Tuesday, April 27, 2010

Submission: to NMBA for 'eligible midwife'

This was the WA submission to the NMBA: lets see what comes from this......

Submission from: WA Branch of the Australian College of Midwives (ACM) Executive.
The ACM is supportive of most of the requirements within this document. We have some concerns around the wording in the 2. Practice, continuum of midwifery care… within this document. We have outlined our concerns and points for clarification.

Re: WA Branch Australian College of Midwives’ Response: Endorsement to practice as an Eligible Midwife

1. Registration standard for the endorsement of midwives as eligible midwives.
• Accepted

2. Practice for at least three years across the continuum of midwifery care (antenatal care, intrapartum care and postpartum care of the women and their infants), within the previous 5 years.
• At the entry point of registration in Australia, midwives are licensed to practice across the full scope of midwifery practice and in accordance with the International Definition of the Midwife (2005).
• We are concerned that the 3 year practice requirement is unnecessary, unfounded and excessive it fails to recognise the academic level to which midwives are now being prepared, which will expand further with the implementation of the 18 month program. If post-registration experience must be a criterion, we support a graduate program IF it incorporates at least the same amount of time working in a continuity of care model as working in a hospital.
• There is confusion as to what the three years means; 3 years full time or part time, which is the most common work pattern for many midwives. An arbitrary requirement to book 30-40 women per year is exclusive. Many midwives work part-time and will wish to continue doing so.
• A caseload model of 30-40 women will exclude a number of midwives who could not manage this full time load but might be very keen to offer continuity of care across the continuum for a smaller number of women.
• Is there provision for those midwives who choose to work only with antenatal and postnatal women and refer women to hospitals for birthing, those whose focus is either/both antenatal & postnatal care?
• What exactly is meant by continuum of midwifery care? Does this imply it has to be the caseload model where there is a continuum for a particular woman? Or could it be that a midwife is practicing over the whole spectrum of the midwife’s role but not necessarily on a day to day basis? Does ‘over 3 years’ mean that all spheres of midwifery should be covered in the 3 years and also, is this 3 years of FTE equivalent or 3 years of part time? How part time could it be?
• We are not sure where the evidence for 3 years has come from as we are not aware that this forms any part of the prescribing requirements for midwives in other comparable countries such as UK. We have had a quick look at the NMC site and cannot find any evidence in the regulations that suggests a timeframe. We have also looked at the New Zealand (NZ) model and they are able to work in the community from day 1 of being registered. NZ does have a mentoring program in place for these midwives. (http://www.midwife.org.nz/index.cfm/1,171,html)
• We could accept the completion of one year as a graduate if initial registration is not accepted.

3. Participation in an additional 20 hours per year of continuing professional development relevant to the continuum of midwifery care.
• Additional CPD of 20 hours in addition to the one semester accredited course at PG level also seems excessive. The scope of practice is the scope of practice, midwifery skills are midwifery skills regardless of the work setting and all midwives will need to do 20 hrs CPD, why are eligible midwives going to be different? They will have already completed an extra course and will be required to do MPR.
• We do support the need for a specific course, there needs to be a decision as to whether this would need to be repeated, how is knowledge to be updated for new drugs etc.

4. Successful completion of a NMBA approved professional midwifery practice review program for midwives working across the continuum of midwifery care.
• We accept MPR (Australian College of Midwives)
• MPR should be mandated for all midwives in clinical practice, and if this a requirement, will the fee be subsidised by the government?

5. Compliance with the collaboration requirements for eligible midwives – that is the requirements for midwives to work collaboratively with other health professionals as outlined in regulation and national health policy instruments.
• Collaborative requirements as per Guidance document emphasises that this means equality in professional relationships and not one profession directing another, which needs to be re-iterated in this document
• The definition of collaboration must be re-stated in this and all documents related to this transition, so that the message gets across loudly and clearly that it does not mean midwives may only practice in this model if a doctor or service says they will provide consultation and care if referral is required. (National Guidance on collaborative maternity Care: NHMRC)

6. Successful completion of an accredited and approved program of study determined by the Board to develop midwives’ knowledge and skills in prescribing, or a program that is substantially equivalent to such an approved program of study….
• There is little emphasis on initiation and interpretation of diagnostic tests, which will also be included under Medicare – We think the educational preparation should include this aspect as was recommended in the previous NHMRC Effective options for childbirth document some years ago, which the Enhanced Role Midwife course was based on in WA.
• Will there be a set list of medications (as there is currently for newly qualifying midwives in the UK) or no set list but only drugs that are ‘within the normal scope of midwifery practice’ (as is currently in New Zealand). Whichever is decided upon we think it should include drugs that would be used in an emergency (as listed in the South Australian consultation paper which also includes, for example, Ergometrine, Adrenaline and Magnesium Sulphate).
• Our preference would be that Pharmacology, Prescribing, Screening and Diagnostics unit becomes part of the pre-registration courses so that midwives qualify with these skills, as they do in New Zealand. However, we can see this is very unlikely so a one year post registration is enough of a consolidation to then be able to undertake such a course to be an eligible midwife.
We take this opportunity to thank the NMBA for providing this opportunity to respond and recognise the need for midwives to be experienced across the full scope of midwifery practice. This document reflects the views of the midwives of the profession, and considers the safety of the public in terms of proficiency, wellbeing and knowledge of the ‘eligible midwife’.

WA Branch executive committee
Pp Pauline Costins


  1. Great work Pauline - thankyou for coordinating and submitting the response. The issue for me is one of equity; I believe all midwives in clinical practice should be subject to the same requirements for education, experience and demonstration of competence regardless of where they work; as it stands, the document separates out privately practising midwives into a different class and infers that those working in hospital settings need to be less well prepared. It will be interesting to see where this goes next..!

  2. Thanks for compiling this response. It addresses many relevent issues.

    I wonder if Aussie midwives (with MBS, MPR, PBS etc) will become eligible to practice in the UK, instead of needing extra time as they do currently (12m/18m preparation time)? Although I agree it takes time to become familiar with local systems etc. Just a thought


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