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Medical practitioner to be registered without conditions

03 May 2016

A medical practitioner who sought a review of a decision to refuse him unrestricted specialist registration is to be registered without conditions.

Dr Christopher Alroe sought specialist registration as a general practitioner in March 2014. Dr Alroe’s application was ultimately refused because the Medical Board of Australia (the Board) did not make a decision within the required timeframe. However, before this occurred, the Board offered to grant Dr Alroe specialist registration subject to conditions requiring that he enter into a mentoring relationship.

When considering Dr Alroe’s application for specialist registration, the Board examined Dr Alroe’s extensive disciplinary and registration history. Dr Alroe had previously been found guilty of:

  1. engaging in a sexual relationship with a patient and his specialist registration as a psychiatrist was cancelled
  2. engaging in poor clinical practice that led to the death of a young patient, for which cancellation of his registration was extended, and
  3. breaching conditions imposed upon his registration as a consequence of the disciplinary proceedings described in (b) above.

The Board was satisfied that Dr Alroe was qualified for specialist registration, but gave further consideration to whether he was suitable. The Board made further enquiries in this regard and Dr Alroe made submissions addressing his suitability, including his previous disciplinary history.

The Board’s position was that in his submissions, Dr Alroe did not discharge the onus upon him to demonstrate that he was a fit and proper person to hold specialist registration, including that he did not show adequate remorse, understanding or acknowledgement of his misconduct or harm to others.

The Board’s view was that he would only be suitable to hold specialist registration if this registration was subject to restrictions. Because the Board failed to make a decision on Dr Alroe’s application within the required timeframe, it was taken as a decision to refuse to register under section 85 of the National Law.1

In September 2014, Dr Christopher Alroe lodged an application to review the refusal of his application for specialist registration.

In the review proceedings before the Queensland Civil and Administrative Tribunal in September 2015, Dr Alroe sought that an order be made for the Board to grant him unrestricted specialist registration. The Board continued to seek that any specialist registration be subject to conditions.

In deciding whether it was necessary to make Dr Alroe’s specialist registration subject to conditions, the tribunal considered that:

  • specialist registration may call for a higher standard or expectation from the public or Dr Alroe’s peers, although the tribunal did not squarely decide this, and
  • Dr Alroe appeared to display a lack of insight, and the conditions proposed by the Board did not appear onerous or unreasonable.

The tribunal found that it was not necessary for conditions to be imposed. It was reasonably satisfied (without being totally convinced) that Dr Alroe had discharged the onus on him to demonstrate that he was a fit and proper person for unconditional registration given that ‘...The admitted safety risks of unconditional registration are reasonably acceptable and not of such a magnitude that they should not be taken in the circumstances.’

The tribunal ordered that Dr Alroe be registered as a specialist general practitioner without conditions. The issue of costs is yet to be decided.

The tribunal’s decision is available on the AustLII website.

1The Health Practitioner Regulation National Law, as in force in each state and territory (the National Law)

Page reviewed 3/05/2016