with the Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012 (APPENDIX 10).
As the response to question 1 in this section indicates, in practice a limited range of selection methods are used: GAMSAT and UMAT are the most common - for graduate medical schools, prospective students sit the Graduate Medical School Admissions Test (GAMSAT - https://gamsat.acer.edu.au/). The UMAT is the Undergraduate Medicine and Health Sciences Admissions test, used to assist with the selection of students into the medicine, dentistry and health science degree programs (https://umat.acer.edu.au/). Medical schools also use a combination of results in previous studies (the grade point average in university of college studies) or high school results, and most, but not all use interviews as an additional selection method.

While medical schools set slightly different entry requirements, entry to any medical course in Australia and new Zealand is very competitive, and students meeting only the minimum stated requirements for any program are unlikely to meet the competitive requirements for selection.


Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
 
Analyst Remarks to Narrative
AMC has provided additional information regarding the admissions committee at the institution. The narrative explains that the committee does report to governance regarding these decisions and that the site team does meet with the committee as part of its assessment. AMC has provided documentation of the site visit demonstrating a review of this committee. However there have not been formal standards developed by the AMC for this criterion.

NCFMEA may wish to request additional information from AMC regarding if they intend to develop standards for this criterion.
 
Analyst Remarks to Response
AMC has provided additional information regarding the admissions committee at the institution. The narrative explains that the committee does report to governance regarding these decisions and that the site team does meet with the committee as part of its assessment. AMC has provided documentation of the site visit demonstrating a review of this committee. However there have not been formal standards developed by the AMC for this criterion.

NCFMEA may wish to request additional information from AMC regarding if they intend to develop standards for this criterion.
 
Staff Conclusion: Additional Information requested
 
Admissions, Recruiting, and Publications, Question 3
 
Country Narrative
Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The relevant standards are:
7.1.1 The medical education provider has defined the size of the student intake in relation to its capacity to adequately resource the medical program at all stages.
7.2.1 The medical education provider has clear selection policy and processes that can be implemented and sustained in practice, that are consistently applied and that prevent discrimination and bias, other than explicit affirmative action.
While the accreditation standards do not explicitly require the medical school to manage admissions through an admissions committee, this structure is common in Australian and new Zealand medical schools.

In an accreditation visit, the AMC accreditation team meets the admissions committee to discuss the policy, weightings for the various selection methods used, research into the appropriateness of the methods used, and selection and training of interviewers (if interviews are used) as well as its authority and reporting lines to the Dean and the central university.

Please see APPENDIX 21: Sample accreditation report – standard 7 student selection, which shows the range of matters concerning selection covered in an accreditation report.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 21: Sample accreditation report – standard 7 student selection
 
Analyst Remarks to Narrative
As stated in the country's narrative, the country does not have a specific standard for selection and admissions of new and transfer students for medical school. ACM does include in its standards (appendix 10) Standard 7 specifies the review is established by the medical education provider. The country further articulates in its narrative that the onsite team meets with the admissions committee to discuss the selection methods utilized for admission. It is not clear based on the documentation if this committee includes faculty members, as required by this guideline.

NCFMEA may wish to request further clarification regarding whether the AMC has plans to develop a standard to specifically address this guideline. In addition, NCFMEA may wish to request information about the existence of an admissions committee and if so, the composition of its members.
 
Country Response
As the sample reaccreditation report at Appendix 24 (section 1.2 page 17) and the extract from the Accreditation report at Appendix 21 (section 7.2) show, an admissions committee is typically part of the governance structure of a medical school and the AMC accreditation reports do comment on the existence and role and/or reporting lines of the Committee Appendix 26, which is the sample accreditation site visit schedule shows that the AMC accreditation teams meet with the admissions committee (see page 4 of the schedule) as part of their assessment..
 
Analyst Remarks to Response
AMC has provided additional information regarding the admissions committee at the institution. The narrative explains that the committee does report to governance regarding these decisions and that the site team does meet with the committee as part of its assessment. AMC has provided documentation of the site visit demonstrating a review of this committee. While they're are not formal standards by the AMC, this information demonstrates that admissions information is regularly reviewed for appropriateness.
 
Staff Conclusion: Comprehensive response provided
 
Admissions, Recruiting, and Publications, Question 4
 
Country Narrative
Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. Medical schools provide an accreditation submission the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set. The conditions set by the AMC for this standard are provided in an appendix as evidence that the AMC assesses against these standards.

The relevant accreditation standard is:

7.1.1 The medical education provider has defined the size of the student intake in relation to its capacity to adequately resource the medical program at all stages.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
 
Analyst Remarks to Narrative
The AMC standards (appendix 10) outline the requirements and considerations for determining the appropriateness of size and qualifications of the entering class. Specifically, standard 7.1.1 requires the medical education provider to determine the size of the student intake in relation to its capacity to adequately resource the medical program at all stages. However, no documentation was included that demonstrates the AMC review of an institution relative to this guideline.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The extract from an accreditation report provided at Appendix 21 shows an AMC team's assessment against these accreditation standards.

The list of conditions placed on the accreditation of medical schools (Appendix 11) shows instances where the AMC has found medical schools did not meet these accreditation standards. Under Standard 7.1.1, there are two instances of conditions being set for noncompliance with these standards:

Condition 1 requires evidence by 2014 that the School is monitoring the implications of the increased student load, and has measures to accommodate the resourcing of the various teaching sites to meet the needs of such a large cohort of students, including facilities and teaching resources for nearly 550 students in each of Years 1 and 2

Condition 2 requires evidence that the size of the student intake is aligned to resources available to deliver the Program.
 
Analyst Remarks to Response
AMC has standards (appendix 10) that explain the medical provider must explain additional information regarding the appropriateness of size and qualifications of the entering class. AMC has provided documentation (exhibit 11 and 14) of the review that demonstrates how this determination is made.
 
Staff Conclusion: Comprehensive response provided
 
Admissions, Recruiting, and Publications, Question 5
 
Country Narrative
See APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The following standards are relevant:
3.4 The medical education provider has developed and effectively communicated specific learning outcomes or objectives describing what is expected of students at each stage of the medical program.
7.2.4 Information about the selection process, including the mechanism for appeals is publicly available.

There are additional requirements placed on universities as part of the quality assurance processes for higher education providers. The National Higher Education Standards Framework (APPENDIX 15) for example specify the university’s responsibility to its students. Section 6of the standards requires “The higher education provider must document its responsibilities to students and meets its responsibilities to students, including through the provision of information, support and equitable treatment.” The specific requirements under this standard include:
6.1 Prior to enrolment and during their studies, all students are informed about their relationship with the higher education provider, which includes:
• any contractual arrangements;
• the obligations of the higher education provider; and,
• the rights and obligations of the student.

6.2 All students have ready access to information about all charges, conditions, refunds, and costs involved in studying with the higher education provider, including course-specific costs and tuition assurance arrangements.

6.3 The higher education provider and its agents and other entities with which it has arrangements for the delivery of a course of study provide current, accurate, adequate, and openly accessible information for prospective and enrolled students on all matters relating to their studies for higher education awards offered by the higher education provider, including information on:
• the higher education provider offering the higher education award and the higher education awards that will be awarded for each course of study;
• the higher education provider’s registration status and the accreditation status of each course of study;
• formal recognition of each course of study by professional bodies;
• structure, credit points and duration or volume of learning for each course of study;
• admission criteria, recognition of prior learning and credit and articulation to and from other studies;
• content and assessment for each unit in the course of study;
• when and where the course of study will be offered, including the units that will be offered in any teaching period; and,
• availability of student support.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
APPENDIX 15: Higher Education Standards Framework (Threshold Standards) 2011
 
Analyst Remarks to Narrative
AMC standards (appendix 10). The standards require clear communications about learning outcomes, selection processes, and the rights and obligations of the students. While the AMC has several standards relative to this guideline, It has not provided documentation of the application of its standards

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The AMC has provided an extract from a site visit report that demonstrates that these matters are addressed (Appendix 46).
 
Analyst Remarks to Response
AMC has standards (appendix 10) that explain the medical provider must explain additional information regarding the use of school catalogs, publications, and other relevant materials. AMC has provided documentation (exhibit 10) of the review that demonstrates how this information is reviewed.
 
Staff Conclusion: Comprehensive response provided
 
Admissions, Recruiting, and Publications, Question 6
 
Country Narrative
Yes.

The AMC standards do not cover privacy requirements as state or national legislation applies. In general, each University allows students access to their academic records in accordance with legislation in that state and its own procedures.

Universities in Australia are subject to the relevant state or territory legislation or in New Zealand the Privacy Act 1993. Universities must state on their website how they manage student information, who has access to information and how the information is collected, stored and disposed of.

The University of Otago for example indicates:

“Information will be stored on University files and databases and all practicable security measures will be maintained. A unique identifier will be assigned to each student, which will be used in conjunction with a secondary means of identification or password/PIN.

Staff members and other personnel within the University or within agencies under contract to the University will have access to students’ personal information for purposes relevant to normal University operations including but not limited to: admission, enrolment, study, academic progress, tuition fees and charges, establishing and maintaining academic and graduation records, assessment, academic agreements (exchange and study abroad partners, scholarship providers or sponsors, programme delivery partners), academic advice and support, student services, discipline, security and safety, Library and IT services, managing students’ association membership and records, managing records of graduates, and other alumni, and managing and improving the quality of services provided by the University.

In order to conduct its proper business and as required under the Education Act 1989 and other laws, regulations, and contractual agreements by which it is bound, the University may use the student information it holds and may disclose information to external agencies such as government departments, bodies responsible for course moderation and professional accreditation or membership, agencies for financial support and pastoral care, and university student and alumni associations.
A list of agencies is provided..

Information provided to external agencies is either student-specific (typically name, date of birth, current contact details and academic or graduation details) or cohort-specific (aggregated or statistical information that does not identify individuals).
Where provision or disclosure of information is voluntary or falls outside the scope of information that the University is permitted to collect, store, use and disclose under the Privacy Act 1993, students will be advised and their consent will be obtained prior to the provision or disclosure of information.

The University will make information held about students available to them upon request and in accordance with the Privacy Act 1993, which also describes the conditions under which information may be withheld. Students have the right to request correction of personal information held in accordance with the provisions of the Privacy Act 1993. If a student withholds information or provides incomplete, false or misleading information the University may decline or cancel the admission or enrolment and may withhold the academic record if its veracity cannot be confirmed.”
See http://www.otago.ac.nz/administration/privacy/otago034437.html

As an example of an Australian Medical school, Sydney Medical School states that personal information collected by the University is handled in accordance with the Privacy and Personal Information Protection Act 1998 and the Health Records and Information Privacy Protection Act 2002. The School has a Privacy Management Plan, that outlines that the University provides access to students to their personal records, without the need to invoke the formal procedures of the legislation.
The Academic Board’s Assessment Procedure 2011 provides students with rights of access to their exam scripts. Students may see their student file by application for access with a week’s notice. For other personal information such as special consideration or disciplinary proceedings, students may apply for access formally (Ref: http://sydney.edu.au/privacy-policy.html. )

The University of Queensland (Ref: https://www.uq.edu.au/rti/access-information-outside-right-information-act) has procedures relevant to Queensland legislation: for example the Right to Information Act 2009. The University’s Right to Information Procedures provide relevant information.
 
