The RCVS is encouraging all members of the veterinary team to respond to a consultation launched by Defra last week, which is seeking views on whether English language testing should be introduced for European Union veterinary graduates who qualified outside the UK.
Outlining its proposals on July 22, Defra explained that, under the European Professional Qualifications Directive (PQD), which aims to facilitate the free movement of professionals within the EU, the RCVS has the right to ensure that any EU vet seeking to work in the UK has the necessary knowledge of English as a condition of registration. However, the Veterinary Surgeons Act, as it currently stands, does not allow the RCVS Registrar to ask for such evidence during the registration process. This, Defra says, means that the RCVS must register any EU vet who holds recognised qualifications and provides the required evidence of good character, even if there are concerns about their ability to practise because of language difficulties.
In contrast, applicants from outside the EU/European Economic Area (EEA) are subject to language checks and have to sit the International English Testing System examination to establish their competence before they are registered. The Veterinary Surgeons Act allows the RCVS Registrar to seek this evidence.
Defra notes that there appears to be disparity in the level of assurance required between European applicants, UK applicants and overseas applicants to the RCVS Register. ‘The proposed controls for EU veterinary surgeons will close the current gap and ensure that all veterinary surgeons who request to work in the UK have the necessary knowledge of English. We believe that the proposals improve equality, rather than being detrimental to one particular group of people,’ it says.
Defra reports that figures provided to it by the RCVS showed that, in the past five years, 118 European vets were referred to the RCVS Preliminary Investigation Committee, 18 of whom had problems communicating in English. Nineteen European vets were referred to the Disciplinary Committee, six of whom had problems communicating in English, with two requiring interpreters. In addition, 15 European vets requested that an interpreter accompany them to their registration.
Defra proposes that the RCVS Registrar should be provided with the explicit right to require that any new applicant to the Register demonstrates competence in the English language. Under the PQD, controls on language may be imposed by a competent authority (in this case the RCVS) only when there is ‘serious and concrete doubt’ about the sufficiency of the professional’s language knowledge in respect of the particular professional activities, and following formal recognition of the applicant’s qualification. Therefore, Defra is proposing that, during their registration process, EU veterinary graduates will be asked to ‘self-certify’. It says: ‘The ability of an applicant to answer the questions asked at this stage will in itself be a demonstration of English language capability. Other evidence of ability will be accepted, such as: having lived in a multilingual household (including English); having studied his/her degree in English; having worked for an English-speaking company.’
If the applicant was unable to satisfactorily demonstrate language competence, the RCVS would then be able to use formal testing. It would write to the applicant confirming that they held a recognised qualification, but explaining that their registration was on hold pending the language test. Defra suggests that applicants could be given the chance to volunteer or work in a veterinary establishment in any capacity other than as a veterinary surgeon as a means of improving their language competence. They would then reapply once they were confident of their language competence. Provisions are also included in the proposals for the RCVS to use language testing if concerns arise during the various stages of the registration process; for example, in the period between application and final registration.
‘For the vast majority of EU migrant vets who apply to work in the UK, we believe that there will be no cause for concern and registration will proceed as normal,’ Defra says. ‘We believe that applying language controls in this manner meets the objective of reducing risk and preventing harm to animal health and welfare and public health while remaining proportionate and not introducing artificial barriers preventing migrant vets from working in the UK.’
Encouraging veterinary surgeons, veterinary nurses and other members of the practice team to respond to the consultation, the RCVS said on July 23 that, every year, about half of all new veterinary surgeon registrants came from outside the UK, the majority from other EU or EEA countries..
Gordon Hockey, the RCVS Registrar, said: ‘Under the current legislation the College is not able to bar someone from joining the Register, and therefore practising, on the basis of language ability, even where we may have serious concerns. I would encourage all veterinary surgeons, veterinary nurses and other members of the practice team to engage with this consultation and consider whether the College should have the right to impose a language test where it has serious doubts, more in line with medical doctors, and the form such testing would take.’
The College said that the results of the consultation would inform its work with Defra to determine whether to proceed with implementing language testing and, if so, to develop the most appropriate system. It added that it would implement language testing for veterinary nurses in parallel with any changes for veterinary surgeons.
The consultation document is available at https://consult.defra.gov.uk/animal-health-and-welfare/vet_language_controls. Comments have been invited by September 30.