BATTLING FOR THE SOUL OF QUALITY MEDICAL LABORATORY PRACTICE IN GHANA; THE GAMLS-MSSG-GCPS/GMA AXIS

On 7^th August 2020, a letter came out from the Office of the Director of Noguchi Memorial Institute for Medical Research (NMIMR), addressed to the Chairperson of an internal NMIMR committee which is tasked with “Promoting Licensure and Practice of Bio-Medical Scientists”. The committee aims to “correct” the current legally sound norm of medical laboratory science in Ghana being the sole preserve of people who studied Medical Laboratory Science ONLY and subsequently got themselves licensed to practice, after satisfying the necessary regulatory requirements. Among other terms of reference, the committee is to engage the Minister of Health, the Director General of Ghana Health, Service, the Presidential Advisor on Health as well as the Parliamentary Select Committee on Health in order to address purported anomalies in both the Health Professions Regulatory Bodies (HPRB) Act 857, 2013 and the National Health Laboratory Policy (NHLP) documents. They are to submit their work to the NMIMR Director, by 31^st October 2020.

This directive quite expectedly got members of Ghana Association of Medical Laboratory Scientists (GAMLS) enraged, judging from the unusual agenda of an NMIMR state institution whose core mandate is for medical research and not medical laboratory diagnostics, also setting up a formidable team to “renovate” the scope of standard medical lab practice in Ghana. Obviously the NMIMR authorities are riding on a crest of a wave of nationwide and global popularity as a result of the key function it is playing in the lab diagnosis of the COVID 19, a role which could have easily been avoided had the NHLP been operational to address the necessary thematic areas of Infrastructural development and Equipment, which are both captured there in the document. We need to come to speed with how the present calm and crystal clear waters of medical lab practice in Ghana is now apparently under threat, due to certain interest professional groups within the health and/or academic sectors. Despite the fact that the legal authority of the Allied Health Professions Council (AHPC) as enshrined in the “Registration” sub section of the HPRB Act 857 2013, gives it the right to endorse both human resource and medical facilities for medical lab practice, this does not really seat well with the other interest groups, including lately NMIMR.

It is important to note that way back in 2009, the Ghana Health Service wrote a letter to the US Center for Disease Control and Prevention (CDC), to assist in reviewing an existing national health lab policy draft document of 2004, for operation in Ghana. A Technical Committee drawn from both the public and private health lab sectors, finalised the NHLP documents and presented them to the Ministry Of Health (MOH) for due launching. However, a Ghana College of Physicians and Surgeons (GCPS) force majeure in 2013, made sure that the documents which were duly signed by then sector Minister Ms Hanny Sherry Ayittey, did not see daylight. The GCPS argued that they were left out of the preparation of the documents, though they are supposedly stake holders in training and practice of medical lab in Ghana.

A GPCS inspired 5 member stake holders committee was therefore put together to as it were, review the botched NHLP document and develop a roadmap for possible re-launching. The work of this committee was however not transparent enough and GAMLS thought the day to day delay in the launch of the policy, was just a deliberate ploy by detractors who were bent on suppressing the necessary positive impact of medical lab professional advancement  within the health space. GAMLS therefore could not tolerate the buying of time anymore, judging from the health needs of the Ghanaian people and also the millions of US Dollars of CDC support going waste. Quite predictably, a massive nationwide industrial action was called for all medical lab professionals both in public and private practice, on August 19^th 2016, to press home the need to launch the policy.

The way the strike action negatively affected healthcare delivery in the country, compelled the government of the day to intervene through the setting up of yet another stake holders committee this time headed by Prof Ernest Aryeetey, former Vice Chancellor of the University of Ghana (UG), to take a deeper look at the issues at stake by the other health and/or academic interest groups.

The other members of the 3 member Prof Aryeetey Committee were Dr Abdul Basit Bamba (high legal luminary and a law lecturer of UG) and Prof Adjei Nsiah (Associate Professor and Head of Centre (Forest and Horticultural Crops Research Centre of UG) and they were tasked with the following mandates and to furnish the then Health Minister for the way forward;

1. Study and analyse the policy documents and petitions submitted to the Ministry
2. Conduct an extensive interview to solicit reasons for or against implementation of the policy
3. Consult widely on best practices in the development of health laboratory policies
4. Present recommendations to the Health Minister

The Committee therefore swung into action by holding at least 2 hours each of meetings with the following interest groups on separate respective dates;

