Vastuskiri

A. Proof of education/training-related qualifications First, thank you for bringing to our notice, that “overall classification of the qualification such as summa cum laude” is not requested by your authority. Second, to ensure that we effectively identify all formal qualifications proofs that are relevant for the recognition procedure of healthcare professionals, could you please also comment on the following questions? The current formal qualification proofs (slides 19-21) cover proofs that refer to post- secondary general education (namely higher education diplomas), as well as secondary (EQF 3-4) and post-secondary (EQF ≥5) vocational qualifications. Below you see how these three proofs are positioned within the hierarchical classification of formal qualification requirements (a slightly revised version of slide 18).

Question-1: Has your authority identified the need to request proof of qualifications that are not covered by the currently tertiary education and the vocational education & training

requirements currently listed in the slides 19 to 21? For example, for qualifications mentioned in Article 11(a) or Article 11(b). Question-2: Spain has submitted a separate proof for qualifications that do not fall under tertiary (higher) education diplomas but that refer to course/training that proves specialist competence and which may be required in addition to the diploma. Has your authority identified the need for requesting such proof?

• Question-2.1: If the answer to the above is yes, would you re-use the description shown in slide 30 or would you need to revise it and how?

• Question-2.2: Would such proof need to be added to Level 2 proofs, alongside the general and vocational proofs shown in the diagram above, or would it be a type of general/vocational qualification?

B. Proof of absence of criminal record

You commented that your authority “only needs the information regarding one’s rights to practice the profession”. Given that “proof of absence of suspension/prohibition of practice” (slide 23) addresses this need, your comment leads us to understand that “proof of absence of criminal record” isn’t needed by your authority. Is our understanding correct? C. Proof of absence of suspension/prohibition of practice

Is it sufficient for your authority to know that there is no suspension/prohibition in place when the applicant completes the procedure, or does your authority also need history of any previous suspensions/prohibitions of practice? D. Proof of change of name Thank you for bringing to our attention that although your authority needs this information, it is the applicant that must issue such proof, not a competent authority from another Member State. However, we’d like to ask what would happen if there were an option to get such evidence from a competent authority. Would you accept it, or would you still need the applicant to issue this proof? E. Proof of acquired rights

Thank you for clarifying that when acquired rights apply, your authority needs confirmation that the qualification meets the conditions of Article 23. Could you please also advise on the following? Question-1: Does your comment mean that instead of having two separate requirements, like the ones shown in slides 34 & 35, it would be sufficient to have a single requirement “proof of compliance with acquired rights” that would cover all cases of Article 23? Question-2: What are your thoughts about merging compliance of qualifications with Annex V (slide 26) and compliance with acquired rights in a single requirement? For instance, using as name “proof of conformance to EU harmonised minimum training requirements” and as description “Proof that the evidence subject's (natural person) formal qualification conform to the harmonised minimum requirements as laid down in Chapter III, Title III of the Directive 2005/36/EC.”? Question-3: As the evidence provider, does your authority have such evidence of compliance ready for exchange, or would the applicant need to request it first for your authority to issue it and make it available for exchange? F. Proof of diploma supplement/Proof of transcript Question-1: Do you request any of these proofs for applicants falling under the general system? If the answer is yes:

• Question-1.1: Do the current definitions (slides 41-42) reflect the information needs of your authority?

• Question-1.2: The minimum information defined for the “proof of tertiary education transcript” (ID 3) is also contained in the current minimum information of the “proof of diploma supplement” (ID 312). Consequently, the information contained in the evidence of transcript would be a subset of the information that is contained in the evidence the diploma supplement. Does your authority still see both as relevant? Is there some other proof that may be relevant, e.g., for clarifying the extent/subject matters of the studies?

G. Regarding the general system of recognition When a healthcare professional from another Member State applies for general system recognition in Estonia, do the requirements shown in slide 39 reflect the proofs that such an applicant would need to submit to your authority? Are there any additional proofs that your authority would need?

