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English Language Skills Registration Standards — Australian and Global Comparative Assessment
—Executive Summary
Lesleyanne Hawthorne — Professor: International Health Workforce Anna To — Research Fellow
2013
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ACKNOWLEDGEMENTS First, we would like to express our sincere appreciation to the 61 key informants from seven countries interviewed to inform this study. Derived from Australia, Canada, Ireland, New Zealand, Singapore, the United Kingdom, and the United States of America, the majority were Chairs or Registrars of the regulators involved, with an exceptional level of relevant expertise at senior as well as operational levels. By agreement, organisations rather than individual key informants are named in this report (with specific titles only provided when requested). Of the 37 regulatory body interviews conducted, 10 were in medicine, 10 in nursing, 7 in pharmacy, 6 in dentistry, 2 in physiotherapy, and a further 2 with broader assessment bodies (the Health Professionals Council in the UK and World Education Services in Canada). In terms of source countries 9 interviews were conducted with regulators in Australia, 8 in Canada (including several provinces), 5 in New Zealand, 5 in the UK, 4 in Ireland, 3 in Singapore and 3 in the USA. A further 5 interviews were conducted with language testing experts (Australia), 4 with senior academics (Australia and New Zealand in the fields of medicine and nursing), and 3 with government policymakers (in Canada). These telephone interviews lasted 0.75 to 1.5 hours. All were transcribed for thematic analysis, followed by return to key informants for review. Their views have informed this study at every level. Regrettably, given space constraints, only a range of interview excerpts could be provided to illustrate key issues throughout the Full Report. Second, we gratefully acknowledge the provision of the complete Occupational English Test (OET) database for our analysis by the test administrator, the Centre of Adult Education (Victoria). We note it is rare to secure access for independent analysis of test results on a de‐identified basis. As advised by the language testing experts interviewed, independent researcher access to language testing databases is typically highly restricted. Our analysis of the OET has permitted definition of the impact of a range of English language testing requirements on the candidate base, and hence is relevant to the AHPRA review process. Third, we sought email advice concerning select language testing and instrument related issues, in particular from the administrators of the IELTS, OET and TOEFL tests. The clarification provided on select points was very helpful, supported by a range of forwarded materials. We also benefited from direct advice elicited from the Cambridge, MELAB (Michigan English Language Assessment Battery), Pearson and CanTEST administrators. Fourth, we would like to express our sincere appreciation to John Pill, an academic with longstanding global expertise in language testing, from both operational and research perspectives. (This experience previously included administration of the OET.) With AHPRA’s agreement John read the Draft versions of the Full and Executive Summary ELSRS Reports, to provide external academic review of the literature analysis. His comments were very helpful, with additional references incorporated here. Fifth, we received excellent support from our two research assistants, Ms Lorraine Devitt and Ms Claudia Sandoval of the Australian Health Workforce Institute. Lorraine meticulously transcribed the 50 telephone interviews, while Claudia accessed the extensive literature required for our review, assisting also with the global ELSRS web audit we conducted in relation to eight
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comparator countries (Australia, Canada, Ireland, New Zealand, Singapore, South Africa, the United Kingdom, and the United States of America) and the key English language tests currently used. (Please see Attachments 1 and 2 for detail, noting these were finalised late 2012.) Last but not least, it has been a continuing pleasure to work under the supervision of Ms Helen Townley and Mr Chris Robertson (on behalf of the Australian Health Practitioner Regulation Agency [AHPRA]) throughout this project. Significant time was required to arrange interviews and secure written feedback, given the stature of the key informants involved. Helen and Chris were gracious throughout the study and of invaluable assistance. They facilitated the arrangement of interviews with National Board Chairs and Executive Officers; chaired a very useful AHPRA Workshop in November 2012 (allowing us to secure direct input from the National Boards); and arranged our preliminary findings session at the NRAS Conference in Melbourne earlier this year, which elicited valuable feedback. With our sincere thanks to everyone who contributed to this project, including the National Boards for their review comment following consideration of the Draft Report (December 2012 to February 2013) and our global key informants. Lesleyanne Hawthorne and Anna To Australian Health Workforce Institute Faculty of Medicine, Dentistry and Health Sciences University of Melbourne
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EXECUTIVE SUMMARY 1. English Language Testing – Context and Major Instruments Language testing is used for a wide variety of purposes, with profound political, social and economic impacts. Current applications include the determination of refugee status, eligibility for citizenship, control of international student entry and placement, selection of skilled migrants, and access to professional registration. Within this context English testing has become a highly lucrative global business, with market share tenaciously sought. The global mobility of international students has driven instrument development since the 1950s, given the need to determine capacity to study in English. The Test of English as a Foreign Language (TOEFL) and the International English Language Testing System (IELTS) have predominated to date:
TOEFL: A pen and paper grammar‐based test developed in the USA in the 1960s, with a range of variants emerging since (most notably the introduction of a speaking test with the development of an internet‐based TOEFL‐iBT version). By 2009 the TOEFL was recognised by more than 6,000 institutions in over 130 countries, in particular the Americas and parts of Asia.
IELTS: A performance‐based test developed by the UK Cambridge consortium in the late 1980s, supported by Australian trialling and input. By 2009 IELTS had one million candidates per year, with the test available in 120 countries across 500 locations. The Cambridge English as a Second Language Tests (including IELTS) annually report over three million candidates, taking tests in 2,500 centres across 130 countries1.
TOEFL and IELTS’ near monopoly status is currently being contested by the emergence of new English tests such as the Pearson Test of English Academic (PTE):
Pearson: Developed by the global publishing group, the PTE has recently been approved by the Australian and UK governments for student visa purposes. It has secured rapid global recognition, including by 200 Australian institutions to date, claiming a high level of reliability.
2. English Language Testing of Skilled Migrants ‐ Australia English testing became a primary Australian strategy to select skilled migrants three decades back. A series of reports in the 1980s demonstrated poor English language to triple the unemployment risk for males, while doubling it for females. In 1990 the Chair of the Australian Medical Council stated ‘… all English speaking developed countries take the view that foreign medical graduates who choose to emigrate must demonstrate in objective testing a good deal of proficiency in English as well as the level of professional competence expected of graduates of their chosen country’.2 Similar views were held in other fields, such as engineering. Within this context, in the late 1980s the performance‐based Occupational English Test (OET) was developed to assess migrant health professionals’ English at the start of the registration process.
OET: Administered by the Council of Education (Victoria) to 2012, the OET examines candidates' speaking, listening, reading and writing skills in linguistic contexts simulating future professional practice in 12 fields (dentistry, dietetics, medicine, nursing, occupational therapy, optometry, pharmacy, physiotherapy, podiatry, radiography, speech
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pathology and veterinary science). From 2005 to 2011 the OET assessed 28,924 candidates in 40 global locations, with the test available up to 10 times per year3.
In 1993 Australia mandated English language testing for skilled migrants in 112 ‘occupations requiring English’ (including all health fields). Since 2007 IELTS Band 6 has been required (raised from Band 5), or Grade B on the OET. Higher levels are set by the Department of Immigration and Citizenship (DIAC) where regulatory bodies require these.14 By July 2012 English language ability had become Australia’s key criterion for skilled migrant selection (with applicants required to prove they possess ‘vocational’ English), alongside qualification level and employer sponsorship. To provide the National Boards and AHPRA with advice concerning English language skills registration standards (ELSRS), the current project undertook:
A global web search to define the tests used and regulatory body registration requirements in eight jurisdictions (Australia, Canada, Ireland, New Zealand, Singapore, South Africa, the United Kingdom, and the United States). (See Attachments 1 and 2.)
Completion of 50 extended interviews (or equivalent) to assess ELSRS practice and issues from the perspective of the heads/ registrars/ managers of regulatory bodies in seven of these jurisdictions (excluding South Africa), in addition to government policymakers and language testing experts (61 key informants in all)2.
An extensive literature review to assess the evidence base in relation to current Australian ELSRS requirements in health fields.
Analysis of the OET database from 2005 to 2011 (28,924 candidates) to define the recent impact of English language testing in Australia by key variables 3.
1 As affirmed by the Department of Immigration and Citizenship (DIAC), ‘Where the nominated occupation requires a higher level of English (equivalent to IELTS test score of more than 5 in each of the four test components) because it forms part of that occupation’s registration, licensing or membership requirement, the visa applicant must have at least the standard of English language proficiency required for the grant of that registration, licence or membership.’ (DIAC, 2010, ‘Employer Sponsored Workers – September 2009 Changes to the English Language Proficiency Requirements’, http://www.immi.gov.au/skilled/skilled‐workers/changes‐eng‐req.htm, accessed 16 August 2012).
2 In consultation with AHPRA the primary interview focus was placed on regulatory body perspectives. Of the 37 regulatory body interviews conducted, 10 were in medicine, 10 in nursing, 7 in pharmacy, 6 in dentistry, 2 in physiotherapy, and a further 2 with broader assessment bodies (the Health Professionals Council in the UK and World Education Services in Canada). In terms of source countries 9 interviews were conducted with regulators in Australia, 8 in Canada (including several provinces), 5 in New Zealand, 5 in the UK, 4 in Ireland, 3 in Singapore and 3 in the USA. Despite several months of attempts, interviews could not be arranged with key informants in South Africa. A further 5 interviews were conducted with language testing experts (Australia), 4 with senior academics (Australia and New Zealand in medicine and nursing), and 3 with government policymakers (Canada). Interviews typically lasted 0.75 to 1.5 hours. All were transcribed for thematic analysis, followed by return to key informants for review. (See ELSRS Full Report.) In three cases regulatory bodies chose to provide written input rather than interviews, and in two cases there were second interviews (given the level of data involved). 50 interviews were thus conducted in all. 3 We gratefully acknowledge the provision of the complete OET database by the Centre of Adult Education, noting it is rare to secure access for independent analysis of test results on a de‐identified basis. As advised by the language testing experts interviewed, independent research access to the IELTS database is typically highly restricted.
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3. English Language Standards for Registration In recent decades the IELTS and TOEFL tests have been the main instruments used to determine migrants’ eligibility for registration across multiple fields and jurisdictions. By 2012 48 Australian regulatory bodies had mandated IELTS standards (compared to the dominance of TOEFL in select parts of Asia and North America). Highly diverse requirements have been set, with modest scientific evidence to date to inform these decisions. For example 73 IELTS Research Reports have been published by the Cambridge consortium in the past two decades. Just four have assessed standards for professional regulation purposes, typically on an audit rather than a validation basis. According to the author of two such reports, ‘IELTS was originally intended and designed as a set of international benchmarks to assess an individual’s proficiency for academic study in English‐speaking contexts… The growing trend for IELTS to be adopted by users outside of academic, including governments, professional associations and employers, may constitute a risk for the test owners if the assessment system cannot be validated for the purposes for which it is being used.’5
The current standards specified by Australian regulatory bodies vary widely, as follows:
Law: IELTS Band 8 (writing), 7.5 (speaking) and 7 (reading and listening)
Teaching: IELTS Band 7.5 required across all 4 English sub‐tests (or equivalent)
Medicine and allied health professions: IELTS Band 7 (7.5 in pharmacy) or Occupational English Test (OET) B
Engineering: IELTS Band 6 (with additional inputs considered, for example candidate interview performance)
Architecture: Interview required
Accounting: No stated requirement In terms of medicine and allied health, global regulatory bodies have adopted markedly different requirements in terms of testing. This represents a dynamic policy space. As demonstrated by the web audit and 50 interviews, regulators may specify:
Few or multiple tests ‐ Australia allowing two (the IELTS and the OET), Singapore four, and Canada eight (with additional French tests accepted).
Different scores – Ranging in IELTS from Band 6 on some skills to Band 7.5 overall (with Band 7 the norm); in TOEFL iBT (the internet version) from 74 to 95; and in TOEFL PBT (the print version) from 537 to 600, with few field‐specific studies undertaken to support specification.
Highly variable scores by select field – In IELTS ranging from a ‘one size fits all’ approach as in Australia (IELTS Band 7 [with pharmacy 7.5]) or OET Grade B, to substantial variability by field (pharmacy typically mandating the highest scores globally compared to lower scores in some countries for nursing).
Different test exemptions – Ranging from nil; to native or near‐native English speakers from defined source countries; to international students qualified in the host country; to international students qualified in the host country having also completed secondary education in the medium of English. (For detail see web‐based ELSRS audit.)
Different test types – Ranging from generic tests (such as the IELTS, TOEFL and the Michigan English Language Assessment Battery); to field‐specific tests (such as the OET and the Canadian Language Benchmarks Assessment for Nurses in Canada); to embedded assessment (such as in the USMLE Clinical Skills test based on
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communication with standardised patients); to interviews rather than tests (in select fields, such as nursing in Singapore).
Different pass timeframes – Ranging from the requirement to pass all four sub‐tests at a single compared to multiple sittings.
Different lengths of result currency – With regulators specifying from six months (nursing in British Columbia) to two years before a fresh test is required.
4. Competing Values in Relation to ELSRS Standards Despite this policy variability, without exception, the 37 regulators interviewed affirmed their prime responsibility to be the protection of public safety and the maintenance of stringent regulation standards. This was strongly affirmed by the global regulators interviewed, across all fields. In Australia the Health Practitioner Regulation National Law as in force in each state and territory (‘the National Law’) requires each National Board to develop and recommend to the Ministerial Council requirements about the English language skills necessary for an applicant for registration in the profession to be suitable for registration in the profession. A National Board may decide an individual is not a suitable person to hold practising categories of registration in the profession if, in the Board’s opinion, the individual’s competency in speaking or otherwise communicating in English is not sufficient for the individual to practise the profession. Further, the objectives of the National Law require National Boards to consider a number of factors when they recommend an English language skills registration standard to Ministerial Council. These include:
(a) to provide for the protection of the public by ensuring that only health practitioners who are suitably trained and qualified to practise in a competent and ethical manner are registered; and
(b) to facilitate workforce mobility across Australia by reducing the administrative burden for health practitioners wishing to move between participating jurisdictions or to practise in more than one participating jurisdiction; and
(c) to facilitate the provision of high quality education and training of health practitioners; and (d) to facilitate the rigorous and responsive assessment of overseas‐trained health practitioners; and (e) to facilitate access to services provided by health practitioners in accordance with the public
interest; and (f) to enable the continuous development of a flexible, responsive and sustainable Australian health
workforce and to enable innovation in the education of, and service delivery by, health practitioners.