1. Medical Scientists Society of Ghana (MSSG)
2. Ghana Association of Medical Laboratory Scientists (GAMLS)
3. Ghana College of Physicians and Surgeons (GCPS)
4. Allied Health Professions Council (AHPC)
5. Ghana Health Service Council
6. Boards of the Teaching Hospitals
7. Ghana Medical Association
8. Ghana Medical and Dental Council
9. Health Facilities and Regulatory Council (HeFRA)
10. Institutional Care Division, GHS
11. Policy Planning Monitoring and Evaluation (PPME) of Ministry of Health
12. Committee of Trainers of Biomedical Scientists

This write up is an attempt to enlighten GAMLS members and the general public in summary, about the various grievances or positions made by the 3 main GAMLS, MSSG and GCPS/GMA “contenders”, as submitted to the Prof Aryeetey Committee, in order to let us appreciate the real reason why the NMIMR Director has found it necessary to write his letter, as stated here early on.

1. MSSG

This group of biomedical scientists trained in the natural sciences in our various universities also have some of their personnel working in research facilities, medical labs and in industrial circles.

MSSG contends that before 2004 and 2005, when the first batch of pure medical laboratory graduates from KNUST and UG respectively passed out, GAMLS represented a broad group of medical lab professionals, until the new breed of graduates backed by GAMLS, began agitating for the exclusion of persons with natural sciences backgrounds from our various medical laboratories. They said this was emphasised by the moves to change the name of the professional association from Ghana Association of Biomedical Laboratory Scientists (GABMLS) to Ghana Association of Medical Laboratory Scientists (GAMLS), to reflect the status quo, which was eventually done during an annual GAMLS congress held in Winneba in 2016.

They reported to the Prof Aryeetey Committee that GAMLS formally wrote a letter to the MOH indicating that biomedical scientists/biochemists should no longer be employed in order to give room for more graduates of people trained solely in medical laboratory science, to be engaged. Invariably, GAMLS will still work with old biomedical scientists but not new ones. This compelled some members of the remaining biomedical scientists/biochemists still in employment in public and private facilities, to pull out from GAMLS to form MSSG, to seek their own welfare and future. Besides, MSSG told the committee that though they were present when discussions bothering on the HPRB Act Bill were held, GAMLS executives held other meetings on their blind side prior to the final bill document submission to Parliament, whose content they claim was totally different from what they know.

MSSG therefore posits that;

• They do not agree to the job title “Medical Laboratory Scientist” as captured in the HPRB Act 2013, since the MOH and GHS had already adopted the name “Biomedical Scientist” to embrace all laboratory professionals with bachelor degrees. They are of the view that the interpretation by AHPC that only persons with degrees or diplomas in medical laboratory science qualify to practice in our medical labs is erroneous.
• They do not also agree that persons with bachelor degree in natural sciences programmes and who have already had 1 year internship in medical labs should take additional courses before they can be registered to practice.
• AHPC refuses to register biomedical scientists/biochemists to enable them undertake medical lab internships and subsequent license to practice and therefore the policy as it stands, emboldens the AHPC unduly.
• GAMLS has influenced AHPC such that persons with natural sciences backgrounds have not written the licensure exams since 2013.
• The policy as it stands, stops people of natural sciences backgrounds from heading any medical laboratory.
• The policy in its present state, gives undue powers to GAMLS over MSSG in that all medical lab professionals are registered, certified and licensed exclusively under the umbrella of GAMLS.
• The HPRB Act needs amendments to include and register biomedical scientists/biochemists who have met the licensing conditions to practice in medical labs.

2. GAMLS

Since the 1970s when medical laboratory practice was formalised in the country, there has not been any regulatory body to guide its activities. To remedy this, an Allied Health Taskforce was set up in 2011 to lay the foundation of a Council which was later dissolved following the establishment of the AHPC.

GAMLS confirmed to the Prof Aryeetey Committee, about knowledge of the preparation of the policy document. They said when the policy was about to be launched, the GCPS petitioned MOH that the process be halted, even though they the GCPS were part of a stakeholders meeting where everyone had the opportunity to be privy to the final draft policy. GCPS claimed they were unaware of anything. When the MOH finally gave them opportunity to make their inputs, the GCPS made significant changes to the policy documents by slotting in their professors and GMA members. As a result of this, GAMLS withdrew itself from the exercise.

In 2013, Hon Sherry Ayittey examined and approved the policy document that was presented to her but the GCPS rejected it on the grounds that their inputs had not reflected in it.

