Community Practitioners' and Health Visitors' Association

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Summary of Questions and Your Views

Q1. Do you think that any specific measures are necessary to ensure effective communication and collaboration by the NMC with each part of the UK, or should this be left to the Council to determine?

It is the CPHVA’S view that a physical presence should be maintained in each of the 4 countries to facilitate effective communication and collaboration.

Clear lines of accountability need to be put in place by Government between the Council and local bodies for the monitoring of standards of pre and post- registration and practice.



Q2. What do you think of the proposed initial composition of the Council – 12 practitioners and 11 lay members?

The CPHVA welcomes the increased lay involvement. However due to the amount of work likely to be generated by the NMC more members may be required or it may be useful to consider appointing deputies for each of the members to ensure sufficient coverage at meetings.



Q3. What steps do you think are needed to ensure that the distinctive contribution of each profession is properly acknowledged?

The Council needs to have equal representation of nurses midwives and health visitors on all committees in order to reflect the differences in education, practice and regulation of each profession.



Q4. What is the maximum NMC membership compatible with a strategic and flexible framework and with the overriding aim of public protection?

31 with the possibility of nominating deputies for each of the members.



Q5. Do you think the President should be elected by NMC members or appointed by Government?

Elected by members to ensure credibility amongst the professions and to be free from political influences.



Q6. Do you have any other views on the size and composition of the new NMC?

The composition of equal membership of the 3 professions is welcomed. The actual size required for effective administration of the Council should become apparent after the first year in operation.



Q7. How can the aim of facilitating the new ways of working described in paragraph 20 best be secured?

A partnership approach is necessary amongst the Council, the local country bodies, education, service and the new post- registration training providers. Each registrant group should have a designated person appointed with responsibility for Regulation and Standards to ensure equity of outcome for each of the registrant groups.



 Q8. What is the best way of ensuring that appropriate professional and consumer advice is available to the NMC?

The CPHVA welcomes the proposed advisory panels. These should be drawn from each of the professions regulated. Transparency in appointment procedures is essential and set criteria for membership of panels should be agreed by Council.



Q9. What are your views about membership of the committees dealing with fitness to practise?

Inclusion of more lay members is welcomed. However it is important that membership should be drawn from each profession regulated.

The cultural influences of each country should also be reflected on the committees.

There should be a processional majority of at least one.



 Q10. What other sanctions should be available for unfitness to practise?

A caution may not be seen by the general public as sufficient intervention in a disciplinary procedure. Conditional registration, however, may be viewed as a more positive remedial approach. A lifetime ban may contravene the European Convention of Human Rights.



Q11. What are your views on an independent appeals process?

In principle this would appear to be a reasonable approach to ensuring fair treatment of registrants. Some points need clarification, however. What would the cost implication be for registrants? Who could appeal to this Tribunal? (e.g. A member of the Public, an NHS Trust or just a registrant?) Who would appoint Tribunal members and who would they be accountable to?



Q12. How can the assessment of good health and good character in the interest of public protection best be reconciled with fairness to individual registrants and prospective registrants?

The health requirement for each registrant group should be explicit and framed in terms of fitness for practice. Care needs to be taken to avoid discriminatory practice against those with any form of disability.

‘Good Character’ would appear to be an outdated description of an individual’s fitness to practice. It is open to subjective and cultural interpretations and should be dropped.



Q13. How do you think the arrangements for the quality assurance of professional education and the statutory responsibilities of the new Council can best be integrated?

University departments responsible for the education of registrants should have quality assurance systems in place. Competencies specific to each registrant group should be determined by the specialists themselves in collaboration with other professionals, NHS providers and consumer groups.

The Council must provide a framework making explicit the requirements for entry to the 3 parts of the Register and ensuring that the practitioner, regulator and employer are clear about what their specific responsibilities are.



Q14. How do you think continuing competence to practise can best be determined, monitored and maintained?

Adhering to the PREP requirements should ensure that practitioners maintain adequate competency levels. Employers have a responsibility to provide suitable updating of practice opportunities and clinical supervision for practitioners.

The Council should put in place a meaningful system to monitor practitioner’s portfolios to ensure they maintain their competencies.



Q15. What role should the NMC have in developing standards for the preparation, supervision and performance of staff working with registered professionals?

The Council should have a clear role in setting and monitoring of standards for staff who work alongside and support registered professionals.



 Q16. What are your views about the early appointment of a "Shadow Council"? How should it be constituted and what method of appointment should be used?

Appointments should be transparent and reflect as far as possible the proposed composition of the new Council.

Consultation with staff regarding transfer arrangements, induction and training should commence at an early stage.



Q17. What are your views on the composition and methods of appointment to the first (statutory) Council?

A mix of appointments and elections reflecting the agreed composition of registrant groups would be most appropriate. Consideration should be given to existing staff to facilitate this transition. Some existing Council members should sit on the new Council to ensure continuity. The President should be elected by the Council.



 Q18. What should the functions of the first Council be, and how should they be performed?

A priority of the new Council should be to examine existing structures to determine fitness for purpose. Good communication systems need to be put in place to ensure dissemination of information to each of the countries and among relevant stakeholders. Continuity of public protection should be a high priority.



 Q19. Have you any further comments about any of the issues raised?

The name of the Council should reflect the Health Visiting component. It seems illogical that Health Visitors have separate registration and equal representation on the Council but not have their name on the title. The CPHVA strongly recommend that the new title of the Council be The Nursing, Midwifery and Health Visiting Council.
Professional Officer, CPHVA Northern Ireland