More and more reservations about the Ministry of Health regulation. Another profession wants changes in the list of qualifications

• During the consultations, the Ministry of Health included almost all proposals submitted by the National Centre for Combating Addictions in the list of activities of addiction therapy instructors.
• The union members cannot agree with several proposals. - If the list indicates that one of the instructor's tasks is to lead a therapeutic community, then he should also be able to conduct an initial interview with the patient - believes Grzegorz Święch
• In an interview with Rynek Zdrowia, he also talks about which activities should be deleted or narrowed down from the list. - We will apply for a meeting at the Ministry of Health and a substantive discussion - he announces
• Associations and professional organizations bringing together representatives of individual professions included in the Act on Certain Medical Professions will send a joint letter regarding the regulation to the Ministry of Health.

The amended draft regulation on the list of professional activities of persons performing certain medical professions, published at the beginning of February, has sparked controversy in some trade union circles.

The most dissatisfied are medical caregivers, whose new list of authorizations significantly limits the scope of their activities, which they have performed so far. Optometrists are also disappointed, as the Ministry of Health has not included them in the list of preventive examinations.

The list of prepared objections from individual professions to the project is growing. The Trade Union of Psychiatric and Addiction Treatment Workers (ZZPLPiU) will also submit its comments to the proposed list of activities of an addiction therapy instructor to the Ministry of Health.

During the consultations, the Ministry included in the list almost all proposals submitted by the National Centre for Combating Addictions (KCPU).

Trade unionists admit that although most of the solutions for addiction therapy instructors included in the new list are substantive and the fact that they regulate the professional activities of this professional group deserves praise, they cannot agree with several proposals.

- We will propose supplementing the proposed scope of activities with conducting an initial interview with an addicted patient or a close person of the patient. This is a task that is most definitely within the competence of the instructor and is carried out by him in medical entities. Moreover, if the list clearly indicates that one of his tasks is to lead and participate in a therapeutic community, then he should also be able to conduct an initial interview - points out Grzegorz Święch, chairman of the National Commission of the ZZPLPiU and a certified specialist in addiction psychotherapy.

Grzegorz Janoszka from the "Monar" Association and ZZPLPiU is of the same opinion and emphasizes that the initial interview should not be confused with a diagnostic interview, which an addiction therapy instructor cannot actually perform.

He also recalls that just a few years ago, one could come across a list of instructors' tasks on government websites that had little to do with reality.

- It included isolating aggressive people, taking care of the hygiene of the rooms by cleaning, washing and disinfecting floors, walls, beds and other objects, and performing basic medical procedures such as stomach lavage and enemas. It was completely incompatible with what an addiction therapy instructor does. Meanwhile, an instructor is a therapist and I would like this to be clearly heard - he emphasizes.

Both experts, however, have reservations about including in the new scope of instructors’ competences accompanying patients on outings and taking part in external conferences and coordination sessions.

According to Janoszka, it is very rare for patients to be accompanied, and if it is, it is done by someone from the staff on duty at the facility. Święch, on the other hand, points out that if we assume that an addiction therapy instructor performs his or her job in a medical facility, then in such facilities, patients are not usually accompanied when leaving.

- This is an activity that basically goes beyond the performance of professional duties at a job position in the workplace, so we will demand its removal from the list - says the chairman of the National Commission of the ZZPLPiU.

- The phrases external conferences and coordination sessions should also be removed, because instructors do not participate in something like that. We do not really know what they mean. Therefore, the activity should be limited to participation in internal conferences, which are organized in every addiction treatment center at least once a week - he points out.

Grzegorz Święch would also remove from the list of activities the point relating to conducting consultation and educational activities in the environment of psychoactive substance users and their relatives.