In addition to this mandate, as affirmed by the 37 regulatory body interviews, ELSRS standards are inevitably shaped by the broader policy agendas and values of the national contexts in which they are embedded. Examples include the following:
In Canada the recent Pan‐Canadian agreement on internal trade (2009), and the federal foreign credential recognition initiative are now forcing development of common assessment standards across the 13 provinces and territories, despite significant regulatory body concerns. Advocacy for more liberal recognition of foreign credentials is also being spurred by the establishment of rights‐based Fairness Commissioners in four provinces, focused on immigrants.
In the UK and Ireland the multilateral European Union Directive has freed EU‐EEA nationals from the requirement to be assessed, in contrast to mandatory English language testing for ‘third country nationals’ ‐ the latter typically derived from Commonwealth countries, and/or native English speakers. Given this, credential and English language
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assessment are de facto outsourced to employers ‐ a matter of significant concern to the regulatory bodies. The EU Directive was under review at the time of writing. There was also a major review of the Professional and Linguistics Assessment Board (PLAB) being undertaken by the General Medical Council in 2012.
The US, confronting mass registration applications, in the 1990s devised the solution of a ‘single pathway, with the same (national) exams and same standards’ for local and international medical graduates. The USMLE includes an embedded medical English exam (replacing the TOEFL since 2004), followed by interview‐filtered selection to supervised residency places (compared to the use of stand‐alone English tests and national exams in other health fields). The National Council of State Boards of Nursing in the past decade has undertaken a range of benchmarking and standard‐setting review processes.
In New Zealand public safety standards must be upheld in the context of the highest rate of reliance on international medical and allied health professionals in the OECD, exacerbated by exceptional rates of out‐migration within a three year period.
In Singapore similar pressures exist, in a society where fertility rates have fallen to 1.1 (the world’s third lowest), and the recruitment/ retention of IHPs has emerged as a national priority.
Within this complex policy environment, specification of English language skills registration standards can also be influenced by a range of competing values, ranging from:
Protection of public safety – core to regulatory bodies’ mission, and the prime value to which they adhere.
Global competition for human capital resources – spurring under‐supplied countries/ regions to recruit/ retain international health professionals through relatively liberal registration standards.
Efficiency – maximising the utilisation and retention of international health professionals (particularly those who are sponsored).
Social justice – reflecting individual human rights‐based national/ state reform agendas designed to liberalise migrants’ access to registration (in cases such as Canada supported by a legislative base).
Government commitment to bilateral or multilateral agreements – designed to free trade in goods and services, supported by mutual foreign credential recognition (for example in Europe [EU] or the Asia‐Pacific [APEC]).
These pressures exacerbate the challenge of defining and defending appropriate English language standards. 5. Limits to the Research Base Supporting ELSRS Decision Making by Regulatory Bodies Within this context medical and allied health regulators reportedly often ‘inherit’ ELSRS standards and instruments, rather than prescribe these on the basis of field‐specific scientific research. They may have access to minimal health‐specific research to support the decision‐making process. According to a range of international key informants, operational factors can influence test choice ‐ most notably tests’ global availability (on and offshore), frequency of administration, competitive price, speed of results, and availability of preparatory courses. Regulators report modest to nil knowledge as to why specific test requirements or standards exist ‐ comments including that these
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were ‘heritage’ decisions (for example that ‘the test administrators/ experts advised this’, or ‘my predecessor might know’, or ‘it’s lost in the mists of time’). Once set, ELSRS requirements tend to be maintained – with standards lifted should complaints about practitioners’ facility occur. Exceptions include recent US reviews in the field of nursing, and detailed Canadian assessments of English requirements for nurses, pharmacists, physiotherapists and medical laboratory technicians. It is worth noting that the 2012 General Medical Council review of the Professional and Linguistics Assessment Board examination explicitly excluded the English language proficiency of international medical graduates. Rather, the review was designed to ensure4:
… that the Professional and Linguistic Assessments Board test continues to be an effective, objective, fair, and non‐discriminatory method to test whether international medical graduates have the knowledge and skills needed to work as doctors in the UK. This review will ensure that all our key interest groups continue to be confident in this method for assessment.6
Reviews such as this are inevitably resource and time‐intensive. Within the PLAB, assessment of effective communication is embedded in the objective structured clinical examination process (candidates being trainee doctors who have successfully completed the GMC Foundation Programme first year). It is worth noting however that the review panel sought explicit input on whether the PLAB examined ‘the right range of knowledge and skills required for safe and effective’ UK medical practice – a question with the potential to elicit views regarding English language capacity5. In terms of Australia the following ELSRS issues were raised by the 2010‐12 House of Representatives Inquiry into Overseas Trained Doctors ([OTDs] also relevant to the allied health professions)6:
1. The appropriacy of the standards required for professional registration (given the National Law requirement to register IMGs ‘able to communicate effectively in English to a standard expected of medical practitioners practising in Australia’).7
2. The scope of tests (including the perceived failure of current ELSRS standards to ensure practitioners possess the communication skills required for clinical practice).
3. Tests’ reliability and predictive capacity. 4. The length of validity of test results. 5. The impact of recent administrative changes (most notably National Boards’ 2010+
requirement for all four English sub‐tests to be passed at a single sitting). 6. The quality of rater training (in the context of perceived variability).
4 Issues to be addressed include the appropriacy of the PLAB, the standards set for both parts of the test (including whether these conform to best practice), the length of validity of passes, any limit to the number of attempts allowed, the PLAB’s reliability and validity in relation to differentiating between candidates, and (most importantly) ‘to examine whether international medical graduates granted full registration after passing the PLAB test are more or less likely than other cohorts of doctors to experience difficulties in medical practice in the UK’, based on a range of research sources. The PLAB was last reviewed in 2003. 5 General Medical Council (2012), ‘Call for Evidence on the Review of the Professional and Linguistic Assessments Board Test – 30 January‐30 April 2012’, General Medical Council. London, www.gmc.uk,org, p. 6. 6 Three Inquiry Recommendations (21‐23) directly address ELSRS standards and issues.
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7. The dearth of feedback provided to candidates (with a potential to improve future test performance).
8. The impact of ‘invisible’ English language tests (such as Australia’s Pre‐Employment Structured Clinical Interview8 which precedes the clinical placement process, and specialist college assessment). 9
The resulting Lost in the Labyrinth report (March 2012) affirmed ‘that a standard is needed as a medical practitioner’s ability to communicate effectively in English is a fundamental aspect of good quality and safe medical practice in Australia’.10 At the same time the specified limits to English language assessment for professional registration were confirmed to the Inquiry by the Chair of the Medical Board of Australia:
… the English language test is basic competency to speak, to listen, to write and to read. It does not deal with cultural awareness, and it does not deal with issues about the use of language in a medical cultural setting. That is supposed to be part of the orientation that people get in the work setting when they start work. It is supposed to orientate them to the cultural situation, the workplace, and the particular needs of that context.11
6. The Transforming ELSRS Context – Factors Influencing Migrant Health Professional Registration Applications to AHPRA
It is timely to review whether these limits to ELSRS scope remain appropriate, in the context of the recent transformation of health workforce migration to Australia. As defined by a 2012 Scoping Report prepared by Hawthorne for Health Workforce Australia12:
The scale of international health professional (IHP) arrivals has grown immensely in recent years (around 50,000 skilled category migrants approved every five years, with thousands of additional IHPs arriving as spouses or through the family and humanitarian categories). A growing number of migrants will therefore apply to AHPRA onshore (unfiltered in advance for human capital attributes).
Source countries have become exceptionally diverse (now spanning up to 210 nations).
Health fields have changed (with nurse arrivals exceeding those in medicine, plus rapid recent growth in pharmacy, physiotherapy and dentistry).13
Temporary rather than permanent entry has become the norm (the entry mode for four‐fifths of recent international medical graduates [IMGs] in Australia).
The majority of skilled migrants are currently sponsored – with 457 visa health professionals immediately commencing clinical work, typically on the basis of limited or restricted registration.
Within this context, clinical communication skills have become increasingly important (despite these not being the original focus of Australian ELSRS requirements).
English language testing is now high stakes – by 2012 the key determinant of migrant health professionals’ selection, registration and early employment outcomes.
In the past decade unprecedented numbers of international students have also qualified in Australia and seek to remain. By 2010 18,487 international students were enrolled in medical or allied health degrees, including around 3,000 medical and 9,000 nursing students. An estimated 78% of medical students to 2012 secured PGY1 places14. Around eight‐ninths of recent nurse
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applicants to ANMAC for skilled migration assessment have been from former international students in Australia. Universities seem likely to pressure National Boards to allow such applicants test exemptions.
7. Key English Language Skills Registration Standards (ELSRS) Issues The following section summarises key ELSRS project findings, based on analysis of the global literature, information provided by the 61 key informants, and the OET database analysis. For more detail see Attachment 1 (Global Benchmarking Eight Country Audit) and Attachment 2 (English Test Genesis and Instrument Audit), noting these were finalised late 2012.
7.1 The Limits to the Research Base In an age of globalization, the English ability of international health professionals represents a critical public safety issue. Language testing instruments are required, with high standards set. The Boards’ current use of IELTS and the OET may be entirely appropriate. At the same time the first Australian study to assess medical complaints found international graduates had 24% higher odds and a 41% higher risk of adverse findings, with IMGs at disproportionate risk qualified in Nigeria, Egypt, Poland, Russia, Pakistan, the Philippines, and India. The authors noted these ‘“at risk” countries… share some similar features: English is not the primary language, and all have medical education and health systems that are quite different to Australia’s. However, this explanation is incomplete because the same can be said of several other countries.”15’ Additional research is required to assess the association between ELSRS standards and field‐specific complaints in select fields, noting that non‐native speakers of English such as Chinese or Vietnamese IMGs were not found to be experiencing significant problems. The literature to inform English language skills registration standards for health professionals to date is in fact slight. Few health‐specific studies exist. Many are based on small sample sizes. There are major research gaps. (For example the majority of studies have focused on medicine, despite growing registration demand in allied health fields.) Test designers frankly acknowledge the limits to their research base, reflecting sparse funding and methodological challenges. They also note their position as ‘perpetual outsiders’ in defining English performance requirements ‐ attempting to capture for the purposes of test design authentic speaking, listening, reading and writing requirements, while ensuring ‘item fit’ (for example through the use of Rasch analysis).16 7.2 The Merits of Generic Compared to Field‐Specific Tests As noted, operational factors favour the use of IELTS – key attractors being its relative cheapness (a third the cost of the OET), global availability and frequency, plus access to preparatory courses and practice materials.17 This is despite the fact that IELTS was designed to assess international students’ readiness to undertake tertiary English‐medium study. There has been minimal investigation to date of the validity of using generic tests to assess candidates’ performance in health‐specific contexts. According to the Cambridge consortium, the test’s ‘communicative ability is… sensibly moderate. Its delivery… is impressive. It is well‐maintained and research‐led. It tests, very deliberately, all four skills’.18 At the same time, as noted in an IELTS Research Report, ‘The question of whether the IELTS testing system is
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appropriate for testing broader skills such as those required for a professional operating as a doctor, nurse, veterinary surgeon, engineer, teacher or accountant arises because there is little research which focuses on validating the testing system for these purposes.’19 As affirmed by the 61 interviews this is a volatile policy space. In Canada, for instance, consideration is increasingly being given to the design of field and country‐specific language tests. By contrast the US is satisfied with the relevance and appropriacy of its embedded USMLE Clinical Skills English language test in medicine, while Singapore champions the value of maintaining interview‐based assessment in the field of nursing. 7.3 Standard‐Setting for Registration National Boards currently mandate identical English language standards for each health field, the exception being pharmacy. No substantial studies however have been commissioned to inform this decision to date, though advice from clinical settings and test administrators is regularly considered. This is also largely the case overseas – with select Canadian and US benchmarking exercises being exceptions. In the US, for instance, 2500+ ECFMG candidates were reviewed in 10‐11 Clinical Skills Assessment encounters. Generalizability theory was used to assess the consistency of spoken English ratings. A high level of reliability was found across 10 independent evaluations. Proficiency in spoken English was correlated with TOEFL scores and native language status (English compared to ‘other’). The researchers were in a position to conclude that ‘valid measures of spoken English proficiency’ were obtained. They also found a ‘high reproducibility of the ratings over encounters and standardised patients’ in simulated medical environment. Within this context, the ECFMG is confident of its standards and current processes7. While current National Board standards may be appropriate, as demonstrated by analysis of the OET database from 2005‐2011 they have highly differential impacts by field. In 2011, for example, 62% of dental and 52% of medical candidates passed the OET, compared to 38% of pharmacists, 32% of physiotherapists, and 17% of nurses. Nurses fared exceedingly poorly on the OET all seven years examined, with particular impact on select countries of training (such as the Philippines and China). According to one IELTS paper, ‘In 2010, the Nursing and Midwifery Board of Australia raised the English language proficiency requirement for registration as a nurse to an Overall score of 7.0 in the Academic module of the IELTS Test, with 7.0 in each of the components that comprise the Test… Although little research has been conducted into the relevance of this score for professional employment, an IELTS score of 7.0 is fast becoming instituted as the standard to which all NESB candidates seeking professional employment in Australia should aim.’20 Is this standard warranted? Alternatively, given the medical complaints study noted, should ELSRS standards in that field be higher? This is currently unknown. 7.4 Exemptions from English Language Testing – Native Compared to Non‐Native Speakers Defining exemptions from English language testing is also challenging. In 2011 just 62% of UK and 74% of South African candidates passed the OET (all fields). Very substantial numbers would have been native speakers of English, with an estimated third being non‐native speakers migrating
7 Boulet, J, Van Zanten, M, McKinley, D & Gary, N (2001), ‘Evaluating the Spoken English Proficiency of Graduates of Foreign Medical Schools’, Medical Education Vol 35: 767-773.
