Provisions on nutrition specialists are notable contents mentioned at the Circular No. 18/2020/TT-BYT, effective from January 01, 2021. So, can a traditional medicine doctor do the job of nutrition specialists?
Article table of contents
Regarding this issue, LAWNET would like to answer as follows:
Pursuant to Article 7 of the Circular No. 18/2020/TT-BYT of the Ministry of Health of Vietnam:
Article 7. Nutrition specialists
1. Head of the nutrition department must be a full-time tenured employee and meet the following requirements:
a) Is a general medicine doctor or general practitioner holding a certificate of at least 6 months of training in clinical nutrition.
b) Is a nutritionist holding a bachelor’s degree or higher if no one is qualified for the requirements mentioned in Point a herein.
2. Persons in charge of nutrition therapy must be a general medicine doctor or general practitioner holding a clinical nutrition training certificate or nutritionist.
According to this regulation, nutrition specialists include general medicine doctor or general practitioner holding a certificate of training in clinical nutrition or nutritionist. So, is a traditional medicine doctor considered as a general medicine doctor?
Currently, there is no legal provision that defines the term "general medicine doctor". However, according to Article 5 of the Circular No. 42/2018/TT-BYT of the Ministry of Health of Vietnam, Medicine and Traditional Medicine are two separate branches. Thus, we can understand that the definition of "general medicine doctor" does not include "traditional medicine doctor", so the fact that a traditional medicine doctor has a training certificate in clinical nutrition is also not subject to working as a nutritionist in the hospital.
Besides, according to Section 2 of the Official Dispatch No. 4018/BYT-YDCT of the Ministry of Health of Vietnam:
2. Traditional medicine doctors who have obtained a practice certificate with the scope of expertise to examine and treat diseases using traditional medicine may perform techniques other than traditional medicine after obtaining the certificate of technical training issued by a lawful training institution and permitted in writing by the person in charge of professional and technical expertise of the medical examination and treatment establishment, without supplementing the scope of professional activities stated on the practice certificate as prescribed in Article 11 of the Decree No. 155/2018/NĐ-CP.
Thus, in order to perform specialized techniques in nutrition, traditional medicine doctors who have a certificate of training in clinical nutrition still need to be authorized in writing by the person responsible for technical expertise in nutrition at the hospital.
Note: Circular No. 18/2020/TT-BYT takes effect from January 01, 2021 and there are no any detailed instructions, so some regulations are unclear which can be understood in many different ways. To ensure compliance with regulations, the above subjects can make consultation documents to receive specific instructions from the Ministry of Health of Vietnam.
Hoa Hong
- Key word:
- Circular No. 18/2020/TT-BYT
