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Revalidation – the confirmer’s challenge Third-party confirmation is a new requirement under the upcoming system of revalidation, but how will it work in practice? Alistair Kleebauer reports Under the Nursing and Midwifery Council’s new system of revalidation, nurses and midwives will have to declare that they remain fit to practise every three years. But it will not be enough for a registrant to simply claim they measure up to the values and principles of the NMC’s revised code of conduct. To renew their registration, this declaration will have to be
supported, or rather confirmed, by a third party. The current system of ensuring nurses keep their practice, knowledge and skills up to date, known as post-registration education and practice (PREP), does not require third-party confirmation. The new system is being introduced because the NMC wants to provide a greater level of assurance to the public that the professionals
who care for them are fit to practise. There will be some situations when confirmation will need to be sought from two people. This is because the NMC has set requirements for confirmation: the confirmer has to oversee the registrant’s practice – so will most likely be their line manager – and be registered with the NMC. If the person who oversees the registrant’s practice is not a nurse or midwife, then confirmation will also have to be obtained from someone who is on the register and is familiar with their practice. The regulator is evaluating feedback from its consultations on this aspect of revalidation. It will publish the new code
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and draft revalidation guidance in December, before piloting revalidation at ‘early implementer’ sites next year. RCN head of policy Howard Catton says that introducing third-party confirmation with an improved auditing system ‘will give assurance to the public that nurses are up to date’. However, in its response to the NMC consultation based on feedback from its members, the RCN raised a number of concerns about third-party confirmation.
Self-declaration
These included the difficulty for nurses working in more ‘unusual’ teams of finding a fellow registrant to be a confirmer, and the use of employer appraisals to inform the confirmation. The college also said a system that can require two people to provide confirmation could become ‘unwieldy and complex’. ‘The two people involved may take a different view of whether someone can be confirmed or not,’ says Mr Catton. ‘What happens if they can’t agree? Do we need to bring in a third person? It needs to be worked out.’ When declaring their own fitness to practise, a registrant will be informing the regulator that they are upholding the standards within the NMC code, which covers areas such as the fundamentals of basic care, duty of candour, medicines management and raising concerns. The confirmer or confirmers will be stating that, to the best of their knowledge, the nurse’s declaration is reliable and they are not aware of any serious concerns that would call the registrant’s fitness to practise into question (see box). But will line managers who are not themselves registered nurses or midwives understand what is being asked of them? Care UK head of behavioural support Simon Jones, a learning disability nurse, says registrants know about the Code, but many line managers ‘don’t even know it exists’.
SUMMARY
Practice nurses, whose line managers are often GPs and practice managers, may need to seek ‘dual confirmation’
When the new system of revalidation is introduced at the end of 2015, nurses and midwives will have to declare to the Nursing and Midwifery Council every three years that they are fit to practise. This declaration must be confirmed by a third party, who will also have to be on the NMC register. Obtaining confirmation could be challenging for nurses and midwives who are not supervised by a registrant.
