Mr. James Cosgrave:

I thank Deputy O'Connell for her questions. We have never asked to be self-regulating. We have asked to be within the regulatory remit of this new statutory instrument and the existing one, SI 478/2002. We have been left outside this. We have consistently asked to be included and to be regulated and held accountable. It is very straightforward. If we are included in the regulations our members will be held accountable. Either they are able to perform the tasks as required by statute or they are not, but it does provide a mechanism for the relevant authority, in this case HIQA, to remove anybody who is not able to operate their duties in a responsible fashion. We feel the lack of statutory regulation of chiropractors' use of X-ray is absolutely undesirable. We have been on the record for more than 20 years as seeking to be involved under the statutory remit of the appropriate regulations.

On the question regarding the use of X-ray apparatus by chiropractors, they are acting as referrer and practitioner, much in the same way as dentists and it is quite routine in dental practice. Chiropractors are trained to interpret the films from a diagnostic perspective, but in most cases radiology reports will also be provided from outside sources.

On the insurance front, it is a compulsory requirement for all members of the Chiropractic Association of Ireland to hold malpractice insurance and insurance that will cover any eventuality. Any of our members using X-ray apparatus is covered under the appropriate insurance. There has never been an issue arising with regard to insurance and X-ray use by any of our members. There are 130 chiropractors in the country, 110 of whom are members of our association, which is approximately 85%, and a total of 11 chiropractors in the State are licensed to have X-ray apparatus. This means 99 chiropractors do not have X-ray apparatus and they have been making referrals to private diagnostic clinics throughout the country. These include the Consultants Private Clinic in Cork and there is also a large private provider of X-ray and MRI services in the State. We have access to refer our patients to these facilities.

Regulation 14.4 caters for people who are not specified as referrers, and at this point in time I am not specified under SI 478 as a prescriber, as it allows for the radiologist in charge to act as the referrer and receive the referral in the event of a referral being made by somebody like me, who is not listed under the current regulations. This situation has worked incredibly well for the past 16 years. I have been referring patients to Irish Medical Council consultant radiologists in the State for 25 years. I have been receiving reports back from those radiologists, and it has been a fantastic service and access has been great. We also have the backup and security of a consultant radiologist's report. This has been working very well, hence the number of X-ray licences issued to chiropractors throughout the country has actually decreased from the 18 licences issued a few years ago to 11 now because there has been good private access and many of our members have utilised this.

Things will change after the introduction of the new regulations, if they remain unamended. I will no longer have the ability to refer to a member of the faculty of radiologists here to have an examination done on a patient. Instead, I will have to refer the patient back to his or her GP and, obviously, provide all of the clinical information as to why I feel the X-ray would be justified, and the GP may or may not make the referral. It means every patient will have to take an extra step. It will delay things and slow them down. Some patients will end up in the public system again and will congest things further. The new president of the National Association of General Practitioners recently said patients could soon wait up to six weeks for a GP appointment, which is curious. It seems very much in contrast to some of the Sláintecare recommendations, on which members of the committee worked tirelessly, to slow down access to diagnostic imaging and delay things. Chiropractors have been working with these arrangements for many years and it has worked very efficiently to the patients' benefit. We are not talking about a huge amount of X-rays per year. We have approximately 600,000 visits per year and we certainly refer a very small percentage of patients for X-ray. It is thought that at present chiropractors take 3,000 to 4,000 X-rays per year, which is hugely at variance with the 1.5 million to 2 million X-rays being taken by other providers in the State. We are not talking about a huge number of X-rays but, nonetheless, when an X-ray is required and used it is a very important diagnostic tool to which we must have access. This change will completely remove access to that diagnostic tool for chiropractors.