Analyst Remarks to Narrative
AMC does not have specific standards relative to this guideline. The information provided indicates that each medical provider allows students access to their academic records in accordance with legislation in that state and its own procedures. The agency includes examples of these policies from the Sydney Medical School and the University of Queensland

Addition information requested: Department. Staff request additional information is provided for the NCFMEA regarding whether the AMC has any plans to establish written policy to address this question.
 
Country Response
No additional response from the AMC.
 
Analyst Remarks to Response
In response to the draft analysis, AMC provided no additional information.

Department Staff would like to reiterate that AMC does not have specific standards relative to this guideline. The information provided indicates that each medical provider allows students access to their academic records in accordance with legislation in that state and its own procedures. The agency includes examples of these policies from the Sydney Medical School and the University of Queensland

Addition information requested: Department Staff request additional information is provided for the NCFMEA regarding whether the AMC has any plans to establish written policy to address this question.
 
Staff Conclusion: Additional Information requested
 
Student Achievement, Question 1
 
Country Narrative
See APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

Standard 5 details the assessment requirements of medical schools. Specifically, Standards 5.1 and 5.2:
5.1.1 The medical education provider’s assessment policy describes its assessment philosophy, principles, practices and rules. The assessment aligns with learning outcomes and is based on the principles of objectivity, fairness and transparency.
5.1.2 The medical education provider clearly documents its assessment and progression requirements. These documents are accessible to all staff and students.
5.2.1 The medical education provider assesses students throughout the medical program, using fit for purpose assessment methods and formats to assess the intended learning outcomes.
5.2.2 The medical education provider has a blueprint to guide the assessment of students for each year or phase of the medical program.
5.2.3 The medical education provider uses validated methods of standard setting.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
 
Analyst Remarks to Narrative
AMC standards (appendix 10) prescribe learning outcomes, assessments, and progression requirements. However, no documentation was included that demonstrates a review of the AMC standards relative to this question.

NCFMEA may wish to request documentation that shows how the onsite inspection team reviews the institution's goals for compliance under this guideline.
 
Country Response
Appendix 24, which is a sample reaccreditation report, shows an assessment against these standards. Section 5of the report, on student assessment, is relevant.

The document at Appendix 11, which lists all the conditions the AMC has placed on medical schools' accreditation for noncompliance with standards in the period July 2010 to December 2015, shows that the AMC has set conditions relating to assessment policies, methods, performance feedback, and assessment quality.
 
Analyst Remarks to Response
AMC has standards (appendix 10) that explains the review of student assessment information at the institution. AMC has provided documentation (exhibit 11) of the review that demonstrates how this information is reviewed for compliance relative to this guideline. Specifically evaluated by the site team visitors are assessments made relative to quality, approach, feedback, and methods of assessment at the institution.
 
Staff Conclusion: Comprehensive response provided
 
Student Achievement, Question 2
 
Country Narrative
See APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

Question h (i)
Standard 5 details the assessment requirements of medical schools. The relevant accreditation standard are:

5.2.1 The medical education provider assesses students throughout the medical program, using fit for purpose assessment methods and formats to assess the intended learning outcomes.
5.2.2 The medical education provider has a blueprint to guide the assessment of students for each year or phase of the medical program.

The glossary to the accreditation standards indicates that asessment includes both summative assessment, for judgements about progression, and formative assessment, for feedback and guidance. Contemporary approaches to assessment in medical education emphasise a programmatic approach where multiple measures of students’ knowledge, skill and abilities over time are aggregated to inform judgments about progress. Assessment programs are constructed through blueprints which match assessment methods with outcomes. The strength of an assessment program is judged at the overall program level not on the psychometric properties of individual instruments.

The explanatory notes to the accreditation standards (currently under review) also indicate that "The AMC considers it important that clinical examinations, whether on real or simulated patients, form a significant component of the overall process of assessment of the clinical disciplines. They provide an incentive to students to learn relevant knowledge and skills. Clinical examinations should include an assessment of student ability to recognise abnormal clinical findings (and their distinction from normal) and the ability to provide an appropriate interpretation of these findings. The AMC also encourages medical schools to utilise direct observation of student performance in in-training or other forms of clinical assessment."

Question h (ii)
Neither Australia or New Zealand have not set national requirements by which medical schools are to evaluate student achievement. Medical schools are free to establish their own methods of student evaluation (referred to as assessment in Australia and New Zealand), consistent with AMC standards. However, as noted in the previous response, the accreditation standards for medical programs require fit for purpose assessment, which is expected to include both formative and summative assessment, a programmatic approach to assessment, and assessment of students’ clinical experience and skills.

In the AMC accreditation process, the adequacy of assessment methods is reviewed by reference to the medical school’s assessment standard-setting procedures, student pass rates, and internal and external reviews of examinations.

Students completing AMC accredited courses are not required to sit any national examinations for medical registration.
Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
 
Analyst Remarks to Narrative
The country states in its narrative, that it sets no national requirements by which medical schools must evaluate student achievement, but rather, student achieve measures are established by each medical school. The AMC conducts a review of the established student achievement requirements as part of the accreditation process. Items considered in that review includes standard-setting procedures, student pass rates, and internal and external reviews of examinations of the school.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline and to explain who conducts these reviews.
 
Country Response
The sample reaccreditation report at Appendix 24 (section 5) details an assessment by an AMC team against which shows the AMC's assessment of a school's processes for setting their methods for evaluating student achievement. The new appendix (Appendix 41) shows an example of an AMC assessment where a medical school's processes where initially found to be deficient, and a follow up AMC assessment was undertaken within three years to ensure that areas of non compliance were addressed.

 
Analyst Remarks to Response
AMC has standards (appendix 10) that explains the review of student assessment information at the institution. AMC has provided documentation (exhibit 11) of the review that demonstrates how this information is reviewed for compliance relative to this guideline. Specifically evaluated by the site team visitors are assessments made relative to quality, approach, feedback, and methods of assessment at the institution. In addition, if a medical provider is not meeting the standards are determined to be deficient, AMC has provided documentation to ensure noncompliant items are addressed.
 
Staff Conclusion: Comprehensive response provided
 
Student Achievement, Question 3
 
Country Narrative
See APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.

The relevant accreditation standards are:
5.2.1 The medical education provider assesses students throughout the medical program, using fit for purpose assessment methods and formats to assess the intended learning outcomes.
5.3.1. The medical education provider has processes for timely identification of underperforming students and implementing remediation.
5.3.2 The medical education provider facilitates regular feedback to students following assessments to guide their learning.
7.4.1 The medical education provider has policies and procedures for managing medical students whose impairment raises concerns about their fitness to practise medicine.
7.4.2 The medical education provider has policies and procedures for identifying and supporting medical students whose professional behaviour raises concerns about their fitness to practise medicine or ability to interact with patients.

In the AMC accreditation process, the adequacy of assessment methods is reviewed by reference to the medical school’s assessment standard-setting procedures, student pass rates, and internal and external reviews of examinations. The AMC separately examines standards relating to assessment of fitness to practise (under accreditation standard 7

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
 
Analyst Remarks to Narrative
The AMC has requirements embedded throughout its standards for continual assessment of student performance throughout the medical school program. The standards require facilitating feedback, identifying underperforming students, and supporting those who exhibit professional behavior concerns. However, no documentation was included that demonstrates a review of these standards.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The AMC has provided an new document (Appendix 41) which is an extract from an accreditation report showing assessment of a medical program against these standards. The report shows assessment over two team visits, with the first commentary identifying areas of non compliance with the standards and the second commentary showing a return team's assessment of progress in areas where concerns had been addressed.

The list of accreditation conditions provided at Appendix 11, shows all the instances where the AMC set conditions on accreditation for non compliance with these standards in the period July 2010 to December 2015 (see conditions listed under standard 5).
 
Analyst Remarks to Response
AMC has standards (appendix 10) that explains the review of student assessment information at the institution. AMC has provided documentation (exhibit 11 and 5) of the review that demonstrates how this information is reviewed for compliance relative to this guideline. Specifically evaluated by the site team visitors are assessments made relative to quality, approach, feedback, and methods of assessment at the institution. In addition, the site visit report demonstrates that reviews of students are conducted both during the academic portion and clinical portion of their medical programs.
 
Staff Conclusion: Comprehensive response provided
 
Student Achievement, Question 4
 
Country Narrative
Medical education providers are not required to meet set student performance outcome measures. They are required to benchmark however. See APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. The relevant accreditation standards are:

6.1.3 The medical education provider collaborates with other education providers in monitoring its medical program outcomes, teaching and learning methods, and assessment.
Standard 6.2 relates to outcome evaluation.

In their accreditation submission, the medical school seeking accreditation must provide the following information in relation to this accreditation standard:

• Provide a summary of collaborative links with other institutions nationally and internationally and describe the nature of those links, student exchanges, staff exchanges, and research.
• Describe any formal benchmarking and collaboration in the area of assessment of student performance, the outcomes and the way the data and information gathered is being used.
• Outline approaches to compare the provider’s curriculum with other programs of study and summarise any curriculum changes made or planned as a result.

(see Appendix 17 section 6.1)

Together, this information allows the AMC to confirm that the medical school meet this accreditation standard. The list of accreditation conditions the AMC has set on the accreditation of medical programs shows that evaluation, and specifically gathering data to inform evaluations has been a key area in these accreditations.
Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of Accreditation Conditions from Medical School Assessments, July 2010 to December 2015
APPENDIX 17: Reaccreditation Submission Guide 2016
 
Analyst Remarks to Narrative
The AMC’s standard 6.1.3, requires that the medical school must collaborates with other education providers in monitoring its medical program outcomes, teaching and learning methods, and assessment. The AMC also requires the reporting of these outcomes in order to maintain accreditation. However, while the country has standards for collecting this information, they have not demonstrated the actual collection and assessment of student outcomes information.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The AMC has provided an new document, at Appendix 40, which provides extracts from four accreditation reports which shows the AMC's assessment of medical programs against these standards. Two extracts show schools which were commended for good practice in their evaluation processes, and two of the extracts relate to assessments where conditions were set to ensure schools complied with these standards.

Some of the extracts refer to the Medical Schools Outcomes Database (MSOD) this is a database set up by all medical schools, to survey students at points through out their medical school training and again in their early years after graduation to determine students career intentions prior to graduation and career destinations after graduation. Graduates are also surveyed about the adequacy of the medical school training for medical practice. Medical schools provide evidence from the MSOD database as p[art of their accreditation submission to the AMC.
 
Analyst Remarks to Response
AMC has standard 6.1.3, that states the medical education provider collaborates with other education providers in monitoring its medical program outcomes, teaching and learning methods, and assessment. AMC has provided documentation (appendix 40) that demonstrates how the information is reviewed for compliance relative to this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Student Achievement, Question 5
 
Country Narrative
Please refer to Appendix 10: Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012. The relevant standards are:

6.1.2 The medical education provider systematically seeks teacher and student feedback, and analyses and uses the results of this feedback for monitoring and program development.
6.3.2 The medical education provider makes evaluation results available to stakeholders with an interest in graduate outcomes, and considers their views in continuous renewal of the medical program.
7.5.1 The medical education provider has formal processes and structures that facilitate and support student representation in the governance of their program.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
 
Analyst Remarks to Narrative
AMC standards specify that student's feedback is collected and reviewed to evaluate and monitor the quality of the medical program. This information is shared with stakeholders and is also used to make adjustments to the medical program. However, the country has not provided any documentation demonstrating the actual collection and assessment of this information.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline and to explain who the stakeholders that it shares this information with are.
 