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through the UK8. This raises the issue of whether it is appropriate to exempt native speakers (NS) from taking ELSRS tests, when evidence suggests many would perform poorly. There have reportedly been no studies to date assessing native speaker compared to non‐native speaker (NNS) performance on the OET. A range of IELTS studies have been conducted, though not in relation to health. According to one such study, many native speakers would be rated Band 5 (or Modest User) on the IELTS scale – ie ‘Has partial command of the language, coping with overall meaning in most situations, though is likely to make mistakes. Should be able to handle basic communication in own field.’ Research suggests the scores of native English speakers are neither homogenous nor high (this research based on TAFE‐enrolled students); that many native speakers would be ineligible to commence university studies if required to reach IELTS scores of Band 6 or above (particularly on all four sub‐tests); and that significant differences exist even between highly educated native speakers (eg barristers outperforming tertiary education lecturers)9. These findings raise significant equity issues21. It is in part for this reason that the UK and Ireland currently allow no automatic exemptions from English language testing for native English speakers who are third country nationals (despite this measure appearing to defy common sense). Universalising English testing however would have significant registration impacts in Australia. It would make it a less attractive destination to native English speaking health professionals (for example from South Africa, Ireland or the UK). 7.5 Exemptions from English Language Testing – Former International Students The research confirmed defining test exemptions for former international students qualified in Australia to be similarly problematic. While tertiary institutions set entry scores, there is no certainty students’ English ability will subsequently improve. As demonstrated by the largest study to date (initiated by DIAC), substantial numbers of international students exit their Australian degrees with IELTS scores of Band 5 or below.22 Language gains of half an IELTS Band may be expected when students study English full‐time for three months.23 Research demonstrates however minimal IELTS gains between entry and exit scores for students completing degrees, over enrolment periods spanning 3 to 4.5 years. While some students improve, others get worse, and many remain stable.24 Few longitudinal studies on this issue exist. Despite such evidence, National Boards seem certain to be lobbied by universities to provide former international students with English language test exemptions. These are currently allowed in a range of comparator jurisdictions such as Canada, Ireland, Singapore and New Zealand (noting some variations by field). Countries may also exempt students qualified wholly in the medium of English, or holding degrees from the UK, USA, Canada, Australia or New Zealand.
8 We note that up to a third of skilled applicants to Australia from the UK may be third country nationals, based on advice to L Hawthorne in the years since 1996 from the Department of Immigration and Citizenship. South African nationals also include third country nationals, and/or non-native speakers of English (eg Afrikaans speakers). 9 McNamara, T. (1996), Measuring Second Language Performance (Longman, UK), see Chapter 7, ‘Mapping and Reporting Abilities and Skill Levels’, pp. 182-197.
14
7.6 The Requirement to Pass All English Four Sub‐Tests at a Single Sitting Based on the literature review and interviews, there is minimal evidence to date to support Australia’s 2010+ requirement for candidates to pass all four English language sub‐tests at a single sitting – a measure resulting in significant registration delays and cost. As demonstrated by the OET database analysis, for example, 18% of Filipino candidates passed all 4 sub‐tests in 2011, compared to a 37% pass rate in 2005 when this was not required. The measure has proven particularly challenging for nurses, whose pass rates fell for most countries of training (including ‐20% for South Korea, ‐17% for China and ‐10% for the Philippines). IELTS administrators state they require proof of all four skills in a single administration to allow ‘a maximally reliable composite assessment of a candidate’s overall language proficiency… This is the way the test has been built, it is not a modular test and therefore the four component modules are not offered as separate tests to be taken at different times’.10 The requirement is also reportedly an administrative convenience to IELTS, which is not imposed in a range of comparator countries (for example in select fields in Canada, New Zealand and Ireland).25 The risk of language attrition between attempts is a further rationale (though IELTS administrators concede this typically occurs at lower rather than higher English proficiency levels). At the same time it has been confirmed by an IELTS study that native speakers (typically associated with a mean score of Band 7) perform with ‘unexpected’ variability across different subtests26. OET administrators see no justification in this policy measure, despite similar revenue benefits. According to the OET, ‘Our stance against the 4‐in‐1 policy is supported by the academic literature surrounding attrition, particularly for learners at higher‐level proficiencies. Given the relatively high point ‘on the ladder’ represented by the current standard… it is fundamentally unfair to require higher‐level achievers to repeatedly demonstrate competency in a sub‐skill (they have already demonstrated it) and it is unlikely to diminish quickly’. It makes better sense ‘to define the skill/s which need practice, and address this for the benefit of ‘boards and professions and patients’.27 The language testing experts consulted for the present study agreed.
7.7 Length of Test Result Validity Similar points were raised concerning Australia’s two year period for test result validity – an issue which received attention in the House of Representatives Inquiry on OTDs (see the Lost in the Labyrinth 2012 report). A range of studies have demonstrated that ‘high proficiency learners plateau for several years until attrition begins’. Should a test score ‘shelf‐life’ be applied, testing experts advise this should differentiate between high and low level candidates, in a context where those scoring IELTS 7 and OET B (or higher) would be ‘likely to show little loss (of skills) for up to 4 years, even with little or no use’.28 A two year validity period however is common across comparator jurisdictions.
10 It is worth noting that New Zealand has maintained a 12 month cumulative pass option for nurses, which IELTS has
been obliged to accept.
15
7.8 Test Validity Test validity represents a critically important issue. In addition to the attraction of face validity (where test content may appeal to candidates, despite being statistically irrelevant29) research concerning validity addresses fitness for purpose, including:
Construct validity ‐ the design and construction of the components of the test.
Content validity – whether a test is based on a job analysis (ensuring the representativeness of the sample to)… select tasks to represent the job… develop a rating form’).
Predictive validity – examining ‘the extent to which the predictions we would make in the basis of test performance about subsequent performance in the criterion situation are borne out’.
Consequential validity – assessment of the impact of the tests in the real world, including the nature of candidates’ ultimate performance in a context where ‘the broader impact of language tests in terms of …. the life chances of test candidates… has hardly been studied’.30
Development of appropriate rating criteria – to determine ‘how performances will be judged (and) the relevant criteria against which judgements are made’.
While some research has been conducted on test validity in relation to the OET, focused on the first three aspects, there is a dearth of research to date on the test’s predictive or consequential validity. No research examining the validity of IELTS for health professional registration could be found, despite the existence of a substantial number of validity studies31. This represents a significant issue ‐ one raised by the House of Representatives inquiry, in a context where substantial numbers of sponsored migrants in the past decade immediately secured clinical employment without the extended supervised period once presumed. The latter remains mandatory in many comparator jurisdictions (for example in the US for USMLE candidates who must undertake residencies; in Canada where internationally trained dentists must repeat the last two years of university study; and in Ireland where pharmacists must undertake internships, with ‘a very risk‐adverse patient focus and approach taken to all decision‐making’). As demonstrated by the literature, effective clinical communication is an immensely complex task. It requires fluent English, adroit cross‐cultural awareness, empathy, use of specialist terminology, idiom and jargon, and a capacity to adapt communicative style to a variety of situations. These skills far exceed English. While there is scope to design more targeted tests, experience to date however suggests proposals for integrating clinical and language assessment are likely to be ruled out, deemed ‘too complex and costly by the profession’32. Given these limitations, the designer of the OET (for instance) notes it is important to ‘be modest about any claims one may wish to make that tests such as the Occupational English Test provide information on ‘the ability of candidates
to communicate effectively in the workplace’33. The same would be true of IELTS.
16
7.9 Test Reliability The reliability of test results is an important issue. IELTS has been associated with significant problems in terms of this in the past. According to Australia’s 2005‐06 skilled migration review, test‐takers at this time had ‘a 40% chance of securing a different (IELTS) result on re‐testing, based on a .77 published reliability score for speaking and writing’.34 While in 2011 IELTS reported a higher level of reliability had been gained, there reportedly remains no certainty that spoken and written tests will be double‐marked35. Within this context, the test experts interviewed observed problems with securing consistent speaking and writing scores. The OET is reported to perform relatively well in terms of reliability, following significant recent improvements. A global literature has evolved concerning rater reliability – a major challenge for ‘performance’ rather than discrete item MCQ tests (the IELTS and the OET being the former, the TOEFL being the latter).36 Research demonstrates candidate assessment in the speaking test to be influenced by raters’ professional background, interpersonal style, gender, variable use of the rating criteria, assessment mode (whether by distance or in person), topic choice etc.
7.10 Provision of Candidate Feedback Finally, as noted by the House of Representatives inquiry, candidates to date receive minimal feedback on their English language standards for registration. There is a dearth of research related to feedback issues.
8. Conclusion As defined in the Executive Summary, a key objective of the National Registration and Accreditation Scheme is to ensure the protection of the Australian public, including through ‘the rigorous and responsive assessment of overseas‐trained health practitioners’. Specification of English language skills registration standards is central to this process, in an age of globalization where Australia is importing around 50,000 international health professionals every five years. The majority of IHPs are sponsored on 457 visas, to address workforce maldistribution and undersupply. Derived from highly diverse source countries, these migrant professionals have immediate prospects of clinical employment (particularly in medicine). The Boards’ current registration requirements may be entirely appropriate and fit for purpose. At the same time Australian policy is founded on a limited (and at times questionable) evidence base, as in a range of comparator jurisdictions. Further research concerning the effectiveness of the instruments used, their predictive capacity, and the standards required for clinical practice seems warranted. Globally and within Australia, language testing for registration has entered a dynamic policy phase, with a range of regulatory bodies reviewing their practice.
17
SNAPSHOT ‐ KEY RESEARCH FINDINGS
Issue
Finding
Uses of English language testing
Global uses of English language testing include the determination of refugee status, eligibility for citizenship, control of international student entry and placement, selection of skilled migrants, and access to professional registration. Within this context English testing has emerged as a lucrative global business, with market share tenaciously sought.
Major tests Since the 1950s the mobility of international students has driven instrument development (including the IELTS, TOEFL and recent Pearson tests). The OET by contrast was designed in Australia to assess speaking, listening, reading and writing skills in linguistic contexts simulating future professional practice (12 medical and allied health fields).
Current significance of English language testing in Australia
By July 2012 English language assessment had become Australia’s key criterion for skilled migrant selection, alongside qualification level and employer sponsorship. It is the main hurdle to professional registration in the medical and allied health fields.
Use of English language testing by Australian regulatory bodies
By 2012 48 Australian regulatory bodies had mandated IELTS for registration purposes (compared to the dominance of TOEFL in select parts of Asia and North America). Highly diverse requirements have been set (ranging from Band 6 to Band 8). There is minimal specialist research to date to inform standard‐setting for the health professions in Australia or overseas.
The ELSRS research base Seventy‐three IELTS Research Reports have been published by the Cambridge consortium in the past two decades. Just four have assessed standards for professional regulation purposes, typically on an audit rather than a validation basis. According to the author of two such reports, ‘IELTS was originally intended and designed as a set of international benchmarks to assess an individual’s proficiency for academic study in English‐speaking contexts… The growing trend for IELTS to be adopted by users outside of academic, including governments, professional associations and employers, may constitute a risk for the test owners if the assessment system cannot be validated for the purposes for which it is being used.’
The Australian ELSRS context
In Australia the Health Practitioner Regulation National Law in force in each state and territory (‘the National Law’) requires each National Board to develop and recommend to the Ministerial Council requirements about the English language skills necessary for an applicant for registration in the profession to be suitable for registration in the profession. A National Board may decide an individual is not a suitable person to hold practising categories of registration in the profession if, in the Board’s opinion, the individual’s competency in speaking or otherwise communicating in English is not sufficient for the individual to practice the profession.
18
Recent trends in Australia It is important to note the scale of international health professional arrivals has grown immensely (around 50,000 skilled category migrants approved every five years); source countries have become exceptionally diverse; health fields have changed; temporary rather than permanent entry has become the norm; the majority of IHPs are currently sponsored (with clinical communication immediately important); and substantial numbers of health professionals have qualified onshore (the study‐migration pathway likely to lead to requests for English language testing exemptions).
The impact of broader societal trends on ELSRS standards
The 37 regulators interviewed for the ELSRS project affirmed their prime responsibility to be the protection of public safety and the maintenance of stringent regulation standards. Despite this, standards are inevitably influenced by the broader policy agendas and values of the national/ state contexts in which regulators are embedded. Factors include health workforce shortages; agreements to facilitate worker mobility and internal trade; rights‐driven credential recognition initiatives; changed skill migration policies; overriding bilateral and multilateral agreements (etc). Pressures such as these can be seen as jeopardising ESLRS standards (for example allowing automatic test exemptions for EU‐EEA nationals in the UK and Ireland). The EU Directive is under 2012 review, with key informants suggesting language testing exemptions may be challenged.
Global ELSRS practice in medical and allied health fields
Global regulatory bodies adopt highly variable requirements in terms of English testing. This is currently a dynamic policy space. As demonstrated by the eight country web audit (Attachment 1), and 50 interviews conducted with key informants, regulators may specify few or multiple tests (Attachment 2); different test types (ranging from generic, to field‐specific, to embedded, to interview‐based); require diverse scores by test and field; allow different types of exemption; permit variable lengths of result validity (ranging from 6 to 24 months); and impose different operational requirements (for example to pass sub‐tests at a single or sequential sittings).
