Foreign-Trained Kenyan Doctor Seeking First Licence
Dr M is a Kenyan citizen who graduated in 2018 from a medical school in East Africa that appears on the Council’s approved list. She completed a 12-month internship in that country, obtained a certificate of good standing, and has worked for four years in emergency departments there. She returns to Kenya with a county hospital offer to start in three weeks as a medical officer. Her documents include her degree certificate, transcript, internship logbook, certificate of good standing, and a letter from the county. She has never held a Kenyan licence. She asks whether she can begin work immediately while her application is processed, and whether her foreign internship will count. The county HR officer proposes to deploy her as a ‘supernumerary’ doctor until the licence arrives. A relative advises her to apply for temporary registration so she can cover the emergency department alone.
1. Identify the registration pathway and the key determinations the Council must make before Dr M may practise.
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Dr M is not automatically entitled to full registration merely because her school is on the approved list and she completed a foreign internship. The Council must verify her identity and citizenship, the institution and programme, the degree and transcript, the content and duration of the internship, her registration and good standing abroad, and any competency or language requirements. It must then decide equivalence: full registration, supervised practice, a bridging or competency assessment, or a prescribed period of internship in Kenya. The outcome should be recorded with reasons, and any additional training should be proportionate to the gaps identified. Until a licence is issued, she must not be rostered for independent clinical duties. Temporary registration is not a shortcut for service cover; it is time-limited, purpose-specific, and may require supervision. The county should treat the three-week start date as provisional and should not assume that the application will succeed within that period.
2. Advise the county hospital on the proposed ‘supernumerary’ deployment and on emergency cover before registration.
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Calling Dr M ‘supernumerary’ does not change the substance of the arrangement. If she takes histories, writes orders, performs procedures, signs discharge summaries, or is the only doctor on duty, she is practising medicine and must be registered and licensed. A lawful arrangement is observational shadowing with no patient-care responsibility, or supervised practice under a Council-approved registration category with a named supervisor who remains accountable. The hospital should roster licensed doctors for emergency cover, use a locum with a valid licence and verified privileges if necessary, and document who is supervising whom. It should tell Dr M in writing that she cannot start clinical work until the licence is produced. Allowing unregistered practice exposes both the doctor and the facility to regulatory action and may leave patients without proper indemnity cover.