Country Response
The sample accreditation report provided as Appendix 24 shows an AMC team's assessment of a school against these standards - see sections 6 and 7 of the report.
 
Analyst Remarks to Response
AMC has standards that require the collection of feedback for quality assurance of the program. AMC has provided documentation (appendix 24) that demonstrates how the site visit team reviews information for compliance relative to this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Student Services, Question 1
 
Country Narrative
Please refer to Appendix 10: Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012. The relevant standards are:

7.3.1 The medical education provider offers a range of student support services including counselling, health, and academic advisory services to address students’ financial social, cultural, personal, physical and mental health needs.
7.3.2 The medical education provider has mechanisms to identify and support students who require health and academic advisory services, including:
• students with disabilities and students with infectious diseases, including blood-borne viruses.
• students with mental health needs
• students at risk of not completing the medical program
7.3.3 The medical education provider offers appropriate learning support for students with special needs including those coming from under-represented groups or admitted through schemes for increasing diversity.
7.3.4 The medical education provider separates student support and academic progression decision making.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
 
Analyst Remarks to Narrative
The Standards (appendix 10) (specifically standards 7.3.1-4) discuss the requirements for institutions to provide counseling and guidance services, student health resources, financial and budgeting support, and confidential psychological counseling.
 
Student Services, Question 2
 
Country Narrative
Note this response is the same as that provided in f above.

The AMC standards do not cover privacy requirements as there is privacy legislation in all states and territories in Australia, as well as national legislation. In general, each University allows students access to their academic records in accordance with legislation in that state and its own procedures.
Universities are subject to the relevant state or territory or in New Zealand the Privacy Act 1993. Universities must state on their website how they manage student information, who has access to information and how the information is collected, stored and disposed of.

The University of Otago for example indicates:
“Information will be stored on University files and databases and all practicable security measures will be maintained. A unique identifier will be assigned to each student, which will be used in conjunction with a secondary means of identification or password/PIN.
Staff members and other personnel within the University or within agencies under contract to the University will have access to students’ personal information for purposes relevant to normal University operations including but not limited to: admission, enrolment, study, academic progress, tuition fees and charges, establishing and maintaining academic and graduation records, assessment, academic agreements (exchange and study abroad partners, scholarship providers or sponsors, programme delivery partners), academic advice and support, student services, discipline, security and safety, Library and IT services, managing students’ association membership and records, managing records of graduates, and other alumni, and managing and improving the quality of services provided by the University.
In order to conduct its proper business and as required under the Education Act 1989 and other laws, regulations, and contractual agreements by which it is bound, the University may use the student information it holds and may disclose information to external agencies such as government departments, bodies responsible for course moderation and professional accreditation or membership, agencies for financial support and pastoral care, and university student and alumni associations.
A list of agencies is provided …
Information provided to external agencies is either student-specific (typically name, date of birth, current contact details and academic or graduation details) or cohort-specific (aggregated or statistical information that does not identify individuals).
Where provision or disclosure of information is voluntary or falls outside the scope of information that the University is permitted to collect, store, use and disclose under the Privacy Act 1993, students will be advised and their consent will be obtained prior to the provision or disclosure of information.
The University will make information held about students available to them upon request and in accordance with the Privacy Act 1993, which also describes the conditions under which information may be withheld. Students have the right to request correction of personal information held in accordance with the provisions of the Privacy Act 1993. If a student withholds information or provides incomplete, false or misleading information the University may decline or cancel the admission or enrolment and may withhold the academic record if its veracity cannot be confirmed.”
See http://www.otago.ac.nz/administration/privacy/otago034437.html

As an example of an Australian Medical school, Sydney Medical School states that personal information collected by the University is handled in accordance with the Privacy and Personal Information Protection Act 1998 and the Health Records and Information Privacy Protection Act 2002. The School has a Privacy Management Plan, that outlines that the University provides access to students to their personal records, without the need to invoke the formal procedures of the legislation.
The Academic Board’s Assessment Procedure 2011 provides students with rights of access to their exam scripts. Students may see their student file by application for access with a week’s notice. For other personal information such as special consideration or disciplinary proceedings, students may apply for access formally (Ref: http://sydney.edu.au/privacy-policy.html. )

The University of Queensland (Ref: https://www.uq.edu.au/rti/access-information-outside-right-information-act) has procedures relevant to Queensland legislation: for example the Right to Information Act 2009. The University’s Right to Information Procedures provide relevant information.
 
Analyst Remarks to Narrative
The country states in its narrative that the AMC does not have specific standards relative to this guideline. The country notes that each medical provider allows students access to their academic records in accordance with legislation in that state and its own procedures. Examples of these policies from the Sydney Medical School and the University of Queensland have been provided.
 
Student Complaints, Question 1
 
Country Narrative
Question n (i)

Yes.

Under the Higher Education Standards (APPENDIX 15), universities are required to make complaints processes available to students.

6.4 Students have ready access to effective grievance processes, which enable them to make complaints about any aspect of the higher education provider’s higher education operations, including operations provided by other entities on behalf of the higher education provider, without fear of reprisal, and which provide for review by an appropriate independent third party if internal processes fail to resolve a grievance.

In addition, the Australian Medical Council’s Procedures for Accreditation (APPENDIX 4) outline the process by which students and other stakeholders are able to raise concerns or make a complaint about an accredited medical program and medical schools. The AMC complaints process indicates that the AMC does not have a role in investigating the complaints of individual students, staff or trainees to address grievances relating to matters such as selection, recognition of prior learning/experience, assessment outcomes, or dismissal from the program. The accreditation standards require education providers accredited by the AMC to have processes for addressing grievances, complaints and appeals, and the AMC reviews these processes when conducting an accreditation assessment. The AMC complaints process permits students and others to raise concerns that might indicate an accreditation standard is not being met.

Question n (ii)
To meet the requirements of the Higher Education Standards Framework, universities have detailed complaints policies. An example of a detailed Australian complaints policy is the Flinders University policy:

http://www.flinders.edu.au/current-students/policies-procs/rights/student-appeals-complaints-and-grievances.cfm

The policy outlines the complaints process, lists other organisations that might be relevant to a complaint, and describes the University appeals committee

An example of a detailed policy in New Zealand, the University of Auckland policy is referenced: https://cdn.auckland.ac.nz/assets/central/about/the-university/how-the-university-works/policy-and-administration/Supervision/resolution-of-student-academic-complaints-and-disputes-statute.pdf

The policy details informal and formal complaints mechanisms available to students.

APPENDIX 4: Procedures for the Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015
APPENDIX 15: Higher Education Standards Framework (Threshold Standards) 2011
1
 
Analyst Remarks to Narrative
The country stipulates standards for student complaints in its Higher Education Standards Framework (Threshold Standards) 2011. Institutions must have written policies for student grievances. The country has included an example of an Australian complaint policy at one of its institutions.
 
Student Complaints, Question 2
 
Country Narrative
Yes, the AMC does investigate systemic complaints, which may indicate that accreditation standards are requirements are not being met. Please refer APPENDIX 4: Procedures for the Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015

The complaints policy is available on the Australian Medical Council website. http://www.amc.org.au/accreditation/complaints

In addition, there is a medical student member on the Australian Medical Council, and a medical student member of the AMC Medical School Accreditation Committee, the body which governs the accreditation process. Through their links the with the Australian and New Zealand Medical Students Associations, and the AMC staff's regular briefing of the executive of these organisations, information about these complaints processes is circulated.

The AMC has investigated three complaints concerning medical schools in the last twelve months, only one of which was submitted by a medical student. The complaint submitted by the medical student was found to be outside the AMC complaints process, since it did not provide evidence of a systemic matter.
 
Analyst Remarks to Narrative
The AMC has standards for developing effective complaint policies and it appears that AMC has received complaints from students. The narrative has noted the receipt of three complaints during the last 12 months. The one submitted by a medical student was determined to be out of scope. The AMC has provided a link to its website where it publishes its complaint policy and contact information to assist anyone when filing complaints.
 
Finances, Question 1
 
Country Narrative
Medical schools in Australia and New Zealand are funded through a combination of government payments for supported places, funding from student fees, endowments, and research grants.

Private medical schools are permitted in Australia. The standards are the same as for other medical schools. There is one private medical school in Australia. It is part of a registered and approved University which, like other universities in Australia is established by an act of parliament and subject to higher education provider quality assurance processes. Private medical schools are required to meet the same accreditation standards for medical programs as government-funded schools.

Medical schools must also be able to demonstrate that their educational objectives are supported by adequate financial resources, and that they are able to maintain high standards of medical education for the proposed period of AMC accreditation.

Please refer to Standards 1.5 in APPENDIX X: Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012.
Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012.
 
Analyst Remarks to Narrative
The country has provided information that there are both private and public medical schools that are funded dependent on the type of institution. AMC has standards that are the same no matter the type of medical school. Specifically, standard 1.5.3 requires that medical education providers must have the financial resources and financial management capacity to sustain its medical program." However, the country did not provide documentation that demonstrates the review for this standard.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The list of conditions set on medical schools (Appendix 11) shows all the areas where the AMC has set a condition on a medical school's accreditation for non compliance. As the sample accreditation report provided at Appendix 24 shows, conditions are set as part of the accreditation report. The list at APPENDIX 11 shows that the AMC has set conditions relating to these standards in six instances in the period 2010 to 2015:

Condition 1 under this standard required evidence of ongoing autonomy for budget and resource allocation to allow the objectives of the medical program to be achieved.

Condition 2 required evidence of plans for a funding model which enables resources to be directed to achieve overall MBBS Program objectives. The model should include a clear line of responsibility and authority for the curriculum and its resourcing.

Condition 3 requires that medical school to confirm its budget model for 2014, including necessary mechanisms for engagement of staff from Schools outside the Faculty

Condition 4 required that school to demonstrate the School has the ongoing financial resources and capacity to sustain the program.

Condition 5 required that medical school to demonstrate the School has the ongoing financial resources and capacity to sustain the program.

Condition 6 required that that medical school to clarify the proposed changes and quantify the impact to the funding of the program of financial constraints facing the university, combined with the introduction of an activity based funding model by the Department of Health, have the potential to have significant negative impacts on the medical program.

The extract from the sample accreditation report provided at Appendix 24 shows the assessment by an AMC team of a medical school's budget position. (See standard 1.5 pages 19 and 20)
 
Analyst Remarks to Response
AMC has standards that are the same no matter the type of medical school. Specifically, standard 1.5.3 states the medical education provider has the financial resources and financial management capacity to sustain its medical program. AMC has provided documentation (exhibit 11 and 12) that demonstrates how the country reviews financial resources of the institution and under the requirements of this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Facilities, Question 1
 
Country Narrative
Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012. The relevant accreditation standards are:

8.1 Physical Facilities
8.1.1 The medical education provider ensures students and staff have access to safe and well-maintained physical facilities in all its teaching and learning sites in order to achieve the outcomes of the medical program.