Limits to the research base In an age of globalization, the English ability of international health professionals is regarded as a critical public safety issue. Tests are clearly required, with high standards set. In Australia the Boards’ use of IELTS and the OET may be entirely appropriate. The literature to inform English language skills registration standards however to date is slight. Few health‐specific studies exist. Many are based on small sample sizes. There are major research gaps. A 2012 analysis of Australian medical complaints data found international graduates had 24% higher odds and a 41% higher risk of adverse findings, with select IMGs who were non‐native speakers of English and trained in quite different systems at disproportionate risk. Within this context there may be English‐related issues, however this is unknown.
Issues raised by the House of Representatives 2010‐12 inquiry on IMGs
The following ELSRS issues were raised by the 2010‐12 House of Representatives Inquiry into Overseas Trained Doctors (of relevance also to the allied health fields): the English standards required for professional registration; the choice and scope of tests; their stability, reliability and predictive capacity; the length of validity of test results; the impact of the requirement to pass all four subtests at a single sitting; the quality of rater training; the dearth of performance feedback to candidates; and the impact of ‘invisible’ English language tests (such as PESCI or specialist college
19
interviews).
Generic compared to field‐specific tests
The ELSRS literature review undertaken demonstrated there has been minimal global or Australian investigation of the validity of using generic tests to assess candidates’ performance in health‐specific contexts. As noted in an IELTS Research Report, ‘The question of whether the IELTS testing system is appropriate for testing broader skills such as those required for a professional operating as a doctor, nurse, veterinary surgeon, engineer, teacher or accountant arises because there is little research which focuses on validating the testing system for these purposes.’ According to the 50 ELSRS interviews, tests are typically ‘inherited’ rather than recently chosen, with the rationale for instrument choice often ‘lost in the mists of time’.
Standard‐setting There is minimal evidence to support ELSRS standard‐setting in the health professions to date (for the IELTS or the OET). While National Board requirements may be appropriate, tests also have differential impacts by field. In 2011, for example, 62% of dental and 52% of medical candidates passed the OET on first or repeated attempts, compared to just 38% of pharmacists, 32% of physiotherapists, and 17% of nurses.
Test exemptions Defining English test exemptions is challenging. There have been no studies
to date assessing native speaker (NS) compared to non‐native speaker (NNS) performance on the OET. In terms of IELTS research the scores of native English speakers are revealed to be neither homogenous nor high; many native speakers completing secondary education would be ineligible to commence medical or allied health university studies if required to secure IELTS scores of Band 7 or above (particularly on all four sub‐tests); and significant differences exist even between highly educated native speakers (eg barristers outperforming tertiary education lecturers in terms of scores). For this reason the UK and Ireland allow no automatic exemptions from English language testing for third country nationals who are native English speakers. Defining test exemptions for international students qualified is similarly problematic. Research demonstrates minimal IELTS gains between entry and exit scores for students completing degrees, over enrolment periods spanning 3 to 4.5 years.
Requirement to pass all four subtests at a single sitting
There is minimal available evidence to date to support Australia’s 2010+requirement for candidates to pass all four English language sub‐tests at a single sitting – a measure resulting in significant registration delay and cost. IELTS mandates this (though some jurisdictions have refused). OET administrators report no scientific justification.
Length of test result validity
The length of test result validity may merit review (particularly for candidates resident and engaged in clinical practice in Australia). A range of studies have demonstrated that ‘high proficiency learners plateau for several years until attrition begins’, within minimal change anticipated in a 3‐4 year period.
Test validity While some research has been conducted on test validity in relation to the OET, there is a dearth of scientific evidence to date concerning the test’s predictive or consequential validity (which reportedly has not been commissioned). No research examining the validity of IELTS for health professional registration was found, despite the existence of a substantial
20
range of IELTS validity studies.
Test stability and reliability IELTS has been associated with significant problems in terms of stability in the past. According to Australia’s 2005‐06 skilled migration review, test‐takers at this time had ‘a 40% chance of securing a different (IELTS) result on re‐testing, based on a .77 published reliability score for speaking and writing’. While in 2011 IELTS reported a higher level of reliability had been gained, there remains no certainty that spoken and written tests will be double‐marked. The OET is reported to perform relatively well in terms of reliability, following significant recent improvements on select tests.
Rater reliability A global literature has evolved concerning rater reliability – a major challenge for ‘performance’ rather than pen and paper tests (the IELTS and the OET being the former, the TOEFL being the latter). Research demonstrates candidate assessment in the speaking test to be influenced by raters’ professional background, interpersonal style, gender, variable use of the rating criteria, assessment mode (whether by distance or in person), topic choice etc.
Conclusion A key objective of the National Registration and Accreditation Scheme is to ensure the protection of the Australian public, including through ‘the rigorous and responsive assessment of overseas‐trained health practitioners’. Specification of English language skills registration standards has become central to this process, in an age of globalization where Australia is importing around 50,000 international health professionals every five years. The National Boards’ current ELSRS requirements may be entirely appropriate and fit for purpose. At the same time Australian policy is founded on a limited (and at times questionable) evidence base. This is also the case in a range of comparator jurisdictions. Within this context, further research on the effectiveness of the instruments used, their predictive capacity, and the standards required for clinical practice seems warranted. A positive exemplar is the ECFMG validation process undertaken. (See Executive Summary.)
21
1 For a detailed analysis of the evolution of IELTS, and its merits, see Davies, A (2008), Assessing Academic English – Testing English Proficiency 1950‐1989 – The IELTS Solution, Studies in Language Testing 23, University of Cambridge ESOL Examinations, Cambridge University Press.
2 Blacket, R (1990), ‘Foreign Medical Graduates: The Experience of the Australian Medical Examining Council and the Australian Medical Council – Implications for Medical Immigration and the Medical Workforce’, Medical Journal of Australia, Vol 153, August 6, p. 129. 3 For a detailed analysis of the development and trialling of the OET, see McNamara, T (1990), Assessing the Second Language Proficiency of Health Professionals, PhD Thesis, Department of Linguistics and Language studies, University of Melbourne. 4 Department of Immigration and Citizenship (2010), ‘Employer Sponsored Workers – September 2009 Changes to the English Language Proficiency Requirements’, http://www.immi.gov.au/skilled/skilled‐workers/changes‐eng‐req.htm, accessed 16 August 2012. 5 Merrifield, G (2012), ‘An Impact Study into the Use of IELTS by Professional Associations and Registration Entities – Canada, the UK and Ireland’, IELTS Research Reports, Volume 11, www.ielts.org, accessed 30 July, p. 5, 11; Merrifield, G (2008), ‘An Impact Study into the Use of IELTS by Professional Associations and Registration Entities – Australia, New Zealand and the USA’, IELTS Research Reports, Volume 8, www.ielts.org, accessed 30 July, p. 5, 11. 6 General Medical Council (2012), ‘Broad Themes of the Review and Members of the Working Group’, http://www.gmc‐uk.org/static/documents/content/Broad_themes_of_the_review_and_members_of_the_working_group.pdf, accessed 1 July 2012, p. 1. 7 Ibid, p. 50. 8 A PESCI ‘is used to assess an IMG’s suitability for a particular role based on the assessed risks of the particular position. It requires the IMG to undergo a structured interview based on clinical scenarios to demonstrate that they have the knowledge, skills and experience to work in a particular position. The PESCI is conducted under the auspices of AMC accredited providers by a panel of at least three members, two of whom need to be familiar with the clinical and professional demand of the type of position involved’. 9 House of Representatives Standing Committee on Health and Ageing (2012) Lost in the Labyrinth Report on the Inquiry into Registration Processes and Support for Overseas Trained Doctors, Parliament of the Commonwealth of Australia, March, Canberra, p. 87‐88. 10 Ibid, p. 130. 11 Ibid, p. 200‐201 12 Hawthorne, L (2012), Health Workforce Migration to Australia – Policy Trends and Outcomes 2004‐2010, Health Workforce Australia, Adelaide, http://www.hwa.gov.au/work‐programs/international‐health‐professionals/health‐profession‐migration
22
13 Health Workforce Australia (2012), Health Workforce 2025, Volume 1 and Volume 2, Health Workforce Australia, Adelaide. 14 Hawthorne, L (2012), ‘International Medical Migration – What is the Future for Australia?’, Special Issue, Medical Journal of Australia Open, 197(2), 23 July, Medical Workforce – Towards 2025 Volume 2 Supplement 1 18‐21; Hawthorne, L & To, A (2012), The Early Migration and Career Trajectories of International Medical Students Qualified in Australia, Medical Deans of Australasia, Sydney,
15 Elkin, K, Spittel, M & Studdert, D (2012), ‘Risks of Complaint and Adverse Disciplinary Findings Against International Medical Graduates in Victoria and Western Australia’, Medical Journal of Australia 197 (8), 15
October, p. 450. It should be acknowledged that L Hawthorne is one of K Elkin’s PhD supervisors, with this paper based on her doctoral research. 16 McNamara, T (1996), Measuring Second Language Performance, Longman, Sydney, Chapter 6; Sarangi, S (2003), ‘Introduction – Trading Between Reflexivity and Relevance: New Challenges for Applied Linguistics’, Applied Linguistics, Vol 24 No 3, pp. 283‐4; Candlin, C & Candlin, S (2003), ‘Health Care Communication: A Problematic Site for Applied Linguistics research’, Annual Review of Applied Linguistics, Vol 23, No 8. 17 Read, J & Wette, R (2009), ‘Achieving English Proficiency for Professional Registration: The Experience of Overseas‐Qualified Health Professionals in the New Zealand Context’, IELTS Research Reports, Volume 10, No. 4. 18 Ibid, p. 110. 19 Merrifield (2008), op cit. 20 Ibid., p. 4. 21 Ibid, p. 197. 22 Birrell, B, Hawthorne, L & Richardson, S (2006). Evaluation of the General Skilled Migration Categories, Commonwealth of Australia, Canberra, 2006. 23 Elder, C & O’Loughlin, K (2003), ‘Score Gains on IELTS After 10‐12 Weeks of Intensive English Study’, IELTS Research Reports, Volume 4, IELTS Australia Pty Ltd, Canberra. 24 Craven, E (2012), ‘The Quest for IELTS Band 7.0: Investigating English Language Proficiency Development of International Students at an Australian University’, IELTS Research Reports, Volume 13, p. 11. 25 Maret, B (2012), Emailed advice to L Hawthorne received 19 June, from IDP Education Australia, in relation to the research evidence to support the requirement for all four IELTS sub‐tests to be passed at a single sitting. 26 Davies, A (2008), op. cit., p. 96. 27 Advice received on this issue to Hawthorne’s emailed request on 15 June 2012, from the Manager of the Occupational English Test Centre, Melbourne. 28 Roever, C (2009), ‘Attrition and Language Testing – Shelf‐Life of Test Scores and What it Means for the OET’, School of Language and Linguistics, University of Melbourne, Presentation at OET Conference, Melbourne.
23
29 Davies, A (2008), op. cit., see pp. 94-98 regarding the rationale for IELTS shifting from field-specific modules to a generic version. 30 McNamara, T (1996), op cit., p.16‐25. 31 See Davies, A (2008), op. cit. 32 This comment was made by one of the language testing experts interviewed, who is Australia‐based, and has very substantial international experience. By agreement, no individual informants are identified in this study. 33 McNamara, T (1996), op cit., p. 41.
34 Birrell, B, Hawthorne, L & Richardson, S (2006), Evaluation of the General Skilled Migration Categories, Commonwealth of Australia, Canberra, p. 111. 35 The authors had a series of email communications to B Maret, B (2012), from IDP Education Australia, in relation to this issue, which was not clarified at the time of the study’s completion (late 2012).
36 See for example Lumley, T & O’Sullivan, B (2005), ‘The Effect of Test‐Taker Gender, Audience and Topic on Task Performance in Tape‐Mediated Assessment of Speaking’, Language Testing, Vol 22 No 4; McNamara, T & Lumley, T (1997), ‘The Effect of Interlocutor and Assessment Mode Variables in Off‐Shore Assessments of Speaking Skills in Occupational Settings’, Language Testing, Vol 14; Elder, C (2005), ‘Individual Feedback to Enhance Rater Training: Does It Work?’, Language Assessment Quarterly, Vol 2, No. 3; Brown, A (2000), ‘An Investigation of the Rating Process in the IELTS Oral Interview’, IELTS Research Reports, Volume 3, No 3.
FINAL Contrastive Country Audit
5 November 2012
ELSRS Attachment 1:
Global Benchmarking – Eight Country Audit
Please note:
• The English language skill registration standards (ELSRS) reported below were derived from our global web audit (conducted January 2012, updated
October 2012). This detailed audit was supplemented by reference to data derived from the transcribed interviews conducted with 61 ELSRS key
informants, which for a range of countries/ fields referenced current policy developments including reviews.
1. Australia
Policy
Overview Prior to 2008: There were variations in registration requirements between both the Australian states and territories, and the different health
professions.
March 2008: The Council of Australian Governments (COAG) created the National Registration and Accreditation Scheme (NRAS) to make
consistent registration requirements for 10 health professions; and English proficiency standards among the elements of registration were
revised. These were applied to temporary as well as permanent skilled migrants for selection and registration purposes.
Test options: For the purposes of professional registration, passes are required in the IELTS or OET tests, as defined below.
National Variability
Standards are uniform nationally and there are only minor differences between standards for the five health professions, as detailed below.
Skilled Migration General Skilled Migration (GSM):
• Specific requirements are in place with 65 points required for GSM selection.
• All applicants (regardless of country of origin) are required to pass English language test before visa application is lodged.
• Minimum requirement is a band score of 6 in each of the four components of the IELTS test (or equivalent standard in a specified test)
• Bonus points are solely awarded if applicants achieve IELTS (or equivalent) score of at least 7 in each test component, with 20 bonus points
for IELTS band 8 (with English and qualification level from July 2011 the key determinants of selection).
