Nurses and other professions: ward management confirmed
The activities of the Complex Unit do not require medical expertise in management or organisation
Positions within complex healthcare units are not reserved solely for senior medical staff, but may also be awarded to senior staff in other healthcare professions (nursing, technical, rehabilitation, prevention and midwifery), subject only to the specialisation required for the post. Failure to do so would constitute a breach of Article 15 of Legislative Decree No. 502 of 1992 (Reorganisation of healthcare regulations), which governs medical management and the management of healthcare professions in a ‘unified’ manner.
The judgement
In this regard, the Lombardy Regional Administrative Court- Brescia (judgement no. 1174 of 2026) dismissed the appeal brought by the National Federation of Orders of Surgeons and Dentists and the provincial orders of Lombardy doctors against the resolution by which the Health Protection Agency– ATS had launched a selection procedure for the appointment of a head of the Complex Structure for ‘Hygiene and Public Health, Environmental Health’. This procedure was open to “medical managers specialising in Hygiene, Epidemiology and Public Health, and managers from the healthcare professions”.
The appellants’ grounds
The appellants had argued that:
- healthcare professionals in management roles would be “lacking the technical and scientific skills required to carry out their duties properly”;
- Article 4 of Presidential Decree No. 484 of 1997 (Regulations laying down the requirements for access to the second management level for healthcare staff) does not mention those practising the healthcare professions;