‘The registrant would have to make them aware by saying: “This is the Code – are we meeting it?” It is putting the onus on us.’ A further challenge is finding the right person or people to do the confirmation. Learning disability nurses such as Mr Jones often work in multidisciplinary teams in social care settings. Mr Jones says he was ‘slightly concerned’ when he first heard about the confirmation requirements as his line manager is not a nurse and neither are his immediate colleagues. He has identified a learning disability nurse and registrant within Care UK who could fulfil the confirmation role, but he still has reservations. ‘We would like to think of ourselves as being professional but it is a very oblique relationship. She works in the same organisation, but she is not my line manager.’ Surrey and Borders Partnership NHS Foundation Trust nurse consultant Phil Boulter asked peers at a recent learning disability network meeting in Edinburgh how they will go about finding a confirmer. Summing up their responses, he says: ‘If there is an NMC registrant, all the better – but it was felt the NMC should consider allowing registrants with other professional bodies, such as psychiatrists, to fulfil the role.’ Jan Gower, the lead practice nurse at the Moat House Surgery in Warboys, Cambridgeshire, is ‘more than happy’ the four nurses in her team are fit to practise and could act as their confirmer. But she admits: ‘I rarely work with them because we are in a room on our own with our patients’. Ms Gower also faces the difficulty of finding someone to
confirm her own fitness to practise as she reports to a GP and a practice manager who is an accountant by background. Dual confirmation – asking one of her nurse colleagues and also the GP or the practice manager – might be ‘easier’, she says. A spokesperson for the NMC says it is ‘working to ensure that the model of revalidation is flexible enough to apply to everyone on the register and that everyone has access to a suitable third-party confirmer’. Pilot organisations will be selected across several settings, including those where responses to the NMC consultation suggested confirmation might not be straightforward, including small primary care settings and nursing agencies, before revalidation begins next year NS This is the fifth article in our six-part series on revalidation. Next week we look at re-registering with the NMC For more on revalidation, go to www.revalidation.zone
The confirmer’s responsibilities Confirmers could be held liable for a registrant’s past or future actions if they were aware of potential problems with the registrant’s practice at the point of confirmation. But they will not be held liable if the confirmation is made in good faith. The NMC has consulted on this aspect of third-party confirmation and it is now analysing the findings to develop detailed guidance in this area. The regulator says significant problems with a registrant’s fitness to practise should have been addressed before the point of revalidation. ‘However, as per current requirements, if any serious concerns arise during the course of the three-year renewal cycle that pose a threat to public protection, anyone is able to raise these concerns with us and they should do so, rather than wait until the point of revalidation,’ says an NMC spokesperson. She adds: ‘If the NMC were to become aware of any dishonesty or collusion in relation to the evidence supporting the declaration, action could be taken under existing fitness to practise processes. We will use a combination of risk-based and rolling selection processes to audit a sample of revalidation submissions.’
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Revalidation – the confirmer’s challenge Third-party confirmation is a new requirement under the upcoming system of revalidation, but how will it work in practice? Alistair Kleebauer reports Under the Nursing and Midwifery Council’s new system of revalidation, nurses and midwives will have to declare that they remain fit to practise every three years. But it will not be enough for a registrant to simply claim they measure up to the values and principles of the NMC’s revised code of conduct. To renew their registration, this declaration will have to be
supported, or rather confirmed, by a third party. The current system of ensuring nurses keep their practice, knowledge and skills up to date, known as post-registration education and practice (PREP), does not require third-party confirmation. The new system is being introduced because the NMC wants to provide a greater level of assurance to the public that the professionals
who care for them are fit to practise. There will be some situations when confirmation will need to be sought from two people. This is because the NMC has set requirements for confirmation: the confirmer has to oversee the registrant’s practice – so will most likely be their line manager – and be registered with the NMC. If the person who oversees the registrant’s practice is not a nurse or midwife, then confirmation will also have to be obtained from someone who is on the register and is familiar with their practice. The regulator is evaluating feedback from its consultations on this aspect of revalidation. It will publish the new code
24 october 22 ::from vol 29 no 8 :: by 2014 STANDARD Downloaded RCNi.com ${individualUser.displayName} on Nov 05, 2015. For personal use only. NoNURSING other uses without permission. Copyright © 2015 RCNi Ltd. All rights reserved.
and draft revalidation guidance in December, before piloting revalidation at ‘early implementer’ sites next year. RCN head of policy Howard Catton says that introducing third-party confirmation with an improved auditing system ‘will give assurance to the public that nurses are up to date’. However, in its response to the NMC consultation based on feedback from its members, the RCN raised a number of concerns about third-party confirmation.