Temporary Skilled Migration (457 visa):
• Applicants must be sponsored by an employer to fill a nominated position.
• English language testing mandated for temporary health professionals.
• Exemptions apply for holders of passports from Canada, New Zealand, Republic of Ireland, United Kingdom or United States of America if
24
FINAL Contrastive Country Audit
5 November 2012
they are nominated in an occupation that does not require a level of English competency for grant of registration, license or membership.
• Applicant would need to have at least the English proficiency standard required for registration license or membership for nominated
occupation.
Key Trends March 2010: Changes to English language skills registration standards (detailed below) were approved by the Australian Health Workforce
Ministerial Council and legislated by the Health Practitioner Regulation National Law Act 2009.
Implemented: From 1 July 2010 (Western Australia joining October 2010)
Australian Health Practitioner Regulation Agency (AHPRA): Governed by the National Law and from July 2010 are responsible for implementing
the NRAS across the country.
National Health Practitioner Boards: Currently there are 10 Boards responsible for regulating their respective professions, supported by AHPRA.
Additional National Boards are to be established in 2012.
Target Groups Health professionals who were not taught and assessed in English: If an applicant is internationally qualified or did not undertake and
complete their secondary education in English, or in Australia, Canada, New Zealand, Republic of Ireland, South Africa, United Kingdom and
United States of America, they must submit evidence of their competency in English language.
Governance Medical Board of Australia Nursing and Midwifery
Board of Australia
Dental Board of Australia Physiotherapy Board of
Australia
Pharmacy Board of
Australia
Test Instruments and Levels
Instrument Medicine Nursing Dentistry Physiotherapy Pharmacy
IELTS Overall: 7, Speaking: 7, Writing: 7, Listening: 7, Reading: 7
Note: For Dentistry, IELTS was accepted from 1 July 2010 where previously OET was the only test accepted.
Overall: 7.5, Speaking: 7,
Writing: 7, Listening:
7, Reading: 7
OET Overall: B, Speaking: B, Writing: B, Listening: B, Reading: B
Additional
Conditions
Evidence that they have
completed 5
equivalent FT years of
education1 taught and
1 This must include pre-registration program of study of 2 FT equivalent years for nurses and midwives, and 1 year for enrolled nurses that is approved by the relevant
nursing and/or midwifery regulatory body.
25
FINAL Contrastive Country Audit
5 November 2012
assessed in English in
any of the recognised
countries listed as
exempt below.
• Since 2010, IELTS and OET passes must be achieved in one sitting.
• Test passes must have been obtained within 2 years prior to applying for registration. Test results will be accepted as current if:
o the candidate has actively maintained employment2 in their profession using English as the primary language of practice in a
country where English is the native language since the test; or
o they are registered as a student in an approved program of study (for Medicine only; programs not listed in standard); or
o they are continuously enrolled in a program of study taught and assessed in English and approved by the recognised nursing
and/or midwifery regulatory body in any of the countries listed in the registration standard below (for Nursing, Midwifery and
Enrolled Nurses only; programs not listed in standard)
• Board reserves right to revoke exemptions listed below
Exemptions
Successful completion of :
• Professional and
Linguistic
Assessments Board
(PLAB) (UK); or
• New Zealand
Registration Exam for
Overseas Doctors
(NZREX).
From 19 September 2011:
• Board has discretion
to grant exemptions
where there is
compelling evidence
demonstrating English
language proficiency
equivalent to the
required standard.
• Applicants registered
as RN or midwife in
New Zealand.
Prior to 19 September:
• Discretion to grant
exemptions due to
compelling reasons
was not stated.
• No exemptions for
As detailed below. As detailed below.
Limited registration
exemptions are
usually related to
postgraduate training
where students would
be considered for an
exemption if they just
fell short of the
language test
requirements.
As detailed below.
2 For Dentistry, although it is not formally written in policy, the Board may accept a test that is older than two years if the applicant is enrolled in a course approved by the
Board.
26
FINAL Contrastive Country Audit
5 November 2012
select countries of
training (including
English speaking
background
countries) existed.
Criteria: If the applicant provides evidence that they undertook and completed secondary education that was taught and assessed in English in
one of the countries listed below. And if the applicant’s tertiary qualifications in the relevant professional discipline were taught and
assessed in English in one of the listed countries below.
Countries: Australia, Canada, New Zealand, Republic of Ireland, South Africa3, United Kingdom and United States of America.
Limited registration: Board may grant exemptions where applicants apply for limited registration, such as:
• To perform a demonstration of clinical techniques.
• To undertake research that involves limited or no patient contact.
• To undertake a period of postgraduate study or supervised training while working in an appropriately supported environment that will
ensure patient safety is not compromised.
These exemptions will generally be subject to conditions requiring supervision by a registered health practitioner and may also require the use
of an interpreter.
2. Canada
Policy
Overview Overall: Professional registration requirements in Canada are complex due to policy variations between national bodies, the 13 provinces/ territories
and the professional bodies. This has been compounded by the finding that information specifically on English language standards is not always
readily available or explicitly defined (noting for this audit French language testing requirements were by agreement excluded).
Test options: For the purposes of professional registration, passes are required in the IELTS, MELAB, TOEIC, CanTEST, CELBAN or TOEFL tests, as defined
below.
National
Variabilit
Provincial variability (Medicine and Nursing):
• Language testing requirements are highly variable across the 13 provinces/ territories of Canada.
• For these fields, English language requirements are provided below for the 5 most populous and 2 least populous provinces by key field, to indicate
3 Although the policy states that Pharmacy applicants from South Africa may be granted an exemption from English language testing, the Pharmacy Board has indicated
that they are not actually exempt due to the variability of candidates’ English skills.
27
FINAL Contrastive Country Audit
5 November 2012
y
the scale of variation from the major population centres to under-supplied provincial sites.
• In descending order of population size, the most populous provinces are Ontario, Quebec4, British Columbia, Alberta, Manitoba, Saskatchewan; and
the two least populous are Newfoundland and Labrador, and Prince Edward Island.
National standards (Pharmacy and Physiotherapy):
o English language requirements are determined by a national body. While provinces are able to apply additional requirements, each has
followed the standards established by the national authority.
Dentistry:
o No English proficiency standards have been set as this is assessed as part of the National Dental Board of Canada (NDEB) Written Exam.
Skilled
Migration
Permanent Skilled Migration (Federal Skilled Worker Program):
• All applicants must include the results of an English or French language test as part of their application. In a major policy change, as of 26 June 2011
no exemptions apply. (Previously, self-report was allowed. This coincided with the admission of large numbers of health professionals with poor or
minimal English, and significant employment displacement.) Bonus points (up to 24 points out of the 67 points required) are only allocated if the
minimum scores are achieved as follows:
o IELTS (General Training only) – Overall: N/A, Speaking: 4, Writing: 4, Listening: 4.5, Reading: 3.5.
o As of 1 January 2013 IELTS minimum requirements will be changed to: Speaking: 6, Writing: 6, Listening: 6, Reading: 6 and language
assessment will be mandatory upfront.
o CELPIG-General – Overall: N/A, each component (Speaking, Writing, Listening, Reading): Level 2H (equivalent to CLB 4)
Temporary Skilled Migration (Temporary Foreign Workers):
o English proficiency standards are those as set by the relevant professional regulatory boards.
Key Trends Medicine:
o A new national standard has been set up but has not yet been implemented in each province. The Registrars have approved the Standard and
the next steps will be to obtain the appropriate and required ministerial approval to proceed. Standards below related to that as at February
2012. Please see Policy Developments under Medicine below.
Nursing:
o Policies pertaining to English language requirements have been stable overall.
Physiotherapy:
o The Canadian Alliance of Physiotherapy Regulators have undertaken a review of language proficiency testing for internationally trained
physiotherapists. The review recommendations below refer to the outcomes of report prepared in August 2012.
Pharmacy:
o In 2009, a pan-Canadian mobility agreement was put in place for Pharmacy and worked through the National Association of Pharmacy
Regulatory Authorities (NAPRA). This has meant the standardisation of English language standards across the 10 provinces. For Medicine, the
4 Quebec, the second most populous province, has its own quite separate jurisdiction with French proficiency requirements. The French tests that are accepted include: TESTcan, Test
d’evaluation de Francais (TEF) and Test de francais international (TFI). As the focus of this audit is on English language test requirements, standards set in Quebec have been excluded.
28
FINAL Contrastive Country Audit
5 November 2012
National Assessment Collaboration (NAC) was established in 2004, under the governance of the Medical Council of Canada (MCC).The aim of
NAC is to develop streamlined assessments for IMGs to obtain a medical licence in Canada regardless of jurisdiction of assessment. English
language requirements have not yet been standardised.
Target
Groups
Health professionals who gained their qualifications from a non-English speaking country:
o If applicants did not attain qualifications from accredited programs or select countries (detailed below), they must (with the exception of
Dentistry) successfully complete and pass an English test.
Governance
(National and
Select
Provincial
Bodies)
Dentistry:
• National Dental Board of Canada (NDEB)
• Royal College of Dental Surgeons of Ontario
• College of Dental Surgeons of British
Columbia
• Alberta Dental Association and College
• Manitoba Dental Association
• College of Dental Surgeons of Saskatchewan
• Provincial Dental Board of Nova Scotia
• New Brunswick Dental Society
• Newfoundland and Labrador Dental Board
• Dental Council of Prince Edward Island
Physiotherapy:
• Canadian Alliance of Physiotherapy
Regulators (The Alliance)
• College of Physiotherapists of Ontario
• College of Physical Therapists of British
Columbia
• Physiotherapy Alberta College & Association
• College of Physiotherapists of Manitoba
• Saskatchewan College of Physical Therapists
• Nova Scotia College of Physiotherapists
• College of Physiotherapists of New
Brunswick
• Newfoundland and Labrador College of
Physiotherapists
• Prince Edward Island College of
Physiotherapists
Pharmacy:
National Association of Pharmacy Regulatory
Authorities (NAPRA)
• Ontario College of Pharmacists
• College of Pharmacists of British Columbia
• Alberta College of Pharmacists
• The Manitoba Pharmaceutical Association
• Saskatchewan College of Pharmacists
• Nova Scotia College of Pharmacists
• New Brunswick Pharmaceutical Society
• Newfoundland and Labrador Pharmacy
Board
• Prince Edward Island Pharmacy Board
Medicine:
• Medical Council of Canada
• College of Physicians and Surgeons of
Ontario
• College of Physicians and Surgeons of British
Columbia
• College of Physicians and Surgeons of
Alberta
• College of Physicians and Surgeons of
Manitoba
• College of Physicians and Surgeons of
Nursing:
• College of Nurses of Ontario
• College of Registered Nurses of British
Columbia
• College & Association of Registered Nurses
of Alberta
• College of Registered Nurses of Manitoba
• Saskatchewan Registered Nurses’
Association
• Association of Registered Nurses of
Newfoundland and Labrador
29
FINAL Contrastive Country Audit
5 November 2012
Saskatchewan
• College of Physicians and Surgeons of
Newfoundland and Labrador
• College of Physicians and Surgeons of Prince
Edward Island
• Federation of Medical Regulatory
Authorities of Canada
• Association of Registered Nurses of Prince
Edward Island
Test Instruments and Levels – Dentistry, Physiotherapy and Pharmacy
Instrument Dentistry Physiotherapy Pharmacy
General
comment
• There are no English language requirements
• Applicants must complete the NDEB Written
Exam and Objective Structured Clinical
Examination (OSCE), within which English
ability is part of the assessment.
• Applicants must also be a licensed member
with the relevant provincial regulatory
body, none of which have additional
requirements for English proficiency.
• A two year review process is currently
nearing completion.
• Applicants must apply for credentialing
through the Canadian Alliance of
Physiotherapy Regulators (CAPR - The
Alliance) which has a set of English
proficiency standards.
• While individual provinces may have
additional requirements, none currently
deviate from those set by CAPR.
• Standards are currently under review.
• English language requirements are defined
by the National Association of Pharmacy
Regulatory Authorities (NAPRA).
• Applicants must gain registration with the
relevant provincial regulatory body, all of
which require the minimum language
standards below.
IELTS
(Academi
c)
Not applicable Overall: 7, Speaking: 7, Writing: 7, Listening: 7,
Reading: 7
Review recommendation: Overall: 7, Speaking:
7, Writing: 6.5, Listening: 6.5, Reading: 7
Overall: 7, Speaking: 6, Writing: 6, Listening: 6,
Reading: 6
Standard Error of Measurement (SEM) is
accepted by all provinces at +/-0.5 of each
band score.
TOEFL iBT
Overall: 80, Speaking: 19, Writing: 19, Listening:
20, Reading: 20
Review recommendation: Overall: 86, Speaking:
21, Writing: 21, Listening: 21, Reading: 21
Overall: 97, Speaking: 27, Writing: 25, Listening:
N/A, Reading: N/A
TOEFL PBT Discontinued unless TOEFL iBT is unavailable.
Previous requirements: Overall: 585, TSE:
45, TWE: N/A, Listening: 50, Reading: 50,
Overall: 580, TSE: 50, TWE: 5, Listening: N/A,
Reading: N/A, Structure: N/A
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FINAL Contrastive Country Audit
5 November 2012
Structure: 50
Review recommendation for countries with only
this version: : Overall: 585, TSE: N/A,
TWE:4, Listening: 55, Reading: 56, Structure:
60
TOEFL CBT Discontinued. Overall: 237, TSE: 50, TWE: N/A, Listening: N/A,
Reading: N/A, Structure: 26
MELAB Overall: 85, Speaking:3, Writing: N/A, Listening:
N/A, GCVR: N/A
The review has suggested that this test may be
discontinued due to low uptake (around 3%
of candidates take the MELAB).
