Many of you will remember registering as a nurse or midwife in your state or territory of residence. Then, if you worked in more than one jurisdiction such as across borders, you had to pay two or more registration fees. With great fanfare the National Registration and Accreditation Scheme (NRAS) swept in on 1 July 2010 bringing a single national register for nurses and midwives, one fee, and common regulatory standards.
The ANMF supported a nationally consistent approach to regulation because this meant common professional terminology across the country. The essential areas where commonality has been achieved through national registration and accreditation are: titles and protection of these titles, a national database of registrants, one registration fee, national registration and accreditation standards. Of huge importance to the nursing and midwifery professions was the development of a shared professional practice framework (PPF) to govern the practice of registered and enrolled nurses and midwives. This achievement through NRAS means all nurses and midwives across Australia work under the same framework.
From the introduction of NRAS, the ANMF was aware of difficulties encountered by some members in their registration processing interactions with the Australian Health Practitioner Regulation Agency (AHPRA). However, the registration and accreditation components of the Scheme now seem to be working well for our professions.
A major review of NRAS is now underway and the ANMF has made a submission detailing the achievements of the Scheme as well as highlighting issues we’re concerned about, to the reviewers. See the full submission on the ANMF website: www.anmf.org.au. We’ve welcomed the review of NRAS as this demonstrates accountability to the public of regulatory and accreditation mechanisms established for their protection. We see this as an opportunity to highlight significant achievements in both the regulation of nurses and midwives, and, the accreditation of their education programs leading to registration and endorsement. As the AHPRA Annual Report 2011/12 states: “AHPRA undertook the largest ever renewal in Australia when more than 333,000 nurses and midwives renewed their registration in May 2011” (AHPRA 2012). This indicates the enormity of the exercise taken on by AHPRA in implementing the NRAS.
There were three specific areas of concern we raised in our submission to the review. The first was the need for regulation of assistants in nursing (AINs). AINs undertake aspects of direct nursing and personal care across acute, community and aged care. But, unlike nurses and midwives, they’re not regulated. Given the purpose of regulation is protection of the public, it’s difficult to understand how a significantly large part of the health and aged care workforce remains unregulated. The ANMF argues AINs should be included in the NRAS as they, like registered nurses, midwives and enrolled nurses provide care, and in doing so, also have the potential to pose significant risk to the public.
It’s essential AINs are safe and competent to practice and should be regulated within the current nursing and midwifery regulatory and practice framework. For AINs there is no mandatory minimum educational preparation, no requirement for CPD, no national standards of practice, no codes of conduct or codes of ethical behaviour, no identified scope of practice, no policies on social media usage, no process for mandatory notification of conduct or health impairment issues, and no legal boundaries to the practice of AINs, other than civil law.
The second issue concerns midwifery regulation. The ANMF is aware of some discussion about separating the NMBA into two Boards – one for nurses and one for midwives. The union does not support this proposition. The Federation has more than 19,000 midwife members (total registered midwives 35,062), who are predominantly registered as both nurses and midwives. With the smaller number of registrants in a separate midwifery board this would realistically attract a significantly higher registration fee for midwives to support its operations, than the current NMBA registration fee. Given the vast majority of midwives are dual registered, there would be a requirement for them to pay for both a nursing registration and a midwifery registration. We see no justifiable regulatory gain for a potentially considerable financial impost on our midwife members. Of concern too is that some dual registrants may well discontinue their midwifery or nursing registration if the costs become burdensome, leading to reduced numbers of midwives and nurses available to the Australian community.
The third area of concern with NRAS is the notification process. The ANMF recognise notifications as an essential area of NRAS to assist in protection of the public. We therefore want the system to be timely, fair, and consistent with the National Law. Additionally, we want NRAS to provide consistency for regulation and accreditation, around the country. However, the current notification system is variable across jurisdictions. The New South Wales and Queensland notification processes, and the difference in Western Australia with mandatory notifications, have all contributed to this inconsistency.
The ANMF is concerned the NRAS review is using notifications as the trigger to potentially unravel a system which is in the most part delivering on its requirements. We don’t want a focus on efficiency gains to come at a cost to the aspects of the National Scheme that currently work well.
Australian Health Practitioner Regulation Agency (AH¬PRA). 2012. AHPRA Annual Report 2011/12. Available from the AHPRA website at: www.ahpra.gov.au/Legisla-tion-and-Publications/AHPRA-Publications.aspx
Elizabeth Foley and Julianne Bryce
Federal Professional Officers