A. Proof of education/training-related qualifications First, thank you for bringing to our notice, that “overall classification of the qualification such as summa cum laude” is not requested by your authority. Second, to ensure that we effectively identify all formal qualifications proofs that are relevant for the recognition procedure of healthcare professionals, could you please also comment on the following questions? The current formal qualification proofs (slides 19-21) cover proofs that refer to post- secondary general education (namely higher education diplomas), as well as secondary (EQF 3-4) and post-secondary (EQF ≥5) vocational qualifications. Below you see how these three proofs are positioned within the hierarchical classification of formal qualification requirements (a slightly revised version of slide 18).

Question-1: Has your authority identified the need to request proof of qualifications that are not covered by the currently tertiary education and the vocational education & training

requirements currently listed in the slides 19 to 21? For example, for qualifications mentioned in Article 11(a) or Article 11(b). Question-2: Spain has submitted a separate proof for qualifications that do not fall under tertiary (higher) education diplomas but that refer to course/training that proves specialist competence and which may be required in addition to the diploma. Has your authority identified the need for requesting such proof?

• Question-2.1: If the answer to the above is yes, would you re-use the description shown in slide 30 or would you need to revise it and how?

• Question-2.2: Would such proof need to be added to Level 2 proofs, alongside the general and vocational proofs shown in the diagram above, or would it be a type of general/vocational qualification?

B. Proof of absence of criminal record

You commented that your authority “only needs the information regarding one’s rights to practice the profession”. Given that “proof of absence of suspension/prohibition of practice” (slide 23) addresses this need, your comment leads us to understand that “proof of absence of criminal record” isn’t needed by your authority. Is our understanding correct? C. Proof of absence of suspension/prohibition of practice

Is it sufficient for your authority to know that there is no suspension/prohibition in place when the applicant completes the procedure, or does your authority also need history of any previous suspensions/prohibitions of practice? D. Proof of change of name Thank you for bringing to our attention that although your authority needs this information, it is the applicant that must issue such proof, not a competent authority from another Member State. However, we’d like to ask what would happen if there were an option to get such evidence from a competent authority. Would you accept it, or would you still need the applicant to issue this proof? E. Proof of acquired rights

Thank you for clarifying that when acquired rights apply, your authority needs confirmation that the qualification meets the conditions of Article 23. Could you please also advise on the following? Question-1: Does your comment mean that instead of having two separate requirements, like the ones shown in slides 34 & 35, it would be sufficient to have a single requirement “proof of compliance with acquired rights” that would cover all cases of Article 23? Question-2: What are your thoughts about merging compliance of qualifications with Annex V (slide 26) and compliance with acquired rights in a single requirement? For instance, using as name “proof of conformance to EU harmonised minimum training requirements” and as description “Proof that the evidence subject's (natural person) formal qualification conform to the harmonised minimum requirements as laid down in Chapter III, Title III of the Directive 2005/36/EC.”? Question-3: As the evidence provider, does your authority have such evidence of compliance ready for exchange, or would the applicant need to request it first for your authority to issue it and make it available for exchange? F. Proof of diploma supplement/Proof of transcript Question-1: Do you request any of these proofs for applicants falling under the general system? If the answer is yes:

• Question-1.1: Do the current definitions (slides 41-42) reflect the information needs of your authority?

• Question-1.2: The minimum information defined for the “proof of tertiary education transcript” (ID 3) is also contained in the current minimum information of the “proof of diploma supplement” (ID 312). Consequently, the information contained in the evidence of transcript would be a subset of the information that is contained in the evidence the diploma supplement. Does your authority still see both as relevant? Is there some other proof that may be relevant, e.g., for clarifying the extent/subject matters of the studies?

G. Regarding the general system of recognition When a healthcare professional from another Member State applies for general system recognition in Estonia, do the requirements shown in slide 39 reflect the proofs that such an applicant would need to submit to your authority? Are there any additional proofs that your authority would need?