Self-declaration
These included the difficulty for nurses working in more ‘unusual’ teams of finding a fellow registrant to be a confirmer, and the use of employer appraisals to inform the confirmation. The college also said a system that can require two people to provide confirmation could become ‘unwieldy and complex’. ‘The two people involved may take a different view of whether someone can be confirmed or not,’ says Mr Catton. ‘What happens if they can’t agree? Do we need to bring in a third person? It needs to be worked out.’ When declaring their own fitness to practise, a registrant will be informing the regulator that they are upholding the standards within the NMC code, which covers areas such as the fundamentals of basic care, duty of candour, medicines management and raising concerns. The confirmer or confirmers will be stating that, to the best of their knowledge, the nurse’s declaration is reliable and they are not aware of any serious concerns that would call the registrant’s fitness to practise into question (see box). But will line managers who are not themselves registered nurses or midwives understand what is being asked of them? Care UK head of behavioural support Simon Jones, a learning disability nurse, says registrants know about the Code, but many line managers ‘don’t even know it exists’.
SUMMARY
Practice nurses, whose line managers are often GPs and practice managers, may need to seek ‘dual confirmation’
When the new system of revalidation is introduced at the end of 2015, nurses and midwives will have to declare to the Nursing and Midwifery Council every three years that they are fit to practise. This declaration must be confirmed by a third party, who will also have to be on the NMC register. Obtaining confirmation could be challenging for nurses and midwives who are not supervised by a registrant.
‘The registrant would have to make them aware by saying: “This is the Code – are we meeting it?” It is putting the onus on us.’ A further challenge is finding the right person or people to do the confirmation. Learning disability nurses such as Mr Jones often work in multidisciplinary teams in social care settings. Mr Jones says he was ‘slightly concerned’ when he first heard about the confirmation requirements as his line manager is not a nurse and neither are his immediate colleagues. He has identified a learning disability nurse and registrant within Care UK who could fulfil the confirmation role, but he still has reservations. ‘We would like to think of ourselves as being professional but it is a very oblique relationship. She works in the same organisation, but she is not my line manager.’ Surrey and Borders Partnership NHS Foundation Trust nurse consultant Phil Boulter asked peers at a recent learning disability network meeting in Edinburgh how they will go about finding a confirmer. Summing up their responses, he says: ‘If there is an NMC registrant, all the better – but it was felt the NMC should consider allowing registrants with other professional bodies, such as psychiatrists, to fulfil the role.’ Jan Gower, the lead practice nurse at the Moat House Surgery in Warboys, Cambridgeshire, is ‘more than happy’ the four nurses in her team are fit to practise and could act as their confirmer. But she admits: ‘I rarely work with them because we are in a room on our own with our patients’. Ms Gower also faces the difficulty of finding someone to
confirm her own fitness to practise as she reports to a GP and a practice manager who is an accountant by background. Dual confirmation – asking one of her nurse colleagues and also the GP or the practice manager – might be ‘easier’, she says. A spokesperson for the NMC says it is ‘working to ensure that the model of revalidation is flexible enough to apply to everyone on the register and that everyone has access to a suitable third-party confirmer’. Pilot organisations will be selected across several settings, including those where responses to the NMC consultation suggested confirmation might not be straightforward, including small primary care settings and nursing agencies, before revalidation begins next year NS This is the fifth article in our six-part series on revalidation. Next week we look at re-registering with the NMC For more on revalidation, go to www.revalidation.zone
The confirmer’s responsibilities Confirmers could be held liable for a registrant’s past or future actions if they were aware of potential problems with the registrant’s practice at the point of confirmation. But they will not be held liable if the confirmation is made in good faith. The NMC has consulted on this aspect of third-party confirmation and it is now analysing the findings to develop detailed guidance in this area. The regulator says significant problems with a registrant’s fitness to practise should have been addressed before the point of revalidation. ‘However, as per current requirements, if any serious concerns arise during the course of the three-year renewal cycle that pose a threat to public protection, anyone is able to raise these concerns with us and they should do so, rather than wait until the point of revalidation,’ says an NMC spokesperson. She adds: ‘If the NMC were to become aware of any dishonesty or collusion in relation to the evidence supporting the declaration, action could be taken under existing fitness to practise processes. We will use a combination of risk-based and rolling selection processes to audit a sample of revalidation submissions.’
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