Dear Doctor,

Further to our recent communication regarding changes notified to the Annual Retention of Registration process by the Medical Council, RCSI and the other Training Bodies through the Forum of Postgraduate Training Bodies have engaged with the Medical Council. Following this engagement we have received amended documentation from the Medical Council which is available here

The Council now propose to defer the introduction of a new declaration as part of the Annual Retention of Registration process until 2020. In 2019, doctors renewing their registration will be asked to complete a two part declaration (unchanged from 2018):

It is important to be aware that RCSI will be required in June of 2019 to provide to the Medical Council the registration numbers and names of all registered Medical practitioners (RMPs) who have not met the minimum requirements in terms of CPD credits accrued (internal (20), external (20), personal learning (5) , research/teaching making a total of 50 credits) in the year ending April 30 2019. The Medical Council will also require RCSI (and all training bodies) to provide the registration numbers of all those who have enrolled/re-enrolled and paid the fee for 2019-2020.

All non-compliant RMPs will be directed by the Medical Council to demonstrate they are meeting the requirements by the end of the Scheme year 2019 – 2020. RCSI will provide all possible support within our resources.

You should only select YES to statement 1 if you are enrolled in PCS and have paid your fee for the year beginning May 1 2019.  We advise you to only select YES to statement 2 if your annual statement of participation for 2018-2019 clearly states that you have met all the professional competence requirements set out in detail in our online guide.  While you are also expected to have completed an audit relevant to your scope of practice during the 2018-2019 PCS year, in the revised explanatory memorandum (click here) for the Training Bodies, you will see that the Medical Council do not intend to enforce the requirement with regard to Audit at the current time due to confusion regarding Data Protection regulations.

You should enrol, re-enrol and pay your fee for the 2019-2020 year of Professional Competence Scheme on or after May 1st. You should complete this process with RCSI before completing the Annual Retention Statements for the Medical Council. Please note RCSI PCS enrolment for 1st May 2019 – 30th April 2020 opens on 1st May 2019.

If you have not met the minimum requirements for PCS in the year due to end on 30 April 2019, you have four weeks remaining to ensure you meet those requirements. Your status is visible on your PCS dashboard (https://pcs.rcsi.ie/) but if you wish for advice on your status, please contact RCSI before completing the Annual retention process.   If you were absent from practice for a period of three months or greater due to illness or maternity leave, please contact the professional competence office (pcs@rcsi.ie) in advance and we will arrange for you to complete a separate declaration to this effect before the end of the year and annotate your Annual Statement of Participation. The position of doctors absent from practice for other reasons is unclear at this time and it is safest to continue to meet the CPD requirements where this is possible.

Please note that doctors who are found to have made a false declaration in the Annual Retention of Registration may be subject to regulatory action which could result in sanction, limitations on your practice, suspension or erasure from the register. Once the Medical Council initiate regulatory action, we will not be able to assist you with this process and we advise that you respond to all communications from the Medical Council promptly with the benefit of appropriate legal advice.

While the Medical Council have indicated to us that they do not intend to take regulatory action against those who truthfully declare that they are not compliant with the requirements, you will be in breach of your obligations under the Medical Practitioners Act and this could result in regulatory action against you.

If you require further advice on the operation of the Professional Competence Scheme or support in meeting the requirements, please contact us at (pcs@rcsi.ie) or consult our website. If you have any queries about the annual retention process or other matters relating to your registration, you should contact the Medical Council directly. RCSI is engaging with the Medical Council in relation to the impact of these new requirements and will update you immediately if there are any material changes.