- This provision goes beyond the activities of an instructor, because it should be understood that he would be performing certain preventive activities that are associated with so-called street work. I have not met addiction therapists who would use street work. I am not saying that it is not done in the world, but when constructing a list of professional activities we should base it on experiences from the country. It is also difficult for me to imagine a situation in which an employer imposes on an instructor, and we also have women in this profession, the obligation to go out with consultation and educational activities on the streets, at train stations or in clubs. It is too risky and we will propose deleting this activity from the list - he announces.

All the more so because - as the expert points out - the list of competences already includes a provision on planning and implementing consultation and information sessions, which does not raise any doubts in the community.

On the positive side, Grzegorz Janoszka would also like to mention the inclusion of activities such as running support groups for addicts and their loved ones, implementing psychoeducational activities or programs to reduce health and social harm , which - as he explains - are today a very important element of addiction therapy and can be performed by instructors.

A detailed list of professional activities is to be regulated, let us recall, by the regulation to the Act on Certain Medical Professions, which has been in force since 26 March 2024. The initial draft of the regulation was published a year ago. The consultation period was shortened at that time - as the ministry explained - out of the need to ensure that the provisions enter into force together with the act.

The number of submitted comments (the report of submitted opinions is over 500 pages long) from various organizations and representatives of individual professions covered by the act, however, extended work on the project by a year. The new version, which was supposed to be the final one, was not presented by the Ministry of Health until 5 February this year.

During the last meeting of the Tripartite Team, Minister Izabela Leszczyna announced that due to the divergent positions of trade unions and employers' organisations regarding the regulation, she would refer the draft for discussion to the Tripartite Team.

Święch reveals that associations and professional organizations bringing together representatives of the professions covered by the act will send a joint letter regarding the regulation to the Ministry of Health.

- We will apply for a meeting at the Ministry of Health and a substantive discussion so that at the end of the work on the project, the ministry will take into account the comments of the social side. After all, these are the opinions of practitioners - announces the unionist.

It also draws attention to the fact that the prolonged work on the lists of professional activities for individual professions creates a risk that the training courses currently being developed will not be consistent with them.

- We currently have a situation in which we do not yet have the final version of professional activities, and the Team of Experts appointed by the Center for Postgraduate Medical Education from autumn 2024 is developing course programs, somewhat guessing which activities will ultimately be included in the regulation. This is not how this process should look - emphasizes Święch.

The original version of the draft act on certain medical professions did not include, let us recall, addiction therapy instructors.

However, the community managed to force the government to include the professional group in the project at the parliamentary stage. The act regulates issues related to the training of instructors, imposes on them the obligation of continuous training, introduces a register and professional responsibility.

- We are proud of this, because as a union we contributed to the inclusion of addiction therapy instructors in the list of medical professions, which helps us anchor ourselves in the medical community. Our next postulate is to include the profession in the act on the method of remuneration of healthcare workers. For now, the profession has not been entered by name in the pay table, which gives employers room for abuse and there are still facilities that pay instructors the minimum national wage - says Grzegorz Janoszka.

According to Grzegorz Święch, it is necessary to supplement the act, commonly known as the pay rise act, with new medical professions.

- An addiction psychotherapy specialist should be in the table in group two, and an addiction therapy instructor - in group six. Unfortunately, without this, employers recognize our qualifications in different ways. Some recognize psychotherapy specialists in group two and pay the pay rises planned for this group. However, there is still a group, led by employers from the Podkarpackie province, that refuses to classify specialists in group two and classifies instructors in group 10 - he says.

The provisions of the pay rise act are also interpreted differently by the district labour inspectorates. - The labour inspectorate in the Podkarpackie province agreed with the employers' arguments. Generally, however, there is a free-for-all in this respect. Despite the fact that the previous management of the Ministry of Health assured that the State Labour Inspectorate would decide cases in favour of therapists - says Święch.

He also points out that since instructors have had their profession regulated, it would be even more necessary to regulate the profession of addiction psychotherapy specialist. - It is strange that the specialist who supervises the work of the instructor is still not regulated - emphasizes the unionist.

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