Public administration: the short-circuit of compulsory training in healthcare

There is a constant and irrational disconnect between the indistinct concept of public administration and healthcare, which is clearly present in the PA decree under conversion. A further example is Minister Zangrillo's Directive of 14 January 2025, which allegedly introduces the obligation of at least 40 hours of training per year for all public employees. A number of perplexities have arisen in the healthcare companies with regard to the contents of the Directive, starting with a preliminary point, i.e. whether the document is addressed 'also' to the companies and bodies of the SSN.

The Directive in question concerns training, but the aspects dealt with extensively in the document were in fact already present in the National Collective Labour Agreement of 2.11.2022, where arts. 64-67 regulate the salient features of training: the general principles, the new competences, the staff training plans, the innovative methodologies, the distinction between compulsory and optional training, and the financial burdens committed. The real difference is that the Directive quantifies the training commitment, raising it to 40 hours from the 24 hours of the previous Directive of 2023, and placing it at the expense of the manager within the scope of his individual performance objectives to which the attribution of the result remuneration is correlated.

I am not at all convinced that it concerns healthcare companies, at least not directly. It is true that the addressees are all the 'public administrations referred to in Article 1, paragraph 2, of Legislative Decree 165/2001', but this is a ritual formulation of a more formal than substantial nature. In support of what has been said, it cannot but be noted that among the addressees for information there are neither the Conference of the Regions nor the individual Regions, unlike all the other exponential entities of the central and local public administrations, including the universities. Equally incontrovertible is the fact that in twenty pages the directive never mentions, not even in passing, healthcare, and when reference is made to the NRP, Mission 6, which commits EUR 19 billion, is completely ignored.

But perhaps the key argument for believing that the directive does not in fact concern healthcare can be found in the text of the Ddl 'Guarantee measures for the provision of healthcare services and other provisions on healthcare', presented in Parliament as Senate Act 1241 on 23 September 2024. Article 12 of the law establishes the National School for High Health Administration at the Ministry of Health as of the year 2025. Now, the bill is signed by Schillaci, Giorgetti, Calderoli and Zangrillo, which is why it should be assumed that the Minister of Public Administration, when drafting the directive, had a clear understanding of the health situation.

Returning to the content of the Directive and the substantial extraneousness of public health, in the text there are dozens of direct references to the Central Functions, from the collective agreements to even mentioning on page 8 High Professionalism instead of High Qualification, as, moreover, provided for by law. The contents of the Directive are mere indications (".... the Directive aims to guide the administrations ....") without legal binding force and mandatory application, at least until they are transposed into a regulatory measure and, above all, into the respective CCNLs. In this last regard, in the CCNL of the Central Functions of 27.1.2025 the issue of 40 hours of training is completely absent. The directive itself acknowledges this when it states on page 4: ".... although not made mandatory by specific rules". Finally, with regard to the fulfilments that the health agencies must put in place, it is obvious that the strategic and operational choices are free and the entire content of the directive can be reported in the PIAO (Integrated Plan of Activities and Organisation) - as, moreover, the minister himself seems to suggest in the penultimate paragraph of page 17 - it being understood that, in my opinion, everything must be contextualised within the framework of the collective agreements in force, taking into account, in particular, the emerging costs and the supposed legal binding nature of the 40 hours of training.