In the accreditation submission, medical schools are required to answer the following questions about their physical facilities (see section of the appended reaccreditation submission guide):

University facilities:
• Provide a summary of the medical education provider’s university-based physical facilities for education, including a statement on the current adequacy of lecture rooms, tutorial rooms and space for teaching.
• Provide a summary of the medical education provider’s university-based physical facilities for staff. Provide a statement on the adequacy of these spaces for staff activities and numbers.
• What are the university’s plans for expansion of these physical facilities in the next five years? Discuss how this aligns with the medical education provider’s growth in staff and student numbers.
• Describe briefly the mechanisms for review of physical resources of the education provider.
• Describe the governance structures that enable the education provider to respond appropriately to change in physical space requirements. Discuss any challenges the school education provider in this area.
• Briefly outline physical facilities that support student research.
Clinical site facilities:
• Briefly describe the physical facilities available at each clinical teaching site to cater for clinical education, student and staff accommodation and support.
• Critically discuss the adequacy of these facilities for current use and future developments.
• What authority does the medical education provider have to direct resources to respond to deficiencies? Indicate what plans exist for improving these facilities.

The AMC validates the information through a program of site visits to all major teaching facilities as part of the accreditation assessment.


Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 17: Reaccreditation Submission Guide 2016
 
Analyst Remarks to Narrative
AMC’s standards (appendix 10) stipulates that the "medical education provider ensures students and staff has access to safe and well-maintained physical facilities in all its teaching and learning sites in order to achieve the outcomes of the medical program." AMC verifies this information during the onsite inspection , however, no documentation of a review was included as documentation.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The list of conditions set on medical schools (Appendix 11) shows all the areas where the AMC has set a condition on a medical school's accreditation for non compliance. As the sample accreditation report provided at Appendix 24 shows, conditions are set as part of the accreditation report. The list at APPENDIX 11 shows that the AMC has set conditions relating to these standards in 10 instances in the period 2010 to 2015:

These demonstrate (see page 14 of the list conditions set relating to standard 8.1) where the AMC accreditation teams have identified, and the AMC has set conditions concerning: inadequate facilities at clinical sites, plans for capital development at clinical teaching sites; evidence of funding and confirmation of plans and timelines for redevelopment of facilities; evidence of facilities to manage a full student, including details regarding lecture, problem-based learning, lab, clinical skills and clinical coaching delivery, and availability of academic and clinical teaching staff; and evidence of adequate student common room facilities and audio visual resources in the problem-based learning tutorial rooms.

The AMC has provided a new attachment which shows its assessment over two accreditation assessments of a medical school whose facilities where found initially to be inadequate. This shows that these matters are addressed in accreditation reports, and that the AMC has processes for ensuring areas of non compliance are addressed.

 
Analyst Remarks to Response
AMC has standards that state that the medical education provider ensures students and staff have access to safe and well-maintained physical facilities in all its teaching and learning sites in order to achieve the outcomes of the medical program. AMC has provided documentation (appendix 11 and 39) that demonstrates how the country reviews the facilities and equipment at the institution and under the requirements of this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Facilities, Question 2
 
Country Narrative
Response to c
The AMC does not specify the facilities in this level of detail in the accreditation standards, but as the response to the previous question shows, medical schools are required to provide comprehensive information on their facilities.
The AMC assesses and monitors medical schools against the approved Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012. Medical schools provide an accreditation submission the AMC that addresses the accreditation standards. Where the accreditation standards are not met, the Health Practitioner Regulation National Law empowers the AMC to set conditions to lead to the standard being met in a reasonable timeframe (as defined by the AMC). The AMC reports instances where a specific standard is not met the Medical Board of Australia, and monitors through annual reports that schools meet the conditions set.

The document at Appendix 11, which lists the conditions set on the accreditation of programs where standards are not met, demonstrates that the AMC does consider facilities broadly, and sets conditions where these do not meet the standards.

Concerning research, the relevant accreditation standard is

1.7.1 The medical education provider is active in research and scholarship, which informs learning and teaching in the medical program.
Medical schools are expected to include research activity in the criteria for appointment of new staff (standard 1.9), and the AMC indicates that it is desirable that most academic staff be ‘research active’ and that all academic staff are seen to be involved in scholarly activities. The medical school is expected to demonstrate a commitment to research with appropriate resource allocation and infrastructure support

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 11: List of accreditation conditions 2010 to 2015
 
Analyst Remarks to Narrative
As previously stated, the AMC’s Standards provide in Appendix 10 stipulates that the "medical education provider ensures students and staff have access to safe and well-maintained physical facilities in all its teaching and learning sites in order to achieve the outcomes of the medical program." It should be noted that items (such as office space allocations) are not specifically written into the standards, but are considerations that are reviewed during the onsite inspection visit and/or through the annual reports. However no documentation was included verifying this information was reviewed.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline. In addition, the AMC needs to further explain if it plans to revise its policy to specifically address all of the requirements discussed in this guideline.
 
Country Response
The AMC has provided an new Appendix 39, which provides an assessment of a medical school over two accreditation assessments, where initially resources and facilities were found not to meet the accreditation standards and to require conditions on the school's accreditation.
 
Analyst Remarks to Response
AMC has standards that state that the medical education provider ensures students and staff has access to safe and well-maintained physical facilities in all its teaching and learning sites in order to achieve the outcomes of the medical program. AMC has provided documentation (appendix 39) that demonstrates how the country reviews the facilities are safe and well-maintained at the institution and under the requirements of this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Faculty, Question 1
 
Country Narrative
The AMC does not set specific requirements as to the size or qualifications of the academic staff body in medical faculties. However, schools are required to have a detailed staff plan that outlines the type, responsibilities and balance of academic staff required to deliver the curriculum adequately, including the balance between medical and non-medical academic staff, and between full-time and part-time staff.

In addition, a medical school must have an appropriate profile of administrative and technical staff to support the implementation of the school’s educational program and other activities, and to manage and deploy its resources.
Please refer to Standards 1.8 and 1.9 in APPENDIX X: Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012.

In the accreditation submission, medical schools seeking accreditation are required to provide detailed information about the staffing profile and the staff appointment and promotion policies (see section 1.9 of the attached Reaccreditation Submission Guide). Questions asked by the AMC include:

• Provide the numbers of funded (university) academic positions associated with the medical program, currently filled or vacant. Express these as full-time equivalent staff. Please also include numbers of administrative and technical staffing resources.
• Describe the strategies used by the education provider to ensure the staff profile (academic, administrative and technical) continues to match the range and balance of functions required to deliver the curriculum. Comment on the perceived sustainability of the current staffing profile and any plans to modify this in the coming period of accreditation.
• Describe any changes in the administrative and technical staffing structure. What administrative and technical support is provided by the medical education provider and/or university?
• Outline institutional or government requirements that affect the school’s staff resource decisions. Indicate how the medical education provider is addressing challenges created by these policies or requirements.
• Describe staffing arrangements for each clinical teaching site and how these interface with the medical education provider. N.B. Please note that details regarding clinical supervision are addressed at Standard 8.4.
• Comment on the education provider’s initiatives to recruit academic and support staff, particularly positions that are hard to recruit to, or areas that are under-staffed.
• Comment on the recruitment, training and support of Indigenous staff, stating the numbers of Indigenous academic, clinical academic and professional staff employed. N.B. The Medical Deans’ Indigenous Health Project’s Critical Reflection Tool at www.limenetwork.com.au refers to this standard.
• Describe the methods used to recruit, support, and train patients and community members formally engaged in planned learning and teaching activities.
• Provide a summary of the general role and duty allocations of joint hospital and academic appointments.
• What is the medical education provider’s policy for ensuring that teaching, research, curriculum development and service contributions are appropriately recognised and rewarded? Are there additional institutional or government policies? Describe any changes since the last AMC accreditation and any planned changes in the coming period of accreditation.
• Outline university policy and practice for academic, administrative and technical staff appointment and promotion, indicating how these have changed since the last accreditation and any plans for change in the coming period of accreditation. What performance appraisal procedures are in place, and how do these relate to staff promotion procedures?
• What staff development programs are available? How is participation by academic, administrative and technical staff in staff development programs encouraged? Comment specifically on programs to enable teachers, including clinical teachers, to upgrade their skills and to obtain appraisals of their teaching performance.
• Outline policy and practice for promotion of clinical title holders and those who hold joint appointments between the university and other bodies. Provide brief details on the policy on clinical duties required and the extent of private practice permitted for academic teaching staff.

The AMC validates the information through the program of meetings during the accreditation assessment, and through cross checking annual reports and handbooks, and the medical school’s website top check lists of staff and staff policies.

Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 17: Reaccreditation Submission Guide 2016
 
Analyst Remarks to Narrative
The AMC does not have specific requirements for size or qualifications of faculty members. However, it is explained that information is collected during the accreditation review at a detailed length to understand the faculty staffing plan and the example questions that help with understanding this topic are included in AMC's Reaccreditation Submission Guide. The country further explains that they monitor this information through assessments of the institutions websites, catalogs, and onsite inspections. However, no documentation of this resubmission by the institution or verification of the monitoring was included in this section.

Since the agency does not have a policy regarding this process, Department Staff is unable to attest to comparability in this section. NCFMEA may wish to request documentation that shows how information is consistently collected about the faculty qualifications and how the agency verifies the information, whether through assessments or onsite inspection team reviews of the institution.
 
Country Response
The sample reaccreditation report provided at Appendix 24 shows that the AMC does consider the nature of the academic staff in an accreditation assessment. Section 1 of the sample report provides an analysis of the adequacy of the staffing.

 
Analyst Remarks to Response
In response to the draft analysis, AMC has confirmed that they do review faculty qualifications during the onsite visit. (Exhibit 12). However, since there is no standard regarding the process, Department staff is unable to confirm how the country ensures consistency in this review and how the agency is able to verify that the information provided during the site visit is sufficient.

NCFMEA may wish to ask the country for more details regarding the process for reviewing the size and qualifications of faculty members.
 
Staff Conclusion: Additional Information requested
 
Faculty, Question 2
 
Country Narrative
The AMC does not currently have these requirements in its medical school accreditation standards. The AMC has just introduced a standard concerning the management of conflict of interest in education providers in its standards for the assessment and accreditation of specialist medical programs, and will introduce a similar standard for medical schools when those standards are next reviewed.

The standard it has introduced for specialist medical programs is as follows:

1.1.6 The education provider has developed and follows procedures for identifying, managing and recording conflicts of interest in its training and education functions, governance and decision-making.

See: http://www.amc.org.au/files/1fc718648287876af0478b09e431bd88d4d014f8_original.pdf
 
Analyst Remarks to Narrative
Stated in the country’s narrative, AMC does not currently have a standard for preventing conflict of interest of the faculty at the medical school. The narrative indicates that the AMC plans to introduce this during the next review.

NCFMEA may wish to request information regarding the timing of this suggested change and documentation that shows the language of the standard that will be created for compliance under this guideline.
 
Country Response
The AMC is completing a minor review of the accreditation standards later in 2016, and will be able to include this new standard at that stage. We expect the new standards to be finalised by early 2017.
 
Analyst Remarks to Response
In response to the draft analysis, AMC has provided additional information indicating that they are completing a minor review in 2016, and that they expect the information to be ready by 2017. However, since this information does not currently exist, Department staff is unable to verify conflict of interest information.

NCFMEA may wish to request for AMC to provide updated information of the progress that is being made to address having a standard for preventing conflict of interest.
 
Staff Conclusion: Additional Information requested
 
Library
 
Country Narrative
Question g (i)

Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012.
The relevant accreditation standards are:
8.2 Information Resources and Library Services
8.2.1 The medical education provider has sufficient information communication technology infrastructure and support systems to achieve the learning objectives of the medical program.
8.2.2 The medical education provider ensures students have access to the information communication technology applications required to facilitate their learning in the clinical environment.
8.2.3 Library resources available to staff and students include access to computer-based reference systems, support staff and a reference collection adequate to meet curriculum and research needs.

