We wrote to you on 25th January 2024 about the changes to the ethical Rules, specifically about the regulations for Multidisciplinary or Group practices and the employment of doctors by private hospitals.
 
The HPCSA has issued a Business Practice Policy Document, to provide further interpretation and clarity on some of these changes. This new document does not change anything significantly but has confused the Ethical Rules position on multidisciplinary or group practices. We think that this is just a drafting error, and we have written to the HPCSA asking them to correct this with an addendum.
 
The Ethical Rules are quite clear (Annexure 6, 3 (2)). Radiologists can only practice in partnership, association, or as a juristic person with Radiographers and Nuclear Medicine Physicians. They cannot form partnerships or associations or have business dealings with clinicians that involve sharing radiology income. This would also fall foul of the perverse incentive guidelines. There is no prohibition in working in multidisciplinary oncology or other teams and receiving consultancy fees for this; the prohibition is pooling or sharing radiologists' income with any clinician.
 
We are aware that structures may be in place or are being contemplated which may fall foul of the Ethical Rules as they apply to radiologists and group practices. If you are aware of these and have evidence of such, please let me know, and we will investigate further and report to the appropriate authorities if necessary.

Richard Tuft

Executive Director