We Are a Leading European Provider of International Solutions to Staff Shortage Problems

PARAGONA POLSKA Ltd

Al. Jana Pawła II 29

00-867 Warsaw, Poland

Warsaw, March 14th 2011

Dear Sirs/Madam,

we are a leading European provider of international solutions to staff shortage problems for the healthcare sector.We are helping doctors, dentist and other healthcare professionals in finding work in Scandinavia, France, Germany and the UK. To date we have helped over 1 000 healthcare professionals and family members start a new professional and personal life abroad. On average, 95% of our healthcare professionals stay in the country to which they have been recruited.

The EU has brought unprecedented opportunities for professionals seeking to move across national boarders in search of personal and professional development. As an organisation, we are passionate about helping medical professionals to takeadvantage of thisunique situation.

Question 1: Do you have any suggestions for further improving citizen's access to

information on the recognition processes for their professional qualification in another

Member State?

Yes, doctors who would like to work / educate themselves in another Member State should be informed in advance on what basis will their diplomas be recognized (how does the process look like). Maybe a single act regulating recognition in details would be helpful here.

Question 2: Do you have any suggestions for the simplification of the currentrecognition procedures? If so, please provide suggestions with supporting evidence.

Yes, we consider that in order to simplify the existing rules to the benefit of individual citizens, the examination of medical knowledge in German – obligatory to obtain authorization of medical diploma in this country – should be canceled. We have encountered such a form of obligatory test while recruiting doctors to hospitals in Nordhein- Westfalen region in Germany. The government ofcity of Detmold („Bezierksregierung Detmold”) asked doctor to present themselves in front of commission which has checked their knowledge of medicine in German.It is a indispensable requirement to obtain a diploma recognition. We consider such proceedings as conflicting with Single Market Act. Recognition of medical diploma should not depend on knowledge of German but base on presented documents. It’s employer who decideswhether to recruit a person who speak or doesn’r speak the language used at work. We thinkthat the diploma recognition should not be influenced by local government assessing the level of medical knowledge in local language. It doesn’t mean that we are imposing a blanket ban on language testing. Doctors should be able to demonstrate their langugae skills but no as an extra condition of automatic recognition based on professional experience.

Question 3: Should the Code of Conduct become enforceable? Is there a need to amend

the contents of the Code of Conduct? Please specify and provide the reasons for your

suggestions.

In our opinion the Code of Conduct should become enforceable as some local governments organize additional test of medical knowledge in German for doctors, which is a condition for receiving anauthorization of original medical diploma (f.e. the government of city of Detmold organizes such an examination).

Question 4: Do you have any experience of compensation measures? Do you consider

that they could have a deterrent effect, for example as regards the three years duration ofan adaptation period?

Hospitals with which we cooperate organize some time of adaptation period after doctors arrival to new country. It helps doctor to integrate in new healthcare system and contributes to the fact that they stay longer/for good in a new Member State.

Question 7: Do you consider it important to facilitate mobility for graduates who are not

yet fully qualified professionals and who seek access to a remunerated traineeship or

supervised practice in another Member State? Do you have any suggestions? Please be

specific in your reasons.

We consider it as very important as we have been recruiting young doctors (wihout specialization) to Germany and they have started their professional training there. We consider that the time of traineeship should be clearly specified and there should be no workobligation ina specificcountryafterreceivingeducationon itspremises.From our experience a commitment to work on the territory of German Republic after finishing specialization there is a very discouraging factor for graduates from Poland, Romania, Hungary and Lithuania.

Question 8: How should the home Member State proceed in case the professional wishes

to return after a supervised practice in another Member State? Please be specific in yourreasons.

They should be positive to it. Please see the explanation above.

Question 11: What are your views about the objectives of a European professional card?

Should such a card speed up the recognition process? Should it increase transparency forconsumers and employers? Should it enhance confidence and forge closer cooperationbetween a home and a host Member State?

We think that such a card would support mobility in the context of faster recognition of qualifications. For the moment to have his university diploma in Germany recognized a doctor from eastern Europe needs about 13 documents from different authorities (they all need to be officialy certified, translated and delivered to local authority in Germany). Such a card would in every respect speed up the recognition process and increase transparency as well – not so much paper work would be assigned to local authorities which deal with a lot of local cases already. Also local government is not always specialized in dealing with foreign documents and assesing foreign qualifications. In our opinionon there is a need for separate European institution for this purpose.

Question 23: Should a Member State be obliged to be more transparent and to provide

more information to the other Member States about future qualifications which benefit

from automatic recognition?

Yes, it would contribute to bigger mobility among individuals. Automatical recognition of future qualifications will be an incentive for individuals to search for a job corresponding with their educationabroad.