Question g (ii)

The graduate outcomes statements (see pages 1 to 4 of the accreditation standards) include the following relevant learning outcomes:

2.15 Retrieve, interpret and record information effectively in clinical data systems (both paper and electronic).
1.4 Access, critically appraise, interpret and apply evidence from the medical and scientific literature.



Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
AMC standards (appendix 10) require that each site has the sufficient availability of resources, sufficient office space, as well as trained staff, and access to library services. However, while the agency has standards relative to this guideline, they have not provided documentation demonstrating the application of this policy.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The AMC has provided an additional new appendix with an extract from an accreditation report regarding resources and facilities (Appendix 39), see Standard 8.2 on page 4-6
 
Analyst Remarks to Response
AMC has standards that state that each site has the sufficient availability of resources, sufficiency of space, as well as training and access to library services. AMC has provided documentation (appendix 39) that demonstrates how the country reviews the facilities (including libraries) at the institution and under the requirements of this guideline.
 
Staff Conclusion: Comprehensive response provided
 
Clinical Teaching Facilities, Question 1
 
Country Narrative
Please refer to APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the Australian Medical Council 2012.
The relevant accreditation standard is

1.6.1 The medical education provider has effective partnerships with health-related sectors of society and government, and relevant organisations and communities, to promote the education and training of medical graduates. These partnerships are underpinned by formal agreements.

Question h (i)

\The accreditation standards are usually accompanied by explanatory notes. As these are under review they are not included the accreditation standards provide with this submission. The notes concerning this standard indicate “Affiliation agreements between the university and hospital providers should address, at a minimum:
• assurance of student and staff access to resources for education
• the medical school’s authority over academic affairs and the education and assessment of students
• the role of the school in appointment of staff with teaching responsibilities
• specification of the responsibility for treatment and follow-up when students are exposed to infectious or environmental hazards
• indemnity arrangements for students. “

Question h (ii)

Formal agreements are approved by the senior officer of the university and the health service.

Question h (iii)

The AMC asks medical schools to submit progress reports structured according the accreditation standards. They must address any accreditation conditions relevant to the accreditation standard, report on any developments planned or undertaken relevant to the standards, including changes to the relationships with health services.


Documents:
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
 
Analyst Remarks to Narrative
AMC’s (appendix 10) standard 1.6.1 states "The medical education provider has effective partnerships with health-related sectors of society and government, and relevant organizations and communities, to promote the education and training of medical graduates. These partnerships are underpinned by formal agreements." AMC further articulates that there are affiliation agreements created for the university and hospital partners. However, while the agency has standards relative to this guideline, they have not provided documentation of the application of this policy.

NCFMEA may wish to request documentation (such as a site visit report) that would demonstrate the AMC’s review of an institution’s compliance with its standards relative to this guideline.
 
Country Response
The list of conditions placed on accreditation (Appendix 11) shows where the AMC has set accreditation conditions concerning affiliation agreements for noncompliance with this accreditation standard (see conditions set under standard 1.6).

The sample reaccreditation report provided at Appendix 24 (see section 1.6) gives an accreditation team's assessment of the formal agreements between a medical school and its partners, in this case saying these partnerships are excellent.

APPENDIX 42 shows the documentation a medical school has provided in response to these standards, including affiliation agreements.
 
Analyst Remarks to Response
AMC has standards that state that the medical education provider has effective partnerships with health-related sectors of society and government, and relevant organizations and communities, to promote the education and training of medical graduates. These partnerships are underpinned by formal agreements. AMC has also provided a screenshot as documentation from one of its medical schools displaying an affiliation agreement. However, the actual affiliation agreement must be uploaded to be included in the official record of documentation submitted with the agency’s comparability petition.

NCFMEA may wish to request the official copies of the documentation to verify the information in the affiliation agreement.
 
Staff Conclusion: Additional Information requested
 
Part 3: Accreditation/Approval Processes and Procedures
Onsite Review, Question 1
 
Country Narrative
Yes, the AMC requires on-site assessment visits for accreditation purposes. Section 3.3 (pages 14 to 20) of the Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 at APPENDIX 4 describe the typical accreditation assessment visit. The AMC schedules visits during the academic year. They usually last four to five days. More time may be required to visit dispersed training sites.

The purpose of conducting a thorough on-site assessment is to determine compliance with the AMC’s accreditation standards. The AMC structures the visit around the accreditation standards, which cover all the areas listed in this question.

Before the accreditation site visit, the medical school is required to submit an accreditation submission addressing the accreditation standards. The AMC uses this submission to help structure the accreditation site visit.

Approximately four months prior to the on-site assessment visit (shorter timeframe may apply for follow-up assessments), the AMC provides the education provider with a guide to assist in preparing its accreditation submission. This submission is the basis for the assessment. The guide outlines the requirement for self-assessment and critical analysis against the accreditation standards. The submission should also describe plans for future development and challenges identified by the provider. It should also provide detailed information on the structure, process and outcomes of the medical education program. The medical school may nominate specific areas for review. Different guides are provided for each form of assessment (reaccreditation assessment, new program assessment, follow-up review). A sample guide is provided as APPENDIX 17, but the full range of guides can be provided if required.

The AMC also invites the medical students’ association to make a submission to the AMC assessment team and provides guidance on the submission content (APPENDIX 22). The AMC asks for the student submission after the education provider has lodged its accreditation submission.

The AMC guidance to assessment teams (The Accreditation Handbook) is at APPENDIX 23.

A sample site visit report is at APPENDIX 24.

Documents
APPENDIX 4 The Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015
APPENDIX 17: Reaccreditation Submission Guide 2016
APPENDIX 22: AMC Student Submission Guide
APPENDIX 23: AMC Accreditation Handbook: The work of AMC accreditation assessment teams 2016
APPENDIX 24: Sample accreditation site visit report
 
Analyst Remarks to Narrative
The AMC has provided its accreditation protocol which outlines standards and procedures for reviewing a medical school and conducting an on-site review as part of the accreditation process. They have additionally provided documentation of a sample site visit report that demonstrates how they review institution’s under these standards. AMC asks that the institution conduct a self-assessment and utilizes this information, as well as student feedback to review during the visit.
 
Onsite Review, Question 2
 
Country Narrative
Yes on-site reviews encompass the main campus of the medical school, any branch campus or campuses, and any other additional location or locations operated by the medical school. AMC accreditation teams are responsible for developing a program of meetings and site visits appropriate to the provider’s structure, size, range of activities, and medical program with the education provider (see section 1.3 of the the Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 at APPENDIX 4). Australian Medical Council staff provide a guide to the school for developing the site visit program (see APPENDIX 25), and work with the staff of the medical school to ensure that the team can assess the program thoroughly against the accreditation standards and that the team will visit all appropriate locations.

In their accreditation submission, medical schools are required to provide information on each clinical teaching site (urban and rural, hospital and community) with a breakdown for each year of the numbers of students placed and in what departments/units, together with projected student numbers in these sites over each year of the coming period of accreditation. This assists the AMC staff to determine the clinical sites that must be visited. (see APPENDIX 17 section 8.3)
The AMC has provided an example of a site visit program to show that this requirement is met (APPENDIX 26).

Documents
APPENDIX 17: Reaccreditation Submission Guide 2016
APPENDIX 25: AMC Guide for accreditation visits
APPENDIX 26: Sample site visit program
 
Analyst Remarks to Narrative
The country states in its narrative that the AMC conducts a comprehensive review of core clerkship sites. The standards for these sites are included in the Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015. The institutions ability to comply with these standards is evaluated by the on-site inspection team. An example team report was included as documentation of this process. However, it is not clear from the documentation provided who is responsible for ensuring the quality of the clinical teaching sites.

NCFMEA may wish to request clarification on who has the responsibility for ensuring quality of the clinical teaching sites.
 
Country Response
Medical schools must have their own processes for deciding that a clinical teaching site is appropriate. In addition to setting their own expectations of clinical placements and facilities, they can draw on reports and accreditation status granted by other national standards organisations. In Australia there are national systems for accreditation of general practices which are set by the Royal Australian College of General Practitioners http://www.racgp.org.au/your-practice/standards/standards4thedition/

There are also national standards for accreditation of health services by the Australian Council on Healthcare Standards http://www.achs.org.au/ including accreditation against national standards for quality and safety in healthcare. http://www.safetyandquality.gov.au/our-work/accreditation-and-the-nsqhs-standards/. Similar processes apply in New Zealand.

The Australian Medical Council, in accrediting a medical school, considers the School's data on its evaluation of the quality of clinical teaching sites, and gathers student feedback on the quality of those sites.
 
Analyst Remarks to Response
In response to the draft analysis, the country has provided additional information about who has the responsibility for ensuring quality in the clinical sites. AMC has explained in the narrative that ultimately this responsibility resides with the medical school itself. There are a series of other entities that provide standards and AMC continues to conduct review of these sites.
 
Staff Conclusion: Comprehensive response provided
 
Onsite Review, Question 3
 
Country Narrative
When the AMC is assessing a medical program through an onsite assessment visit, members of the AMC accreditation assessment teams visit all important clinical training sites, that is, the sites that offer core clinical training. The sample site visit program for the assessment of the Flinders University medical program (provided at APPENDIX 26) shows the breadth of the site visits undertaken by AMC teams. As medical schools in Australia frequently have a rural clinical school or other clinical school at distance from the campus, the AMC has focussed attention on ensuring that the quality of the medical education and training at these dispersed sites is reviewed.

It has two accreditation standards (APPENDIX 10) relating to comparability of experience and assessment across teaching sites:
2.2.3 The medical program achieves comparable outcomes through comparable educational experiences and equivalent methods of assessment across all instructional sites within a given discipline.
5.4.2 The medical education provider ensures that the scope of the assessment practices, processes and standards is consistent across its teaching sites.
In addition to considering the medical school’s response to these standards in its accreditation submission, the AMC uses on site visits to assure itself that these standards are met.

The AMC has procedures relating to major changes in an accredited program (see 3.2.2 of the Procedures of Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 (APPENDIX 4). The definition of a major change includes “a substantial change in ….institutional setting”. As section 3.2. of the Procedures describes, the AMC expects to be told prospectively by medical schools of any such planned changes. Normally, this occurs through the regular progress reports that the AMC requires. If the AMC decides a major change is occurring, it can require a site visit.

The AMC ensures that it knows the major clinical teaching sites of each medical school by asking for the following documentation from them:

1. In accreditation submissions: A table for each clinical teaching site (urban and rural, hospital and community) with a breakdown for each year of the numbers of students placed and in what departments/units, together with projected student numbers in these sites over each year of the coming period of accreditation. (see APPENDIX 17 section 8.3)
2. In regular progress reports, information on changes to the clinical sites used by the medical school. (See APPENDIX 27 Standard 8)

Documents:
APPENDIX 4: Procedures of Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 17: Reaccreditation Submission Guide 2016
APPENDIX 26: Sample site visit program
APPENDIX 27: AMC Progress Report Guide
 
Analyst Remarks to Narrative
The country cites The AMC’s standards and accreditation/approval process which requires an on-site evaluation of all clinical clerkship sites. This includes those that have never been visited, those previously reviewed, and at all new sites. However, it is not clear based on the standards or narrative how often the review occurs. The AMC standards stipulate that "AMC accreditation entails a cyclical program of review of programs of study, and the AMC work program for any year is determined in part by the requirement to assess those programs whose accreditation expires in that year." The guideline for this section recommends that new sites are visited within 12 months.