Overall: 88, Speaking:3, Writing: 82, Listening:
N/A, GCVR: N/A
TOEIC Overall: N/A, Speaking: 160, Writing: 160,
Listening and Reading total: 800
Review recommendation: Discontinue test5.
Not accepted
CanTEST Overall: 4, Speaking: 4.5, Writing: 4, Listening: 4,
Reading: 4
Overall: N/A, Speaking: 4.5, Writing: 4.5,
Listening: 4.5, Reading: 4.5
Additional
Condition
s
Not applicable • Results do not need to be obtained in one
sitting.
• Results are valid for 2 years from test date
Exemptions
Applicants who completed an NDEB-accredited
programs in USA and Australia are exempt.
If education was in English, or completed in
Australia, USA, NZ, Ireland, South Africa, UK
or France.
• Applicants with a university degree from a
Canadian or US program accredited by
Canadian Council for Accreditation of
Pharmacy Programs or Accreditation
Council for Pharmacy Education.
5 TOEIC has been recommended to be discontinued because the test does not include professional licensure as an ‘appropriate use’; and its format is very different from
the other approved tests.
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FINAL Contrastive Country Audit
5 November 2012
• For Ontario only: Applicants who completed
the majority of their primary, secondary and
university education in English are generally
granted an exemption. Applicants may
submit adequate non-objective evidence of
proficiency. Such as, authored publications
accompanied by letter from a professor who
can attest to language proficiency.
Test Instruments and Levels – Medicine and Nursing
Instrument Medicine Nursing
General comment • Requirements for only the 5 most populous and 2 least populous
provinces are listed below.
• Standards for Alberta and Saskatchewan were not available -
relevant authority has been contacted, awaiting response.
• Information on the website for Ontario currently only lists English
standard requirements for certificate of registration for
postgraduate medical education rather than for licensure. Ontario
will soon be adopting the recently established National Standard
(please see Policy Developments below).
Requirements for only the 5 most populous and 2 least populous
provinces are listed below.
IELTS (Academic) British Columbia: Overall: 7, Speaking: 7, Writing: 7, Listening: 7,
Reading: 7
Newfoundland and Labrador: Overall: N/A, Speaking: 7, Writing: 7,
Listening: 7, Reading: 7
Ontario (once National Standard is adopted): Overall: 7, Speaking: 7,
Writing: 7, Listening: 7, Reading: 7
Ontario: Overall: 6.5, Speaking: 7, Writing: 6.5, Listening: 6.5, Reading:
6.5
British Columbia, Alberta, Manitoba, Saskatchewan, New Brunswick;
Newfoundland and Labrador: Overall: 7, Speaking: 7, Writing: 7,
Listening: 7.5, Reading: 6.5
Prince Edward Island: Overall: 7.5, Speaking: 7.5, Writing: 7.5,
Listening: 8, Reading: 7
TOEFL iBT
British Columbia: Overall: 95, Speaking: 25, Writing: N/A, Listening:
N/A, Reading: N/A
Manitoba: Overall: 100, Speaking: 25, Writing: N/A, Listening: 25,
Reading: N/A
Newfoundland and Labrador: Overall: 92, Speaking: 24, Writing: 20,
Ontario: Overall: 74, Speaking: 26, Writing: 14, Listening: 18, Reading:
19
Newfoundland and Labrador: Overall: 86, Speaking: 26, Writing: 20,
Listening: 20, Reading: 20
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FINAL Contrastive Country Audit
5 November 2012
Listening: 20, Reading: 20
Ontario (once National Standard is adopted): Overall: 96, Speaking:
24, Writing: 24, Listening: 24, Reading: 24
TOEFL PBT Ontario: Overall: 537, TSE: 50, TWE:N/A, Listening: 53, Reading: 53,
Structure: 53
TOEFL CBT
(discontinued test)
Prince Edward Island: Overall: 237, TSE: 50, Writing: N/A
Ontario: Overall: 203, TSE: 50, TWE:N/A, Listening: 19, Reading: 20,
Structure: 20
MELAB Not accepted Ontario: Overall: 75, Speaking:3, Writing: N/A, Listening: N/A, GCVR:
N/A
TOEIC Not accepted Ontario: Overall: 720, Speaking: N/A, Writing: N/A, Listening: 350,
Reading: 350
Prince Edward Island: Overall: 930, Speaking: 190, Writing: 200,
Listening: 495, Reading: 435
CELBAN Not accepted (NURSING SPECIFIC TEST) Ontario: Overall: N/A, Speaking: 8, Writing: 7, Listening: 9, Reading: 8
British Columbia, Alberta, Manitoba, Saskatchewan, New Brunswick;
Newfoundland and Labrador, Prince Edward Island: Overall: N/A,
Speaking: 8, Writing: 7, Listening: 10, Reading: 8
Additional
Conditions
British Columbia and Newfoundland and Labrador: Test results are
valid for 2 years.
British Columbia: Test scores must be submitted within 6 months of
test date.
Newfoundland and Labrador: Applicants whose first language is not
English, or who have completed their nursing education in a
country where the everyday language is not English, are required
to successfully complete an English test.
Exemptions
British Columbia: If the language of instruction at medical school was
in English. And the primary language of patient care was English.
And applicant was trained in a native English country.
Newfoundland and Labrador: If the applicant's medical education and
experience was in one of the countries recognised by the College
as having English as a first language. Or if they have a high school
diploma. Or have a minimum of two years of undergraduate
education (in any field) in English from one of the countries that
have English as a first language.
Ontario: If the candidate completed a nursing program in countries
recognised by the College as native English or French countries.
Or if they are registered and have practised nursing in a country
where English or French is the official or predominant language, in
the last five years.
Alberta, Manitoba, Saskatchewan: If English is the language they first
learned at home in childhood, is the language which they identify
as knowing best and being most comfortable with or is the
language they primarily use for reading, writing, listening and
speaking.
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FINAL Contrastive Country Audit
5 November 2012
Policy
Developments
A new National Standard has been established by Federation of
Medical Regulatory Authorities of Canada (FMRAC) with all
provinces moving to adopt this in due course:
IELTS: Overall: 7, Speaking: 7, Writing: 7, Listening: 7, Reading: 7
TOEFL iBT: Overall: 96, Speaking: 24, Writing: 24, Listening: 24,
Reading: 24 (to be phased out in 2016)
Exemptions: If candidates completed their medical education and
patient care experience in one of the countries that have English
as a first and native language (ie. Australia, Bermuda, British
Virgin Islands, Canada, Ireland, New Zealand, Singapore, South
Africa, United Kingdom, United States of America, US Virgin
Islands, Caribbean Islands: Anguilla, Antigua and Barbuda,
Barbados, Dominica, Grenada, Grenadines, Jamaica, St. Kitts and
Nevis, St. Lucia, St. Vincent, Trinidad and Tobego)
The Federal government and Provincial and Territorial governments
negotiated an internal trade agreement for the recognition of
registration across the country (except Quebec which is slightly
different).
An umbrella organisation was established in the last year (separate
from the Canadian Nursing Association) and it was decided that
they would only accept IELTS and CELBAN for nurses. It is
anticipated that everyone who has not been educated or
practising in an English area will have to take the test. This has not
yet been through legislation.
For Ontario, this will take effect on 1 January, 2013:
IELTS: Overall: 7, Speaking: 7, Writing: 7, Listening: 7.5, Reading: 6.5
CELBAN: Overall: N/A, Speaking: 8, Writing: 7, Listening: 10, Reading:
8
3. Ireland
Policy
Overview Overall: In Ireland, professional registration in the fields below is typically vested with the relevant over-arching registration authority.
Test options: For the purposes of professional registration, passes are required in the IELTS or TOEFL tests, as defined below.
National Variability None. Registration is also automatic for members of EU-EEA countries.
Skilled Migration Permanent Skilled Migration (Long Term Residency):
• No English language requirements have been set for eligibility purposes.
• However applicants wishing to apply for Long Term Residency must have a minimum of 5 years reckonable residence on the date of
submission. Only legal residence in the State on work permit, work authorisation or working visa conditions will be counted as reckonable
residence.
Temporary Skilled Migration (Work Permit):
• This is an employer-sponsored visa.
• Non- European Economic Area (EEA) nationals require a work permit.
34
FINAL Contrastive Country Audit
5 November 2012
• No English language requirements have been set for eligibility purposes.
Key Trends Registration standards have been stable over time.
Target Groups Medicine, Dentistry and Pharmacy: English proficiency tests are usually a requirement for individuals who are not members of the European
Union (EU) or the EEA.
Nursing: In addition to the above, applications are not accepted from the following:
• Non-EU trained nurse or midwife who has not been engaged in the practice of nursing/ midwifery during the five years prior to the
application date; or
• State Enrolled Nurse only, State Certified Nurse only, Licensed Practical Nurse only, Vocational Nurse only, USA Associate Degree only or
Nurses Aide only; or
• An applicant who undertook only the June 2006 examination in the Philippines; or
• Bulgarian qualification of ‘фелдшер’ feldsher only (EU/2005/36 Directive Article 23a)
Physiotherapy: There are no exempt groups.
Governance Irish Medical Council Irish Nursing Board (An
Bord Altranais)
Dental Council (Comhairle
Fiacloireachta)
Irish Society of Chartered
Physiotherapists
Pharmaceutical Society
of Ireland (PSI)
Test Instruments and Levels
Instrument Medicine Nursing Dentistry Physiotherapy Pharmacy
General comment Please see note in Target
Groups section.
English language test
results are a
requirement to sit the
Dental Council exam.
EU and EEA applicants
must make a
Statutory Declaration
that they are
competent to do
business in English.
IELTS (Academic) Overall: 7, Speaking: 6.5,
Writing: 6.5,
Listening: 6.5,
Reading: 6.5
Overall: 7, Speaking: 7,
Writing: 7, Listening:
6.5, Reading: 6.5
Overall: 7, Speaking: N/A,
Writing: N/A,
Listening: N/A,
Reading: N/A
Overall: 7, Speaking: 6.5,
Writing: 6.5,
Listening: 6.5,
Reading: 6.5
Overall: 7, Speaking: 7,
Writing: 6.5,
Listening: 6.5,
Reading: 6.5
TOEFL iBT
Not accepted Not accepted Overall: 100, Speaking:
N/A, Writing: N/A,
Listening: N/A,
Reading: N/A
Not accepted Overall: 97, Speaking: 27,
Writing: 25, Listening:
25, Reading: N/A
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FINAL Contrastive Country Audit
5 November 2012
TOEFL PBT Not accepted Not accepted Overall: 600, TSE:N/A,
TWE: N/A, Listening:
N/A, Reading: N/A,
Structure: N/A
Not accepted Overall: 590, TSE:N/A,
TWE: 5.5, Listening:
59, Reading: 56,
Structure: 56
TOEFL CBT
(discontinued
test)
Not accepted Not accepted Overall: 250, TSE: N/A,
TWE:N/A, Listening:
N/A, Reading: N/A,
Structure: N/A
Not accepted Not accepted
Additional
Conditions
• Results must be
achieved in one
sitting (not explicitly
stated in policy but
emerged from
interview with
Medical Council)
• IELTS results are valid
for 2 years.
• Results must be
achieved in one
sitting.
• Test results are valid
for 2 years or must
provide evidence of
having worked full
time as a nurse in an
English-speaking
environment since
the test.
Tests results are valid for
2 years prior to
application date.
Results do not need to be
obtained in one
sitting.
Not stated • IELTS and TOEFL iBT
must be attempted in
same sitting.
• Tests are valid for 2
years or applicant
must provide
evidence of having
lived and worked or
studied full time in an
English speaking
context.
Exemptions
Applicant is exempt if they
have:
• a recognised
qualification under
the Registration
Rules; or
• a basic medical
degree /internship
training through
English
• passed the United
States Medical
licensing Examination
EU-trained applicants are
exempt.
Applicant may be entitled
to acquired rights if
they have worked in
an EU country in 3 of
the previous 5 years
depending on the
country [from
interview but not
explicitly stated in
policy]
Applicant is exempt if:
• they are nationals of
EEA Member States;
or
• their dentistry degree
was obtained through
English.
There are no exemptions. If applicant:
• has qualification from
an EU or European
Economic Area (EEA)
member state; or
• is a national of a
member state of the
EU or EEA; or
• has passed at least six
subjects in the Irish
Leaving Certificate
examination.
36
FINAL Contrastive Country Audit
5 November 2012
(UMSLE) from 2004
• a Cambridge ESOL
CAE - CEFR Level C1
Policy
Developments
Under the revision of the EU directive, the relevant authorities should be able to ask for proof of English competence prior to registration if
deemed necessary [from interviews with Nursing and Dentistry informants – policy not yet finalised].
4. New Zealand
Policy
Overview Overview: The Boards / Councils require that applicants prove their English proficiency through evidence of successful completion of a prescribed
English test. Further, the assessment of communicative competence is embedded in clinical examinations where these are required as part of
the pre-registration process. Councils have a discretionary power to require applicants to provide proof of English language competence at any
time.
Test options: For the purposes of professional registration, passes are required in the IELTS or OET tests, as defined below.
National
Variability
None
Skilled Migration Permanent Skilled Migration (Skilled Migrant Category):
• Minimum requirement is an overall score of 6.5 in the IELTS General Training or Academic module.
• Evidence may be provided that minimum English proficiency requirements are met, for example if the applicant’s qualification was gained
through a course of study in which English was the only medium of instruction. This is decided on a case-by-case basis.
Temporary Skilled Migration (Essential Skills Work Category):
• This visa is for applicants who have a job offer from a New Zealand employer.
• Applicants must be fully or provisionally registered in New Zealand, details are listed below.