GAMLS posited to the Prof Aryeetey Committee as follows;

• The claim of GCPS about a written letter concerning a stakeholders meeting is false.
• GCPS members want to head the medical labs even though they lack the requisite qualification to do so.
• GCPS made changes to the policy documents by replacing GAMLS names with those of GCPS members.
• GCPS wants to head the various medical labs under the sole supervision of Laboratory Physicians (LP).
• The policy and its related documents should be launched as a matter of urgency.
• Anybody who wants to work in the medical lab, should be registered by the AHPC and that it is a serious offence under section 21 (c) in Part One of the HPRB Act 2013, to profess or practice medical laboratory science, without prior registration and license by the AHPC.
• No one without medical laboratory science qualification can/should be registered and licensed.
• Biomedical Scientists should be trained in medical laboratory science before they can be considered to write the licensure exams and be registered with the AHPC.
• The MOH and its agencies should not recruit biomedical scientists/biochemists to work in medical labs and that GAMLS would only allow them if AHPC creates a different licensing arrangement for them.
• The headship of the various levels of medical labs should only be opened to Medical Laboratory Scientists.
• Only qualified and experienced medical lab scientists should head the Directorates of Korle Bu, Komfo Anokye or other teaching and/or regional hospital labs.
• That professionals from the Ministry of Education (medical school staff) should not be made to head the Korle Bu Central Lab in particular and similar facilities nationwide.

3. GCPS/GMA

They told the Prof Aryeetey Committee that the Korle Bu administration has given so much powers to GAMLS over the Medical School in the management of the Central Lab and this has resulted in lots of indiscipline especially in absenteeism and unnecessary strike actions. These led to patients who can afford, to often resort to labs outside Korle Bu and thereby promoting many conflicts of interest situations.

They also told the Committee that theNHLP documents were developed without their inputs and as it stands now, poses a serious threat to their members’ survival and effectiveness as LPs. They said their members have being physically prevented from working in labs as a result of the apparent strength given GAMLS by Korle Bu management.

GCPS therefore posited to the Prof Aryeetey as follows;

• The policy should not be implemented until it is significantly reviewed to remove sections that affect their presence and roles in the labs. It is their view that the HPRB Act does not determine who can practice in the medical labs, but rather who a medical lab scientist is and how he/she may be regulated.
• The MOH should have an organogram to give clear direction in the management of labs.
• Laboratory reports should end with the LP and should therefore be signed by both the LP and medical lab scientist.
• The laws on medical and dental practice should be amended to relect the role of LPs.
• The policy should be amended because Laboratory Technicians cannot interpret some results.
• Headship of laboratories at the various levels should be open to only LPs.
• LPs cannot be regulated by the AHPC as they are already regulated by the Medical and Dental Council.
• GCPS should have oversight responsibilities at various levels of labs in the country, as the labs are also used for training purposes.

It is the firm belief of this writer that the practice of medical laboratory science in Ghana has come of age, with the generation of various levels of qualified personnel ranging from the consultants from the recently inaugurated West African Postgraduate College of Medical Laboratory Science (WAPCMLS), through to medical lab related PhD holders, masters, bachelors and diploma holders. Hitherto, the absence of a properly regulated environment meant that people of natural science backgrounds have successfully “encroached” on the medical lab space and this has strongly compromised standard and quality medical lab services in most cases in the country. Also, before the creation of the AHPC and HeFRA, all manner of funny and substandard medical lab facilities proliferation was the order of the day. Even though the present situation of private medical labs is far from perfect, it is a significant improvement in a regulatory law enforcement environment than before.

The autonomy of medical laboratory science in Ghana as spelt out in the HPRB Act 2013, in which medical laboratory scientists must be distinctively registered only by the AHPC under the Part One of the law, whereas, LPs are registered only by the Medical and Dental Council under Part Two of the same law, ought to be respected by all. An attempt or continual attempts by certain conflicting groups such as the MSSG and NMIMR to hold on to the soul of medical laboratory services will therefore not inure to the overall good of healthcare delivery in Ghana. The insistence and consistence of GAMLS on this absence of a NHLP issue, is truly not self-seeking but rather attempts at underscoring the need for quality practice and effective management of medical laboratory services in Ghana.

A recent letter from GAMLS dated on the 18^th August 2020, which was addressed to the Chief Director of the MOH and copied to the Minister of Health, DG of GHS, AHPC, HeFRA, WAPCMLS, HSWU, Allied Health Federation, etc, formally informs them about the upcoming inauguration of the Society of Medical Laboratory Managers, Ghana (SMLM-G), which is slated for Tuesday 25^th August 2020. It is indeed a great boost to the forward march of medical laboratory profession in Ghana and there is therefore no need for any fear or panic from any quarter. As experienced by GAMLS for now, it is said that “the flower that blooms in adversity is the rarest and most beautiful of all!” (Walt Disney).

MLS EMMANUEL TOBOH (Manny) writes

(24/08/2020)