PPOZ to the Ministry of Health: Three Proposals, Three Negative Opinions

The Healthcare Employers’ Association presented its negative positions on three legislative proposals to Health Minister Jolanta Sobierańska-Grenda. These concerns relate to a draft regulation on custom-made medical devices, a draft amendment to the Act on the Professions of Physician and Dentist, and a draft of a new Act on the Professions of Nurse and Midwife. As the PPOZ emphasizes, the proposed solutions encroach on the professional responsibilities of individual medical professions, undermine the organization of work in primary health care, and do not serve to improve the quality of patient care.

PPOZ Opposes Shifting New Responsibilities onto Family Physicians

One of the main concerns is the proposal to require primary care physicians to issue prescriptions for certain orthopedic devices. “In our view, determining which patients qualify for orthopedic devices requires specialized knowledge and experience in orthopedics, surgery, or rehabilitation,” These are competencies specific to physicians in these specialties and, in certain cases, to physical therapists,” comments Bożena Janicka. According to the PPOZ, transferring these responsibilities to family physicians will not improve the quality of care but will increase the burden on primary care. “That is why we are demanding that the proposed changes be withdrawn and that these responsibilities remain with specialists,” adds the PPOZ president.

Criticism of Changes in Medical Education

The draft amendment to the Act on the Professions of Physician and Dentist also received a negative assessment. The PPOZ opposes, among other things, shortening the postgraduate internship from one year to six months and eliminating instruction in medical law and bioethics. “The internship serves as a bridge between medical school and professional practice. It is a very important stage in preparing a young doctor for independent practice, and shortening it could have an impact on the quality of care in the future,” comments Bożena Janicka.

The PPOZ is also critical of the proposal to make the ability to independently provide health care services, work on-call shifts, and take the specialty exam contingent upon passing the State Competency Exam. “Completing medical school, passing the Final Medical Exam, completing an internship, and receiving a positive evaluation from the residency program director are sufficient proof of a physician’s preparedness,” explains President B. Janicka.

PPOZ also raises objections to the planned invalidation of a successfully passed State Specialization Exam after 24 months if the physician does not obtain the title of specialist within that time. According to PPOZ, the regulations do not take into account unforeseen circumstances, such as illness or parenthood. The organization calls for extending this period to at least five years and exempting doctors who are already pursuing their specialization from the new regulations.

Another point of contention is the mandatory suspension of the right to practice for failure to fulfill the continuing professional development requirement. According to the PPOZ, such a far-reaching sanction is disproportionate and limits the medical self-governing body’s ability to assess each case individually.

Objections to Expanding Nurses' Scope of Practice

The PPOZ also takes a negative view of the draft of the new law on the nursing and midwifery professions. “We do not oppose the expansion of nurses’ and midwives’ competencies per se, but the changes must be based on an appropriate level of education, experience, and increased professional responsibility.” Meanwhile, the proposed regulations unduly encroach on physicians’ responsibilities and may undermine their role as the professionals responsible for leading the diagnostic and therapeutic process. And it is precisely the preservation of this role that guarantees patient safety,” emphasizes Bożena Janicka.

According to the PPOZ, the bill should clearly define the list of medications, medical devices, foods for special dietary uses, and diagnostic tests that could be prescribed by nurses and midwives.

The organization also opposes granting nurses the right to issue certificates of temporary incapacity for work, arguing that such certificates require a comprehensive assessment of the patient’s health. Provisions regarding advanced practice nursing and midwifery (APN) raise additional concerns. “The draft does not specify either the scope of this practice or the competencies of those who perform it, which means it is currently unsuitable for a reliable assessment,” adds the president of PPOZ.

“Patient safety should be the starting point”

The Healthcare Employers’ Association is calling on the Minister of Health to re-examine all three draft bills. According to the organization, the changes should, above all, enhance patient safety and improve the functioning of the healthcare system. - Changes to the law should enhance patient safety, improve the organization of the healthcare system, and make thoughtful use of the competencies of individual medical professions. However, none of the proposed bills meets these conditions—quite the contrary! All of them create new organizational problems and increase the risk of a decline in the quality of care provided. We believe that any change to professional competencies or the rules governing the practice of a profession should be designed primarily to improve healthcare, rather than to shift responsibilities between professional groups on an ad hoc basis. Hence our strong opposition!” explains Bożena Janicka.

Source: PPOZ