Key Trends February 2010: Health sector regulatory bodies receive a proposal from Health workforce NZ (HWNZ) on behalf of the Ministry of Health
suggesting select shared functions for all health-related regulatory authorities together with reduction in the number of regulatory authority
board members to improve workflow efficiencies in processing registration, rectification and professional standards.
Target Groups Health professionals who gained their qualifications from a non-English speaking country are required to submit evidence of English proficiency.
37
FINAL Contrastive Country Audit
5 November 2012
Governance Medical Council of NZ
(MCNZ)
Nursing Council of NZ Dental Council of NZ
Physiotherapy Board of
NZ
The Pharmacy Council of NZ (PCNZ)
Test Instruments and Levels
Instrument Medicine Nursing Dentistry Physiotherapy Pharmacy
IELTS (Academic) Overall: N/A, Speaking:
7.5, Writing: 7,
Listening: 7.5,
Reading: 7
Overall: 7, Speaking: 7,
Writing: 7,
Listening: 7,
Reading: 7
Overall: 7.5, Speaking:
7, Writing: 7,
Listening: 7,
Reading: 7
Overall: 7.5, Speaking: 7,
Writing: 7, Listening:
7, Reading: 7
Overall: 7.5, Speaking: 7, Writing: 7,
Listening: 7, Reading: 7
OET Not accepted Overall: B, Speaking: B,
Writing: B,
Listening: B,
Reading: B
Overall: N/A, Speaking:
B, Writing: B,
Listening: B,
Reading: B
Overall: N/A, Speaking: B,
Writing: B, Listening:
B, Reading: B
Overall: B, Speaking: B, Writing: B,
Listening: B, Reading: B
Additional
Conditions
• IELTS is the only
English test
approved by the
Council.
• Results must be
obtained in one
sitting.
• IELTS test results
are valid within 2
years of
registration
application. Or 2
years of NZREX
exam date (for
new candidates).
Repeat candidates
do not need to
IELTS:
Band 7 in each Sub-test
must be achieved
within 12 months
of first sitting the
test.
Results do not need to
be achieved in a
single sitting.
OET and IELTS results
must be obtained
within 2 years of
the date of
application for
registration.
• Results must be
obtained in one
sitting.
• Results are valid
for 2 years for new
applications or 3
years for repeat
registration exam
candidates who
have lived and
worked in a
country where
English is the first
language.
• The Council has
discretionary
power to require
For postgraduate
physiotherapy
students, who have
not received their
primary
physiotherapy degree
in New Zealand the
Board will accept the
academic acceptance
criteria and English
language criteria of
the educational
institutions/organisat
ions.
• OET and IELTS results must be
obtained within 2 years of the
date of application.
• OET results do not need to be
achieved in one sitting
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FINAL Contrastive Country Audit
5 November 2012
resit IELTS for up
to five years of last
NZREX attempt uf
they have been
residing
continuously in the
countries listed
below.
an applicant to
provide proof of
English language
competence at any
time.
Exemptions
• If primary medical
qualification is
from: NZ,
Australia, the UK,
Ireland, USA,
Canada or a South
African medical
school where
English is the sole
language of
instruction; or
• If applicant:
Completed at least
24 months FTE of a
PG qualification at
the University of
Otago or the
University of
Auckland, and
provide references
from two
professors; or
• Has evidence of
continuous work
as a registered
medical
practitioner in an
Nurses who have
qualified and
gained registration
in Australia.
• If applicant
graduated from a
joint Dental
Council
(NZ)/Australian
Dental Council
accredited
program; or
• English is the
applicant’s first
language; and the
applicant
completed their
UG dental training
in NZ, Australia,
UK, USA, Ireland or
Canada where
English is the sole
language of
instruction and
assessment.
• If applicant can
demonstrate
continuous practice
as a registered
physiotherapist for at
least 2 years within
the 3 years
immediately prior to
application in one of
the following
countries:
• England, Wales,
Scotland, Northern
Ireland, Eire, Canada,
Australia, South
Africa and/or USA,
where English was
the first and primary
language used in the
physiotherapy
practice setting; and
provide details of
two referees (similar
to that for Medicine).
• International students who
completed their Pharmacy training
in NZ are exempt (from interviews
– not explicitly stated in policy)
• If applicant is registered in
Australia unless the PCNZ finds
that the applicant does not
communicate effectively in English
in which case the PCNZ reserves
the right to place restrictions on
eligibility to practise.
For those who are not registered in
Australia, Canada, Ireland, UK or
USA they may be exempt:
• If English is the official language of
the applicants’ country; and
• Have evidence of completion of
UG pharmacy degree where Eglish
was the sole language of
instruction and assessment; and
• Have written testimony by an
employer of applicant’s
continuous work in pharmacy
where English was the first
language for at least 2 years within
the previous 5 years.
• Have written testimonies on
39
FINAL Contrastive Country Audit
5 November 2012
institution where
English was the
first and prime
language for at
least 2 years
within the 5 years
prior to
applications6; or
• Was registered
with the MCNZ on
or after 18 Sept
2004 and whose
registration was
cancelled for administrative
reasons7.
letterhead signed by at least 2
suitably experienced pharmacists
who speak English as a first
language of applicant’s ability to
comprehend and communicate
effectively in written and oral
English in a clinical setting with
patients and colleagues.
For those who are registered in
Australia, Canada, Ireland, UK or
USA they may be exempt:
• If English is their first language; or
• They pass the English test as
specified by the above
requirements (IELTS must be
obtained in one sitting; unclear if
this is also the case for OET); or
• If they have an approved
IELTS/OET exemption through
provision of written testimonials
as set out for applicants for other
countries.
5. Singapore
Policy
Overview Overall: Each health profession below has its own regulatory authority that sets the English language requirements.
Test options: For the purposes of professional registration in Medicine and Pharmacy, passes are required in the IELTS, OET or TOEFL tests, as
6 Must provide names and contact details of at least two referees who are senior suitable medical practitioners who speak English as a first language and who can attest to
the applicant’s ability to comprehend and communicate effectively in English in a clinical setting with both patients and professional colleagues. 7 Must provide names and contact details of at least two referees as detailed above.
40
FINAL Contrastive Country Audit
5 November 2012
defined below.
National Variability None
Skilled Migration
Permanent Skilled Migration (Professionals/Technical Personnel and Skilled Workers Scheme):
• No English language requirements have been set.
• Applicants must hold a P or Q pass8 or S Singapore employment pass.
Temporary Skilled Migration (S Pass – employer sponsored visa):
• No English language requirements have been set.
Key Trends Physiotherapy from January 2011: Physiotherapists must be registered with the Allied Health Professions Council, a national regulatory body
for allied health professions. English language standards have not yet been set and were not previously in place.
Pharmacy from September 2008: Singapore Pharmacy Board reconstituted as Singapore Pharmacy Council for rigorous registration processes.
Medicine: English language requirements have been consistent over time, and are set by Singapore Medical Council.
Nursing, Dentistry: No English proficiency standards are in place, as set by Singapore Nursing Board and Singapore Dental Council, respectively.
Target Groups Doctors and pharmacists who were not taught and assessed in English:
• Applicants need to sit an English test.
• Exemptions exist for pharmacists with a degree from the United Kingdom, United States of America, Canada, Australia or New Zealand.
Physiotherapy, Nursing, Dentistry:
• No test requirements are in place.
Governance Singapore Medical Council Singapore Nursing Board Singapore Dental Council Allied Health Professions
Council
Singapore Pharmacy
Council
Test Instruments and Levels
Instrument Medicine Nursing Dentistry Physiotherapy Pharmacy
General comment • No formal English
tests are mandated
however informal
assessments of
English language skills
are embedded in
• No specific policy on
English standards or
testing was stated on
the website.
• Must have a
Singapore Dental
• No specific policy on
English standards or
testing was stated on
the website.
• From January 2011,
physiotherapists must
8 The fixed monthly salary of the applicant determines whether the applicant is eligible for a P or Q pass.
41
FINAL Contrastive Country Audit
5 November 2012
face-to-face
interviews conducted
in source countries.
• Applicants must have
completed a nursing
program equivalent
to an accredited
program in Singapore
and have a job offer.
Decided on a case-by-
case basis.
Council-recognised
degree or must sit
exam.
• Applicants are
exempt if degree is
attained in UK, NZ,
USA, Australia,
Canada, Hong Kong
and Ireland.
register under the
Allied Health
Professional Bill
which is still under
development.
IELTS (Academic) Overall: N/A, Speaking: 7,
Writing: 7, Listening:
7, Reading: 7
Not applicable Not applicable Not applicable Overall: 7, Speaking: 7,
Writing: 7, Listening:
7, Reading: 7
OET Overall: N/A, Speaking: B,
Writing: B, Listening:
B, Reading: B
Not accepted
TOEFL iBT
Overall: 100, Speaking:
N/A, Writing: N/A,
Listening: N/A,
Reading: N/A
Overall: 94, Speaking: 26,
Writing: 24, Listening:
22, Reading: 22
TOEFL PBT Overall: 600, TSE: N/A,
TWE: N/A
Overall: 587, TSE: 50,
TWE: N/A, Listening:
N/A, Reading: N/A,
Structure: N/A
TOEFL CBT
(discontinued test)
Overall: 250, TSE: N/A,
TWE: N/A
Overall: 240, TSE: 50,
TWE: N/A
Additional
Conditions
Test results must be
obtained in one
sitting9.
All tests valid for 2 years
from test date
Test results are valid for 2
years and must be
obtained in one
sitting10
.
9 This is not formally stipulated on the Singapore Medical Council website but emerged from the written data provided by senior Council members
10 This is not formally stipulated on the Singapore Pharmacy Council website but emerged out of the interview with senior Council members.
42
FINAL Contrastive Country Audit
5 November 2012
Exemptions
Applicants are exempt if
the instruction of
their basic medical
course was in English.
Employer-sponsored
nurses are exempt
from a face-to-face
interview as the
employer has
screened them and
apply to SNB on their
behalf.
Not applicable Not applicable Applicants are exempt if
their pharmacy
degree was attained
in the UK, USA,
Canada, Australia or
NZ.
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FINAL Contrastive Country Audit
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6. South Africa Please note:
Despite a range of approaches made over several months, it did not prove possible to arrange interviews with South African key informants. The
information below is thus wholly web-sourced, and may be less current.
Policy
Overview Overall:
Test options: Where applicable, IELTS is the accepted test.
National Variability Medicine, Dentistry and Physiotherapy exist within the Health Professions Council of South Africa (HPCSA) and have similar requirements. No
information was listed for Nursing.
Skilled Migration
Permanent Residence can be applied under the following permits:
Work Permit: Applicants must have a job offer/contract on a permanent basis from their future employer. It must be demonstrated that the
position was advertised and that no South African citizens or permanent residents could fill the position. This is subject to yearly limits of
available permits.
Temporary Residence:
General Work Permit: Employer must demonstrate that no citizens/permanent residents could fill the role and document proof of efforts.
Candidate’s proof of qualifications must be evaluated by South African Qualifications Authority. Candidate must also have proof of:
registration with the professional body where applicable; and their experience and skills in line with the job offer.
Quota Work Permit: Candidates apply for this permit if their profession is listed in the government gazette list where quotas for the maximum
number of foreign workers are stated. Applicants must have 5 years experience in their occupation.
Exceptional Skills Work Permits: Similar to the Quota Work Permit but is broader and does not involve a published list of occupations. The
applicant must have: a letter from a foreign or South African organ of state or from an established South African academic, cultural or
business body confirming the exceptional skills of the applicant; and publications and testimonials to substantiate exceptional skills or
qualifications.
Note: No English language requirements were stated on the Department of Home Affairs website for any of these permits.
Key Trends HPCSA was established in 1928 with most recent changes to the Health Act made in 2007.
Target Groups Overall: Those who obtained a qualification in a language other than English.
Governance HPCSA - Medical and
Dental Board
South African Nursing
Council (SANC)
HPCSA - Medical and
Dental Board
HPCSA - Professional
Board for
South African Pharmacy
Council
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FINAL Contrastive Country Audit
5 November 2012
Physiotherapy,
Podiatry and
Biokinetics
Test Instruments and Levels
Instrument Medicine Nursing Dentistry Physiotherapy Pharmacy
General comment Practitioners who
obtained their
qualifications in a
language other than
English must
complete the IELTS.
No information around
English standards was
listed on website.
SANC has been contacted
directly via email.
Practitioners who
obtained their
qualifications in a
language other than
English must
complete the IELTS.
English language
proficiency is
assessed as part of
the Examination for
Registration. The test
comprises a
theoretical and
practical/clinical exam
with latter involving
two examiners and a
moderator.
English standards set
below are for the
qualification for entry
into the Professional
exam.
IELTS (Academic) Overall: 6, minimum
individual band scores
not stated
Overall: 6, minimum
individual band scores
not stated
N/A Overall: 6, minimum
individual band scores
not stated
Additional
Conditions
Candidates’ academic
written and verbal
skills relating to
academic language
are informally
assessed during the
Board’s examination
when applicable.
No specific statements
were made regarding
test validity period or
the ability to use
results from multiple
sittings.
Candidates’ academic
written and verbal
skills relating to
academic language
are informally
assessed during the
Board’s examination
when applicable.
No specific statements
were made regarding
test validity period or
the ability to use
results from multiple
sittings.
No specific statements
were made regarding
test validity period or
the ability to use
results from multiple
sittings.
45
FINAL Contrastive Country Audit
5 November 2012
Exemptions
Candidates from English
speaking countries
and candidates with
English as a first or
second language
qualification on
secondary school
level are exempt.
Candidates from English
speaking countries
and candidates with
English as a first or
second language
qualification on
secondary school
level are exempt.
No exemptions stated on
website.
7. United Kingdom
Policy
Overview Overall: Each health profession below has its own regulatory authority that sets the English language requirements.
Test options: For the purposes of professional registration, passes are required in the IELTS, as defined below.