NCFMEA may wish to request clarification about the timing of the onsite visit process, specifically the timeframe for the new sites that are established in the country.
 
Country Response
Accreditation assessments occur at least every 10 years. 10 years is the standards reaccreditation cycle for a medical program that has no major changes. However, a major change (such as a change in setting, including the additional of a new major clinical teaching site) would require a site visit before the teaching commences at the new site.

There has been little change in the sites used by medical schools for core clinical rotations that has required accreditation assessments outside the usual cycle of accreditation visits.



 
Analyst Remarks to Response
In response to the draft analysis, AMC has provided details about the timing of the onsite visit process, explaining that those visits occur at minimum every 10 years. It is not clear from the response how quickly new sites are visited. In adherence to the guideline, it is suggested that new sites are visited within 12 months.

NCFMEA may wish to ask for clarification regarding how soon new sites are visited once it id determined that they are candidates for accreditation.
 
Staff Conclusion: Additional Information requested
 
Onsite Review, Question 4
 
Country Narrative
The AMC does review formal agreements between medical schools and clinical teaching sites as part of its accreditation assessments. An accreditation standard specifically relates to this requirement (APPENDIX 10):

1.6.1 The medical education provider has effective partnerships with health-related sectors of society and government, and relevant organisations and communities, to promote the education and training of medical graduates. These partnerships are underpinned by formal agreements.
Medical schools are required to answer the following in their accreditation submissions (APPENDIX 17):

What formal relationships and agreements are in place to ensure effective communication and liaison between the university, the medical education provider and health care and research institutions affiliated with the university? Is the education provider represented on relevant boards and committees of these institutions? Are the institutions represented on the education provider’s committees? Summarise briefly any major developments since the last AMC accreditation and their impact and any plans for the coming period of accreditation. The response to these questions should cover:
o legal and financial dimensions of the relationships
o university and medical education provider input to governance and decision-making committees, including appointment committees
o health service input into university and medical education provider decision-making
o a summary of the formal agreements regarding consultations, joint appointments and standing committees
o the extent of responsibilities of academic staff within hospitals and the university.

Documents
APPENDIX 10: Standards for Assessment and Accreditation of Primary Medical Programs by the AMC 2012
APPENDIX 17: Reaccreditation Submission Guide 2016
 
Analyst Remarks to Narrative
The country states that the institutions in conjunction with the clinical clerkships site initiate formal affiliation agreements. ACCM assesses the agreements for compliance with the standards outlined in the Standards (appendix 10). However, the country has not provided sample documentation that showcases an affiliation agreement.

NCFMEA may wish to request documentation of an example affiliation agreement to document application of their standards.
 
Country Response
The list of conditions set on medical schools (Appendix 11) shows all the areas where the AMC has set a condition on a medical school's accreditation for non compliance. As the sample accreditation report provided at Appendix 24 shows, conditions are set as part of the accreditation report. The list at APPENDIX 11 shows that the AMC has set conditions relating to these standards in four instances in the period 2010 to 2015:

The AMC has required the following of medical schools (listed on page 2 standard 1.6 of the list at Appendix 11):

Evidence that the Program has constructive partnerships and proactive communication with all relevant hospitals and health services that supports its teaching.

The AMC requires evidence that the agreements with health services are effective in managing specific teaching plans at each site, student placement numbers and the School’s expectations of clinicians.

Evidence of engagement with relevant local communities, organisations and individuals in the Indigenous health sector. There are some separate health structures for Indigenous health services and separate agreements would be required with those services)

Confirmation that the School’s contracts with the state Government (concerning access to placements) and Commonwealth regarding the Program are finalised.
 
Analyst Remarks to Response
AMC has standards that state that the medical education provider has effective partnerships with health-related sectors of society and government, and relevant organizations and communities, to promote the education and training of medical graduates. These partnerships are underpinned by formal agreements. AMC has also provided a screenshot (in the section about clinical teaching facilities) as documentation of one of its medical schools that displays an affiliation agreement. However, the actual affiliation agreement must be uploaded to be included in the official record of documentation submitted with the agency’s comparability petition.

NCFMEA may wish to request the official copies of the documentation to verify the information in the affiliation agreement.
 
Staff Conclusion: Additional Information requested
 
Onsite Review, Question 5
 
Country Narrative
The AMC applies the process described in ii (b) above in assessing clinical training. It visits all important clinical training including sites located in Australia, New Zealand and, where medical schools have international clinical training opportunities for core clinical training, sites overseas.

The AMC has a separate policy on offshore accreditation, Medical Courses Conducted Offshore by Australian and/or New Zealand Universities (APPENDIX 28), which describes the limited circumstances in which the AMC will assess and accredit an Australian or New Zealand medical program to offer its medical program offshore. This policy indicates that the assessment of any offshore proposal will require a site visit (see 5.1.1). Note the AMC is reviewing this policy but this requirement will not be changed.

Documents

APPENDIX 28: Medical Courses Conducted Offshore by Australian and/or New Zealand Universities
 
Analyst Remarks to Narrative
As previously stated, the institutions in conjunction with the clinical clerkships site initiate formal affiliation agreements. The AMC assesses the agreements for compliance with the standards (appendix 28). The institutions ability to comply with these standards is evaluated by the on-site inspection team. However, the country has not provided any documentation demonstrating the application of these standards.

NCFMEA may wish to request documentation of an example affiliation agreement to document application of their standards.
 
Country Response
The sample reaccreditation report provided at Appendix 24 (section 1.6) shows that the AMC does review formal affiliations agreements as part of an accreditation assessment. The list of accreditation conditions (provided at Appendix 11) shows that the AMC sets accreditation conditions when affiliation agreements are not complete (see condition1 a2 under this section which require:

1 Evidence that the Program has constructive partnerships and proactive communication with all relevant hospitals and health services that supports its teaching.

2 Evidence that the agreements with health services are effective in managing specific teaching plans at each site, student placement numbers and the School’s expectations of clinicians.
 
Analyst Remarks to Response
AMC has standards regarding the clinical clerkships that partner with the medical education provider partners to carry out additional training opportunities for core clinical training. AMC has provided documentation (exhibit 12) that demonstrates how the site team reviews the affiliation agreements for these sites as part of the onsite review.
 
Staff Conclusion: Comprehensive response provided
 
Qualifications of Evaluators, Decision-makers, Policy-makers
 
Country Narrative
Qualification and training of the individuals who participate in on-site evaluations of medical schools

Australian Medical Council Assessment teams are peer-based in the broadest sense and may include clinicians from the private and public sector, hospital and community-based environments, scientists, medical educators, students/trainees, health consumers and community members, medical and/or health managers, regulators, and academic content experts. The accreditation assessment team chair must be experienced in AMC accreditation. An AMC standard operating procedure, which explains the process for selecting an assessment team is provided as APPENDIX 29.

The general requirements of accreditation teams are shown in the position description sent to potential team members (see APPENDIX 30). These are:
• Support professional accreditation, and contribute to the development of the process.
• Be familiar with the approved standards and procedures for the assessment and accreditation of medical schools.
• Be aware of current issues in medical education and health care delivery.
• Be supportive of innovation and evolution in medical education and practice.
• As a peer, share information and experience to encourage improvements in the program being accredited.
• Undertake the reading and writing necessary to complete the assessment.
• Lead interviews and meetings as required.

The AMC holds annual accreditation workshop, led by the Chair and Deputy Chair of the Medical School Accreditation Committee and AMC accreditation staff. The AMC invites to the workshop: assessment team chairs and deputy chairs, new members of assessment teams, deans of medical schools undergoing accreditation, the president of the medical student society in each school undergoing accreditation. The workshop is an opportunity to learn about the experience of accreditation, consider the role of the different groups engaged in accreditation and learn through role play processes and techniques for accreditation site visit interviews and team evaluation of a medical program against the accreditation standards. The workshop program for 2016 is provided as APPENDIX 31. The AMC has begun work on online training materials, and expects to have the first modules available in the next 12 months.

The AMC provides a detailed Accreditation Handbook to all team members (see APPENDIX 23). Each team has some specific training provided by AMC staff at their preliminary team meeting.

Qualification and training of the individuals who establish the accreditation/approval standards for medical schools

The Medical School Accreditation Committee of the AMC is responsible for developing accreditation standards, and recommending them to the AMC’s governing body, the AMC Directors for approval. (see section 1.2 of the Procedures for Accreditation for its terms of reference) at APPENDIX 4.
The Committee includes nominees of key stakeholder organisations: the Australian Medical Students’ Association; the Confederation of Postgraduate Medical Education Councils (responsible for standards for the first year of medical practice); the Committee of Presidents of Medical Colleges (responsible for specialist medical training); the Medical Council of New Zealand; the Medical Board of Australia, and the Medical Deans Australia and New Zealand. The Committee also includes members of the Australian Medical Council, and a member with background in and knowledge of health consumer issues.
New committee members are invited to participate in the AMC accreditation training.

Qualification and training of the individuals who decide whether a specific medical school should be accredited/ approved
The AMC Directors are the decision making body of the AMC and decide whether a specific medical school should be accredited, based on a recommendation from the Medical School Accreditation Committee and ultimately decide on the accreditation standards to be recommended for approval.
The directors include the chairs of the AMC’s committees (who are chosen for their expertise and standing in medical education) and the AMC chief executive officer and directors elected by the members of the Australian Medical Council. The elected directors may be medical practitioners, educationalists, and/or community members. There is a transparent process for selection of the governing body. This is outlined in the AMC constitution (APPENDIX 5 – section 7).
The AMC has a formal process for the appointment of AMC committee chairs, including the Chair of the medical School Accreditation Committee, which involves a search process and appointment against defined requirements. Applicants must complete a written expression of interest application and an interview. To select a new chair of an AMC committee, the AMC Directors first appoint a search committee and provide the search committee members with:
• a statement of requirements of the role and attributes of the required chair
• the process for seeking expressions of interest through AMC stakeholder networks and council members
• details of the interview process.
The AMC commissions training for Directors from the Australian Institute of Company Directors as required. This training relates to their roles as company directors rather than medical education.

Documents
APPENDIX 4: Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015
APPENDIX 5: Constitution of the Australian Medical Council
APPENDIX 23: AMC Accreditation Handbook: The work of AMC accreditation assessment teams 2016
APPENDIX 29: AMC standard operating procedure, selection of a medical school accreditation team
APPENDIX 30: Position description – membership of an accreditation team
APPENDIX 31: Program 2016 AMC accreditation workshop
 
Analyst Remarks to Narrative
The country has provided the information regarding the AMC’s standards, qualifications, and training requirements for onsite team reviewers, those who establish the standards, and decision making groups which who establish the standards for each of these groups and make accrediting decisions. The qualifications vary from group to group, but many require relevant medical experience. The country has also provided documentation that demonstrates how the various stakeholders are trained for the position in which they serve. However, no documentation was included that explains how those involved meet the current standards. Nor was any information included about the standards for those that are involved in the appeals process.

NCFMEA may wish to encourage AMC to provide additional details about how the decision makers, team reviewers, and other groups that currently serving the organization are meeting the standards for their roles. In addition, they may wish to ask for additional information about standards for those individuals involved in the appeals process.
 
