With over 670 000 registrants, the Nursing and Midwifery Council (NMC) is the largest health-care regulator in the UK and there is a need to constantly review and update its processes. I am sure we are all aware of the impending changes to statute relating to the purpose of supervision of midwives. Then there is the newly introduced revalidation processes that aim to ensure nurses and midwives have met their PREP requirements in a meaningful way (NMC, 2011); these are to remain in place until April 2016, when revalidation is scheduled to be in place. Registrants will have a responsibility to reflect on and constantly seek to improve and evaluate their practice.
This is not a new concept to midwives as it is similar to the annual review, which puts in place safeguards for both midwives and women. Engagement with this, however, can be a challenge. Some midwives prepare for their annual review by maintaining a log of training, reflecting on practice and seeking to keep up to date. Others meet only the minimum requirements. Hopefully the revalidation process will ensure some equity, with employers able to address and provide financial support for training—something the supervision of midwifery could not offer. Midwives need to review the NMC (2015) guidance on revalidation to ensure all documentation and reflections are available for whomever their employer nominates to oversee this process.
We have all been informed about the amended renewal process, which was put into place in November, but this does not appear to have grabbed everyone's attention as fully as it should. As always, the NMC will inform registrants that their fee is due, but if this is not paid on time the midwife will need to apply for re-entry to the register. During the re-application period, estimated to be between 2–6 weeks, the midwife will not be allowed to practise as his or her registration would have lapsed.
Dependent on individual circumstances and period of lapse, differing documentation may be required, such as references and evidence of meeting PREP requirements. It is up to the individual to ensure that fees are paid on time and any necessary paperwork, such as the notification of practice form, is completed. Employers also need to have rigorous processes in place to ensure all registrants are on the NMC register and also the relevant part(s) of it. The easiest way to avoid the consequences of failing to renew is by paying by direct debit—something I have recently signed up to.
As an NMC fitness to practise panellist, I am all too aware of the issues related to nurses and midwives who do not meet the required standards of practice, due mainly to lack of competence, misconduct or ill health. A referral to the regulator means a lengthy period of time for investigation and arbitration, during which time practice might be restricted or even suspended. We all make mistakes, but not paying the renewal fee on time is easy to avoid and one less stress in our otherwise busy lives.
This was emphasised during my recent experience of being a panellist for registration appeals. The regulatory registrar can refuse re-entry to the NMC register for a number of reasons, such as convictions, but also because registration has lapsed (usually for a sustained period). If the midwife has continued to work either knowingly or unknowingly without being on the register, his or her integrity, and ability to be capable of safe and effective practice, may be brought into question. Honesty is said, in legal terms, to be difficult to remedy, as it could be an inherent part of the individual's character. This means that it can be difficult, although not impossible, to defend.
To address this, the midwife would need to gather evidence and probably employ a legal representative, lodging an appeal and giving evidence to the panel under oath. This process could take months, during which the midwife would not be able to practise and his or her employer may or may not keep the position open or re-employ the midwife. The appeals require the registrant to provide documents in support of any mitigating circumstances i.e. reasons why the fee was not paid on time. The midwife would then need to illustrate that he or she is of good character and is practising to the required standards. This would require a number of references, testimonials and perhaps witnesses to support the fact that the individual has the integrity required to be a safe midwife.
The appeal might be supported, which means re-entry to the register on payment of the renewal fee. However, getting a job could then be a difficult process as this lapse and investigation would need to be declared. If the appeal is declined, the midwife cannot return to work as a midwife (or a nurse, if on both parts of the register).
This, therefore, is a complex and lengthy process, potentially causing much stress and loss of earnings as a result of simply not paying on time. Don't get caught out—make sure you update your records with the NMC if you have a change of address and ensure you make a note in your diary or electronic devices to remind you when your fee is due. Dealing with your professional registration should not be a perfunctory issue, and dealing with it properly is a reflection of your professionalism.