National Variability None
Skilled Migration
Permanent Skilled Migration and Temporary Skilled Migration (Tier 1 (General) and Tier 2):
Applicants can score up to 10 out of 100 points for English language ability. They must score points in this area or their application will be
refused.
• A large range of tests are accepted including: IELTS, TOEIC and TOEFL iBT. The full list is available from:
www.ukba.homeoffice.gov.uk/sitecontent/applicationforms/new-approved-english-tests.pdf
• Minimum requirement is Level C1 of the Common European Framework of Reference (CEFR) in all 4 components.
Key Trends Physiotherapy: Physiotherapy (along with 14 other health professions) is regulated by the Health Professions Council which was set up by the
Health Professions Order 2001. From 1 April 2011, TOEFL and Cambridge International General Certificate of Secondary Education are no
longer accepted.
Nursing: As of February 2007, the Nursing & Midwifery Council (NMC) decided that a score of 7 was the lowest level acceptable for language
skills for nurses (previously 6.5). This change resulted from public consultations and evidence collected from the British Council.
Medicine, Dentistry: English language requirements have been stable.
46
FINAL Contrastive Country Audit
5 November 2012
Pharmacy: Policy on English language requirements was only implemented in 2002. Prior to that, English testing was not required.
Target Groups Overall: Non-EU and non-EEA nationals are generally required to sit an English test.
Governance General Medical Council
(GMC)
Nursing & Midwifery
Council (NMC)
General Dental Council
(GDC)
Health & Care Professions
Council (HCPC)
• General
Pharmaceutical
Council (GPhC)
• Pharmaceutical
Society of Northern
Ireland (PSNI)
Test Instruments and Levels
Instrument Medicine Nursing Dentistry Physiotherapy Pharmacy
General comment IELTS scores must be valid
when applicants sit
the PLAB Part 1 test.
Overseas qualified
dentists must sit the
Overseas Registration
Exam (ORE) if they
are not eligible for
exemption.
Candidates must
submit passed IELTS
results for the
purpose of the ORE.
IELTS is the accepted test.
Applicants are
strongly advised to
contact HPC first if
they propose to rely
on an alternative test.
Non-EEA applicants need
to complete an
Overseas Pharmacists
Assessment Program
(OSPAP) programme
before they can apply
for registration.
Applicants may also
be interviewed as part
of this process to
verify their clinical
knowledge.
IELTS (Academic) Overall: 7, Speaking: 7,
Writing: 7, Listening:
7, Reading: 7
Overall: 7, Speaking: 7,
Writing: 7, Listening:
7, Reading: 7
Overall: 7, Speaking: 6.5,
Writing: 6.5,
Listening: 6.5,
Reading: 6.5
Overall: 7, Speaking: 6.5,
Writing: 6.5,
Listening: 6.5,
Reading: 6.5 Website did not state
whether Academic or
General Training is
required.
England, Scotland and
Wales: Overall: 7,
Speaking: 7, Writing:
7, Listening: 7,
Reading: 7
Northern Ireland: Not
stated on website.
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FINAL Contrastive Country Audit
5 November 2012
PSNI has been
contacted, awaiting
reply.
Additional
Conditions
• Results must be
achieved in one
sitting.
• Results are valid for 2
years.
• Results are valid for 2
years. Where the test
score is more than
two years old, it can
only be accepted as
evidence of present
level of ability if the
person can prove that
they have actively
used or tried to
improve their English
language proficiency.
• Results must be
achieved in one
sitting.
• Results are valid for 2
years.
Not stated on website. • Results must be
achieved in one
sitting.
• Results are valid for 2
years. If successful
results are over 2
years old applicants
do not need to re-sit if
within the last 2 years,
they have completed
a postgrad course of
study (taught and
examined solely in
English). Or providing
a reference from an
employer/tutor/
lecturer covering at
least 3 months FT
employment or study.
Exemptions
• EU nationals are
exempt. No other
exemptions apply.
The following exemptions
apply to the ORE and
by extension, English
testing:
• Applicants who
gained their primary
dental qualification
from a university in
the EEA or
Switzerland; or
• Applicants with select
qualifications from
Hong Kong,
• EU nationals or those
who are entitled to
be treated as
nationals are exempt.
• Nationals of the EEA,
or anyone with a
European Commission
(EC) right, or Swiss
Nationals who benefit
under European law
(since 1 June 2002)
are exempt at
application stage.
However they are still
required to meet the
GPhC’s code of
conduct and to ‘have
48
FINAL Contrastive Country Audit
5 November 2012
Singapore, Malaysia,
South Africa, New
Zealand and Australia,
some of which had to
have been completed
before 2001.
the language skills to
communicate and
work effectively with
colleagues’. In some
instances, EEA
nationals may be
required to complete
the OSPAP (as decided
on a case-by-case
basis).
• GMC may consider
evidence other than
an IELTS certificate
unless applicants have
already taken the
IELTS and failed. In
which case, they must
retake the IELTS and
achieve the required
scores.
Policy
Developments
Key informants have suggested that in practice, there has been a decoupling of qualification recognition and language testing in the EU
Directive, whereby EU applicants may be asked to demonstrate English competence on a case-by-case basis.
The EU Directive is currently undergoing a review process, with a range of key informants anticipating changes will be made to enable language
testing of EU/EEA health professionals throughout the EU, in addition to third country nationals.
8. United States of America
Policy
Overview Overall: Professional registration requirements for health professionals vary greatly among states. Generally, foreign trained professionals must
demonstrate their proficiency in English by exam or if certified by a sponsor. To demonstrate the range of English testing requirements,
details are provided for the 5 most populous states (California, Texas, New York, Florida, Illinois, Vermont and Wyoming) compared with
the 2 least populous states (Vermont and Wyoming).
Test options: For the purposes of professional registration, passes are required in the IELTS, TOEFL and TOEIC, as defined below.
49
FINAL Contrastive Country Audit
5 November 2012
National Variability
Medicine: English language requirements are uniform.
Dentistry: Requirements for Dentistry were not stated on the website.
Nursing, Physiotherapy and Pharmacy: Requirements are generally consistent with the standards set by the relevant national body. However
there is some variation between states.
Skilled Migration Permanent Skilled Migration (Employment-based Immigration: Third Preference EB-3):
• No English language requirements were stated on the website.
Temporary Skilled Migration (Temporary Non-immigrant Workers):
• No English language requirements were stated on the website.
Key Trends Overall: The professions generally have a national body or credentialing authority that sets English language requirements. State boards are
responsible for licensure and are typically able to apply additional requirements. English assessment was embedded in the United States
Medical Licensing Examination (UMSLE) from 2004.
Target Groups Overall: Health professionals from a non-English speaking country are generally required to sit an English test.
Governance
(National and
Select State
Bodies)
National
• Federation of State
Medical Boards (FSMB)
• Educational
Commission for
Foreign Medical
Graduates (ECFMG)
Select States
• Medical Board of
California
• Texas Medical Board
• NY State Board of
Medicine
• Florida Board of
Medicine
• Illinois Department of
Financial and
Professional
Regulation Division of
Professional
National
• National Council of
State Boards of
Nursing (NCSBN)
• Commission on
Graduates of Foreign
Nursing Schools
(CGFNS)
Select States
• California Board of
Registered Nursing
• Texas Board of
Nursing
• NY State Board of
Nursing
• Florida Board of
Nursing
• Illinois Board of
Nursing
• Vermont State Board
National
American Dental
Association (ADA)
Select States
• Dental Board of
California
• Texas State Board of
Dental Examiners
• New York State Board
for Dentistry
• Florida Board of
Dentistry
• Illinois State Board of
Dentistry
• Vermont Board of
Dental Examiners
• Wyoming Board of
Dental Examiners
National
• Federation of State
Boards of Physical
Therapy
• Foreign Credentialing
Commission on
Physical Therapy
(FCCPT)
Select States
• Physical Therapy
Board of California
• Texas Board of
Physical Therapy
Examiners
• Physical Therapy,
Podiatry &
Ophthalmic
Dispensing Office of
the Professions NY
State Education
National
• National Association
of Boards of
Pharmacy (NABP)
• Foreign Pharmacy
Graduate Equivalency
Committee (FPGEC)
Select States
• California State Board
of Pharmacy
• NY State Board of
Pharmacy
• Florida Board of
Pharmacy
• Illinois Department of
Financial and
Professional
Regulation Division of
Professional
Regulation – State
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FINAL Contrastive Country Audit
5 November 2012
Regulation
• Vermont Board of
Medical Practice
• State of Wyoming
Board of Medicine
of Nursing Department
• Florida Board of
Physical Therapy
• Illinois Department of
Professional
Regulation
• Office of Professional
Regulation, Vermont
• Wyoming Board of
Physical Therapy
Board of Pharmacy
• Vermont Board of
Pharmacy
• Wyoming State Board
of Pharmacy
Test Instruments and Levels
Instrument Medicine Nursing Dentistry Physiotherapy Pharmacy
General Comments • English assessment
component is
embedded within the
Clinical Skills
Assessment (Step 2) of
the UMSLE. Applicants
must pass this hurdle.
• No separate English
language requirements
exist.
• Applicants must pass
the UMSLE but must
first get Educational
Commission for
Foreign Medical
Graduates (ECFMG)
certification in order to
sit the USMLE.
• Graduate Medical
Education (GME) is a
• Most states require
applicants to
complete the
Commission on
Graduates of Foreign
Nursing Schools
(CGFNS) certification
program, a part of
which is the
requirement to pass
an English proficiency
exam. Such states
include New York,
Vermont and
Wyoming.
• Texas, Florida and
Illinois have separate
requirements11
.
• Requirements for
California were not
English standards were
not stated on the
website.
• Requirements for
California, New York
and Vermont were
not stated on the
website.
• Applicants need to
satisfy requirements
for FPGEC which sets
general standards on
English proficiency.
• Requirements for
Wyoming were not
stated on the
website.
11
It was unclear from the websites whether CGFNS certification was also a requirement for these states.
51
FINAL Contrastive Country Audit
5 November 2012
requirement for
unrestricted licence to
practice and varies
between states.
stated on website.
IELTS Not applicable New York, Vermont,
Wyoming:
Overall: 6.5 (no min
scores stated for
individual
components)
Texas:
Overall: 6.5, Speaking: 6,
Writing: 6, Listening:
6, Reading: 6
Florida:
Overall: 6.5, Speaking: 7,
Writing: N/A,
Listening: N/A,
Reading: N/A
No information stated on
website.
Not accepted Not accepted
TOEFL iBT
New York, Vermont,
Wyoming, Texas,
Illinois:
Overall: 83 (no min scores
stated for individual
components)
Florida:
Overall: 76
Texas, Florida, Illinois:
Overall: 89, Speaking: 26,
Writing:24, Listening:
18, Reading: 21
California, Texas, New
York, Florida, Illinois,
Vermont:
Overall: N/A, Speaking:
26, Writing:24,
Listening: 18,
Reading: 21
TOEFL PBT New York, Vermont,
Wyoming, Florida:
Overall: 540 (no min
scores stated for
individual
components)
Wyoming only:
Overall: 560, TWE:4.5
Florida only:
Overall:550, TSE:50 (no
other min scores
stated for individual
components)
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FINAL Contrastive Country Audit
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Texas:
Overall: 560, TSE:50,
TWE:4
Illinois:
Overall: 560
TOEFL CBT New York, Vermont,
Wyoming, Illinois :
Overall: 220
Texas:
Overall: 220, TSE:50,
TWE:4
Florida:
Overall: 207
Not accepted Florida only:
Overall: 213, TSE:50 (no
other min scores
stated for individual
components)
TOEIC New York, Vermont,
Wyoming, Florida:
Overall: 725 (no min
scores stated for
individual
components)
Not accepted Not accepted
MELAB Florida only:
Overall: 79
Not accepted Not accepted
ECPE Florida only:
Overall: MELAB converted
score of 79
Not accepted Not accepted
Conditions Not applicable No applications are
currently being
accepted from
applicants educated
in Haiti.
Not stated on website Not stated on website • TOEFL iBT must be
completed in one
testing session.
• Candidates must take
the TOEFL iBT in a
test centre located
within one of the
NABP member and
associate member
53
FINAL Contrastive Country Audit
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jurisdictions
including:
o the 50 states of
America*;
o District of
Columbia;
o Guam;
o Puerto Rico;
o Virgin Islands;
o 8 Canadian
provinces; and
o New Zealand.
• TOEFL PBT and TSE
scores are only
accepted from
candidates if they
applied for FPGEC
(Foreign Pharmacy
Graduate Equivalency
Committee)
Certification before 1
April, 2010 and took
the exam before 30
June, 2010.
Exemptions
Applicants who received
their basic medical
degree or qualification
from a medical school
in Canada that is listed
in the International
Medical Education
Directory (IMED).
Texas: If nursing program
was conducted in
English.
New York:
• Passing the Canadian
Nurses Association
Test (CNATS).
New York, Vermont,
Wyoming:
• If nursing education
was in Australia,
• Canadian
practitioners get
eligible accreditation
through a reciprocal
agreement with
Commission on
Dental Accreditation
of Canada (CDAC).
• In 2002 the Dental
Board of California
implemented a
Not stated on website. There are no exemptions.
Applicants must sit the
test if they did not
complete a program
accredited by the
Accreditation Council
for Pharmacy
Education (ACPE)
which only lists US
jurisdictions.
54
FINAL Contrastive Country Audit
5 November 2012
Barbados, Canada
(and select schools in
Quebec), Ireland,
Jamaica, New
Zealand, South Africa,
Trinidad and Tobago,
the UK; and
• Textbook and
instruction was in
English.
Florida:
• If nursing coursework
was in English and
English textbooks
were used.
Illinois:
• If first language is
English
process to approve
dental schools
outside the US and
Canada. Graduates of
those approved
dental school will be
able to sit for the
California Dental
Board
55