Country Response
The analysis says no documentation was included that explains how those involved meet current standards. A list of the members of the Medical School Accreditation Committee showing their background and qualifications and the membership positions they hold is provided as APPENDIX 44. All members of the Committee are appointed by the AMC governing body, the Directors.

A sample document that shows the information AMC staff present to the Medical School Accreditation Committee when they propose membership of an accreditation team is provided as Appendix 45.

 
Analyst Remarks to Response
In response to the draft analysis, AMC has provided documentation demonstrating the background and qualifications of those members currently serving roles within the organization. (Appendix 44) While this addresses the concern for meeting current standards, it is still unclear to Department staff about the background and qualifications of those who are involved in the appeals process.

NCFMEA may wish to ask AMC to provide additional details about the appeals panel members to ensure qualifications and backgrounds are appropriate.
 
Staff Conclusion: Additional Information requested
 
Re-evaluation and Monitoring, Question 1
 
Country Narrative
The length of the accreditation period granted by the AMC has not changed since the AMC last reported to NCFMEA. Each education provider and program undergoes an accreditation assessment by an AMC team at least every ten years. Broken into two periods of general six years and then four years. See Section 5 of the Procedures for Accreditation – APPENDIX 4).

When an AMC accreditation assessment team assesses a program, and the AMC accredits the program, it can grant accreditation for a maximum period of six years. In the sixth year of accreditation, the medical school provides a comprehensive report providing evidence that it continues to meet the accreditation standards, and that it has maintained its standards of education and of resources. The report also provides an appraisal of the developments since accreditation, and information on plans leading up to the next AMC reaccreditation. If this report is satisfactory, the AMC can grant continuing accreditation up to a ten year period since the team assessment (generally another four years). See Section 4.3 of the Procedures for Accreditation (APPENDIX 4).

The AMC may grant accreditation with or without conditions. Where it imposes conditions, the provider’s continuing accreditation is subject to it satisfying the conditions within a specified period.

Accreditation may also be granted for shorter periods of time if the AMC identifies a significant level of deficiency. At the conclusion of this period, or sooner if the education provider requests, the AMC will conduct a review. The provider may request either a full accreditation assessment or a more limited review (concentrating on the areas where deficiencies were identified).

Documents:
APPENDIX 4: Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015
 
Analyst Remarks to Narrative
The country's reaccreditation interval is a maximum of ten years, broken into two periods of generally six years and then four years.
 
Re-evaluation and Monitoring, Question 2
 
Country Narrative
The AMC monitoring procedures are explained in the Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 (APPENDIX 4 -section 4). In Australia, monitoring of accredited medical schools is a legislated requirement of the AMC under the Health Practitioner Regulation National Law (see APPENDIX 2).

The principal monitoring mechanisms are structured progress reports, comprehensive reports and the full accreditation assessment every ten years. In addition, the AMC expects that accredited education providers will report at any time on matters that may affect the accreditation status of their program, such as a change to its capacity to meet the accreditation standards, or any change that may meet the definition of a major change to the program.
The AMC asks medical schools to submit progress reports structured according the accreditation standards. They must address any accreditation conditions relevant to the accreditation standard, report on any developments planned or undertaken relevant to the standards, and provide standard data. The AMC also asks the medical school’s student society to make a submission in response to their medical school’s progress report. The AMC provides progress report guides (APPENDIX 21) for the medical school and the student society reports (APPENDIX 32).
The frequency of the reports relates to the AMC accreditation decision recorded in each medical school’s most recent AMC accreditation report. Medical schools granted the full period of accreditation are asked to submit written reports one, three, five, seven and nine years after the medical program’s assessment by the AMC. In the sixth year of accreditation, the medical school submits a comprehensive report to seek extension of the accreditation.
Medical schools granted accreditation of a major structural change and new education providers and programs are required to submit annual reports.
Having reviewed the progress report, the AMC Medical School Accreditation Committee will determine whether:
(i) the report indicates that the program and provider continue to meet the accreditation standards including if accreditation conditions have been satisfied in the time period set by the AMC , or
(ii) further information is necessary to make a decision, or
(iii) the provider and program may be at risk of not satisfying the accreditation standards.

If the Committee needs more information to make a decision, it communicates with the medical school about the information required and the date for submission. The Committee may decide that a meeting with representatives of the medical school is necessary to discuss the AMC’s requirements.

If the Committee considers that the medical school may be at risk of not satisfying the accreditation standards, then it invokes the AMC Unsatisfactory Progress Procedures (see section 4.4 of the Procedures for Accreditation at APPENDIX 4).

The AMC also invites the medical students’ society of the relevant medical school to lodge a submission, which the AMC medical School Accreditation Committee considers with the medical school progress report. A copy of the template is provided as an appendix.

Q (h) ii) The AMC receives few complaints from individual medical students.

The AMC complaints process is described in APPENDIX 33. It describes how the AMC manages complaints about an accredited medical program. Under this process, (section 7(i)), where a systemic complaint is found to have some substance then the AMC will take appropriate steps to manage the issue. That may involve discussion and agreement with the provider concerned, monitoring of the issue, which may involve specific immediate monitoring, and/or the imposition of conditions on accreditation.

One of the reasons for receiving only a small number of individual complaints is that the AMC has strong processes for collecting the feedback of the student body on their medical program. As reported in earlier responses, the AMC seeks a submission from the medical students as part of any accreditation process and the assessment team meets groups of students during the onsite visits. The AMC also seeks a student submission as part of its regular monitoring process (either annually or every two years depending on the accreditation status of the medical school) (Refer to APPENDICES 22 and 32).

Documents:
APPENDIX 2: Extract from the Health Practitioner Regulation National Law
APPENDIX 4 Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 (section 4)
APPENDIX 21: AMC Progress Report Guide
APPENDIX 22: AMC Student Submission Guide
APPENDIX 32: Medical student society progress report submission guide
APPENDIX 33: Complaints about programs of study, education providers and organisations accredited by the Australian Medical Council
 
Analyst Remarks to Narrative
The AMC has standards for developing effective complaint policies and it appears that AMC has received complaints from students. In a prior section (Part 2, Student Complaints, Question 1), the AMC has provided the location of its website where it publishes the complaint policy and contact for who to notify regarding complaints. The AMC states that if a complaint is found to have substance, further investigation occurs. This may result in an increase in monitoring or a change in conditions of accreditation.
 
Substantive Change
 
Country Narrative
The Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 (APPENDIX 4), section 3.2.2 includes the Australian Medical Council’s definition of a major change, which is:

"a change in the length or format of the program, including the introduction of new distinct streams; a significant change in objectives; a substantial change in educational philosophy, emphasis or institutional setting; and/or a substantial change in student numbers relative to resources. Significant changes forced by a major reduction in resources leading to an inability to achieve the objectives of the existing program are also major changes. The gradual evolution of a medical program in response to initiatives and review would not be considered a major change."

The AMC requires notification of proposed changes in advance of the changes being introduced so that it can determine the implications of the change for accreditation. In section 4.1 of the Procedures for Accreditation, the AMC indicates “the AMC expects that accredited education providers will report at any time on matters that may affect the accreditation status of their program, such as a change to its capacity to meet the accreditation standards, or any change that may meet the definition of a major change to the program.” The Procedures for Accreditation (section 3.2.2) describe the options for advising the AMC of changes. This can be through regular progress reports, or a specific notice of the change.

As many of the changes described above will need to be assessed by an AMC team before they are introduced, the AMC requests at least 18 months’ notice of the intended introduction of the change.

When it considers the initial advice from a medical school about planned changes, either through a specific notice of intent or through progress reports, the Medical School Accreditation Committee will decide if it is a major change. If it is, the Committee will also decide whether the major change can be approved for introduction within the current accreditation of the program or is of comprehensive impact that would require reaccreditation of the whole program. The AMC will advise the medical school of its decision, including whether the assessment will be carried out by correspondence or by visit.

If the AMC determines the medical school’s proposed change to be major, the medical school will be invited to submit a Stage 1 Submission. This submission is the basis for the assessment of the program of study.

Documents:
APPENDIX 4: Procedures for the Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015
 
Analyst Remarks to Narrative
According to the narrative, the AMC requires universities to report substantive changes related to the following: changes in objectives, resources, and changes in institutional setting. The Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 documents the specifics for notification. The AMC state requires that substantive changes are reviewed and then a determination is made to whether an on-site inspection team visit is warranted or not. However, the agency has not provided documentation of this review or confirmed that it has review any substantive changes during this period of comparability.

NCFMEA may wish to request documentation that shows an application for substantive change, how this information is reviewed, and if applicable how the onsite inspection team reviews the institution's goals for compliance under this guideline or indicate that it has not reviewed and substantive change notifications during this period of comparability.
 
Country Response
The AMC has provided a new attachment, (Appendix 43) which is a letter from the AMC to a medical school to begin the process of an onsite assessment after the AMC has decided that the program is undergoing a major change.
 
Analyst Remarks to Response
In response to the draft analysis, AMC has provided a letter (appendix 43) from AMC to the institution explaining the process that they will follow for the site visit regarding a substantive change. While it does explain the information to be reviewed, there is not documentation that demonstrates the application from the institution about the change or documentation from the site visit team demonstrating their review of the institution against AMC’s standards.

AMC may wish to request additional documentation including an institutional application for substantive change and AMC’s review of this information.
 
Staff Conclusion: Additional Information requested
 
Conflicts of Interest, Inconsistent Application of Standards, Question 1
 
Country Narrative
The following statement concerning conflicts of interest is taken from the Procedures for Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015 (APPENDIX 4) section 2.7.

"Members of AMC committees are expected to make decisions responsibly, and to apply standards in a consistent and an impartial fashion.
The AMC recognises that there is extensive interaction between the organisations that provide medical education and training in Australia and New Zealand so that individuals are frequently involved with a number of programs. The AMC does not regard this, of itself, to be a conflict. Where a member of an AMC accreditation committee or an assessment team has given recent informal advice to an education provider on its program of study outside the AMC accreditation process, that member must declare this as an interest.

The AMC requires its Directors and members of its committees to complete standing notices of interest and to update these regularly. These declarations are available at each meeting of the committee. The agendas for AMC committee meetings begin with a ‘declaration of interests’, in which members are requested to declare any personal or professional interests which might, or might be perceived to, influence their capacity to undertake impartially their roles as members of the committee.
The committee will decide how the member’s interest in a particular item will be managed, for example by exclusion from the meeting or from discussion of the relevant item. Members will not vote on matters on which they have a declared personal or professional interest. All declared interests will be recorded in the committee minutes, as will the committee’s decision in relation to the interest."

The AMC requires proposed members of assessment teams to declare to the Medical School Accreditation Committee any relevant personal or professional interest that may be perceived to conflict with their ability to undertake impartially their duties as an assessor (APPENDIX 34). The AMC will disclose all declared interests of the persons recommended to the education provider and seek the education provider’s comments on the team membership. Having considered the interests declared and the provider’s comments, the accreditation committee makes a decision on the appointment of the team.

Where the education provider’s view on the suitability of an appointment conflicts with the view of the accreditation committee, the committee will refer the appointment of the team to the AMC Directors for decision.

If a conflict of interest emerges for an assessor during an assessment, the team chair and executive officer will determine an appropriate course of action. This may entail changing the report writing responsibilities of the assessor, requiring the assessor to abstain during relevant discussion, or altering the assessment program. Any such conflicts, and the course of action taken, will be reported to the Medical School Accreditation Committee.

Documents:
APPENDIX 4: Procedures for the Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015
APPENDIX 34: AMC Standing Notice of Interests form
 
Analyst Remarks to Narrative
As stated in the narrative, the AMC requires Members of its committees to make decisions responsibly, and to apply standards in a consistent and an impartial fashion." While the AMC has provided a copy of the procedures (appendix 4) related to Conflict of Interest and has also provided a blank copy of its Standing Notice of Interests form, it has not included signed documentation that demonstrates the application of its requirements. .

NCFMEA may wish to for additional information and documentation demonstrating application of the conflict of interest standards for all personnel involved in accreditation activities.
 
Country Response
The AMC has provided two new documents demonstrating the application of these policies. These are a standard letter to a medical school inviting their comment on the proposed appointment of a chair of an accreditation team (Appendix 45), and as an extract from a recent meeting of the Medical School Accreditation Committee, which is the committee which oversees the accreditation process. This extract shows: that the meeting begins with a declaration of interests, and the management of the appointment of the chair of the accreditation team and any potential conflicts of interest (Appendix 37).
 
Analyst Remarks to Response
In response to the draft analysis, AMC has provided documentation (appendix 37 and exhibit 9) that demonstrates the AMC meeting begins with a declaration of interests and that requests information regarding any conflicts that an institution may have regarding a chair of an accreditation team. While good in practice, it is possible that all voting members have not been exposed to (for example if they miss the meeting) the information that discusses how to act if a conflict of interest occurs.

NCFMEA may wish to request have to develop a process for collection of signed statements from all of its decision makers and site visitors acknowledging that they are not acting in an unbiased way. It is Department Staff understanding that additional work is already being considered as it relates to this topic.
 
Staff Conclusion: Additional Information requested
 
Conflicts of Interest, Inconsistent Application of Standards, Question 2
 
Country Narrative
The Australian Medical Council ensures that accreditation standards are consistently applied to all schools through: training and support of accreditation teams, the hierarchy of decision making and reporting in the AMC, and reconsideration and review processes.

Training and support of accreditation teams - AMC accreditation staff accompany every accreditation team and are responsible for identifying areas of inconsistent application of standards and asking the team to review their findings. All teams are given samples of previous accreditation reports, and accreditation conditions to assist them to understand the requirements. AMC training of accreditation team chairs and deputy chairs stresses the importance of conducting assessments against the standards, and the AMC provides template forms for team members to complete that require them to assess the medical program against the standards at every step of the process. Team members first complete this assessment individually, and then the team works as a group to reach a consensus. A sample is provided as APPENDIX 35.

Hierarchy of decision making: The AMC hierarchy of committees allows policies and recommendations to be developed by expert groups, considered through committees which have representation from relevant stakeholder groups, and then considered for approval by AMC directors, the governing body of the Australian Medical Council. For example, AMC assessment team members are chosen for their expertise and capacity to contribute to the assessment and accreditation of a medical program. They prepare a report which presents their findings against the accreditation standards (Executive summary sample to an accreditation report is at APPENDIX 36) . The Medical School Accreditation committee reviews the team’s draft report to ensure it is a balanced assessment, and that the accreditation standards have been applied appropriately. The Committee makes a recommendation to the AMC Directors on the accreditation outcome and, if necessary, accreditation conditions, within the options set out in the Procedures for Accreditation (APPENDIX 4). Accreditation decisions are made by the AMC Directors, on the advice of the Medical School Accreditation Committee. This structure is explained in section 1 of the Procedures for Accreditation.

Review and reconsideration- The Procedures for Accreditation also provide for the medical school to review and comment on the team’s draft accreditation report (see section 3.3.7 of the Procedures) and to seek formal reconsideration of the report (see section 3.3.8 of the Procedures).

Documents
APPENDIX 4: Procedures for the Assessment and Accreditation of Medical Schools by the Australian Medical Council 2015
APPENDIX 35: Sample AMC guide to assess the medical program against standards
APPENDIX 36: Sample Executive Summary of an AMC Accreditation Report
 
Analyst Remarks to Narrative
The AMC has guidelines in the Procedures for the Assessment and Accreditation of Medical Schools that includes standards and procedures regarding consistent reviews. Further explained in the narrative is that consistency in its review occurs through training, regular reporting, and the reconsideration of recognition processes. AMC included documentation that demonstrates how it assesses standards. The agency included a reference to a report for demonstrating additional compliance with this guideline; however that attachment was not included as evidence.

NCFMEA may wish to request a copy of a report and additional information about how reporting assists the agency in consistency in decision making.
 
Country Response
The document at Appendix 36 (a sample executive summary of an accreditation report) illustrates the standard way in which the AMC presents its public record of its accreditation findings. This shows the AMC assesses the medical program against each standard.

As noted above, the Medical School Accreditation Committee is responsible for reviewing the accreditation team's draft findings and ensuring they are balanced and consistent.

The medical school being accredited has an opportunity to review the executive summary (and the whole accreditation report) , and as indicated above, can seek reconsideration if they are dissatisfied with the report.

The transparency of this report, which provides a clear indication of whether a standard is judged as met/substantially met or not met, and the detailed report which provides the rationale for the finding, assists the Medical School Accreditation Committee to assess whether the standards are being applied consistently and fairly, and the medical school to judge whether it considers the assessment to be fair and reasonable.

 
Analyst Remarks to Response
In response to the draft analysis, AMC has provided additional documentation (appendix 36) that demonstrates their review of accreditation findings. This documentation illustrates how AMC ensures that they are providing consistency in their reviews of its medical schools.
 
Staff Conclusion: Comprehensive response provided
 
Accrediting/Approval Decisions, Question 1
 
Country Narrative
The AMC response in k(i) concerning controls against the inconsistent application of the accreditation/approval standards is also relevant to this response. The mechanisms reported under that question: training and support of accreditation teams, the hierarch of decision making and reporting in the AMC, and reconsideration and review processes is also relevant here.

Under the Health Practitioner Regulation National Law (APPENDIX 2), which provides the legal framework for AMC accreditation, the AMC may grant accreditation if it is reasonably satisfied that a program of study and the education provider that provides it meet an approved accreditation standard. It may also grant accreditation if it is reasonably satisfied that the provider and the program of study substantially meet an approved accreditation standard, and the imposition of conditions on the approval will ensure that the program meets the standard within a reasonable time. AMC accreditation reports state whether the AMC has found accreditation standards to be met or substantially met or not met. The Executive Summary in each report provides an assessment of the medical program against each accreditation standard. This summary is drafted by the AMC staff with input from the accreditation team, and reviewed by the Medical School Accreditation Committee before it is submitted to the AMC Directors. A sample executive summary of an AMC accreditation report showing the assessment against the accreditation standards is provided at APPENDIX 36.

Documents:
APPENDIX 2: Health Practitioner Regulation National Law
APPENDIX 36: Sample Executive Summary of an AMC Accreditation Report
 
Analyst Remarks to Narrative
The country is guided by written standards and procedures outlined in the Health Practitioner Regulation National Law that ensures decisions are based on compliance with ACCM's standards. The country has attached a copy of a report which reflects a review of the institution.
 
Accrediting/Approval Decisions, Question 2
 
Country Narrative
In its accreditation submission guide (APPENDIX 17), the AMC asks for the medical school for the following relevant information:

• Provide details of any student cohort performance analysis planned or undertaken by the education provider. How are performance data correlated across campuses?
• Provide data on pass rates for each year and each major component of the program for the last three years.
• Provide details of any analysis of student performance in relation to student background, conditions and entrance qualifications. How will this information be used for student selection, curriculum planning and student counselling processes?
• Outline the mechanisms used to track students after graduation.
• How does the medical education provider evaluate graduate outcomes. (e.g. intern supervisor evaluations, surveys of recent graduates, success in vocational and other licensure examinations, career destinations or employer feedback)?
• How is information about graduate outcomes used as feedback for program development?

This information is assessed by the accreditation team and used in making its decision about achievement of standards under Standard 6 (monitoring and evaluation).

Document:
APPENDIX 17: Reaccreditation Submission Guide 2016
 
Analyst Remarks to Narrative
The AMC has provided a summary of how it evaluates performance for making accreditation decisions based off its documentation titled Reaccreditation Submission Guide 2016. This guide includes information submitted by the institution to explain how it continues to meet the qualifications for reaccreditation. One of the questions is specific about monitoring student achievement outcomes. However, the agency has not provided documentation of this process.

NCFMEA may wish to request a copy of a completed reaccreditation submission demonstrating how it assesses the institution for reaccreditation.
 
Country Response
The extract from accreditation reports (new Appendix 40) addresses this question. .



 
Analyst Remarks to Response
In response to the draft analysis, AMC has provided additional documentation (appendix 40) that demonstrates an extract of reports regarding reaccreditation. This documentation illustrates how AMC ensures that they are providing consistency in their reviews of its medical schools.
 
Staff Conclusion: Comprehensive response provided
 
Accrediting/Approval Decisions, Question 3
 
Country Narrative
The response to question ii) above is relevant. Each individual medical school is responsible for collecting this information.
 
Analyst Remarks to Narrative
The AMC has provided a summary of how it evaluates performance for making accreditation decisions based off its documentation titled Reaccreditation Submission Guide 2016. This guide includes information submitted by the institution to explain how it continues to meet the qualifications for reaccreditation. One of the questions is specific about monitoring student achievement outcomes. However, the agency has not provided documentation of this process.

NCFMEA may wish to request a copy of a completed reaccreditation submission demonstrating how it assesses the institution for reaccreditation.
 
Country Response
The AMC has provided a new appendix (Appendix 40) which shows a sample of four assessments of medical programs approaches to collecting this data and the AMC assessment of the adequacy of these approaches. Two reports commend good practices and two of the reports set conditions on the accreditation where compliance has not been demonstrated or set recommendations for improvement to improve practices.
 
Analyst Remarks to Response
In response to the draft analysis, AMC has provided additional documentation (appendix 40) that demonstrates an extract of reports regarding reaccreditation. This documentation illustrates how AMC ensures that they are providing consistency in their reviews of its medical schools.
 
Staff Conclusion: Comprehensive response provided
 
Accrediting/Approval Decisions, Question 4
 
Country Narrative
No the AMC does not establish these sorts of performance measures for medical schools. The AMC requires medical schools to critically evaluate their own success, explain their methods, and describe how the information is used to improve the medical schools performance.
 
Analyst Remarks to Narrative
The country has provided a summary explaining that the AMC does not have national standards for assessing performance. This determination is left at the discretion of the institution, which also includes their own suggestions about how they can make improvements. However, no documentation was included that demonstrates how this information reviewed for appropriateness.

NCFMEA may wish to request documentation that demonstrates the institution's goals for compliance under this guideline.
 
Country Response
No further response from the AMC.
 
Analyst Remarks to Response
No additional information was provided by AMC in response to the draft analysis. Department staff would like to reiterate the information stated earlier. The country has provided a summary explaining that AMC does not have national standards for assessing performance. This determination is left at the discretion of the institution, which also includes information about how to improve. However, no documentation was included that demonstrates how this information reviewed for appropriateness.

NCFMEA may wish to request documentation that demonstrates the institution’s goals for compliance under this guideline.
 
Staff Conclusion: Additional Information requested