The long awaited safety and quality framework is finally circulated for us to see and I do love this statement:

This framework is not a legal requirement for a PPM who is exempt, until it is approved in a code or guideline by the NMBA under s39 of the National Law.

This paragraph is totally bizarre,  after all the money spent after all the hours put in, we are being given an amnesty until the NMBA can get their act together as the government don’t want to police the frame work.

284 Exemption from requirement for professional indemnity insurance arrangements for midwives practising private

midwifery

1. (1) During the transition period, a midwife does not contravene section 129(1) merely because the midwife practises private midwifery if—
2. (a) the practise occurs in a participating jurisdiction in which, immediately before the participation day for that jurisdiction, a person was not prohibited from attending homebirths in the course of practising midwifery unless professional indemnity insurance arrangements were in place; and
3. (b) informed consent has been given by the woman in relation to whom the midwife is practising private midwifery; and
4. (c) the midwife complies with any requirements set out in a code or guideline approved by the National Board under section 39 about the practise of private midwifery, including—
5. (i) any requirement in a code or guideline about reports to be provided by midwives practising private midwifery; and
6. (ii) any requirement in a code or guideline relating to the safety and quality of the practise of private midwifery.
7. (2) A midwife who practises private midwifery under this section is not required to include in an annual statement under section 109 a declaration required by subsection (1)(a)(iv) and (v) of that section in relation to the midwife’s practise of private midwifery during a period of registration that is within the transition period.
8. (3) For the purposes of this section, the transition period—
9. (a) starts on 1 July 2010; and
10. (b) ends on the prescribed day.

I am not really surprised and have already said in public that I thought an amnesty until this is sorted would be best.  Looks like we have it.

So once every one sorts themselves out what are the potential problems with the framework?

Women considered appropriate for inclusion in this option of care are women with a singleton pregnancy, cephalic presentation, at term and free from any significant pre existing medical or pregnancy complications. Further to this, distance and time to travel to an appropriately staffed maternity service should be considered when assessing appropriateness for this option of care.

This is a major problem, it’s one thing to preach the ACM guidelines it’s totally another to have a framework that we have to follow with this kind of prescriptive legislation.

Further to this, distance and time to travel to an appropriately staffed maternity service should be considered when assessing appropriateness for this option of care.

For the women living in more than 20 minutes from their hospital this could be an issue.  Appropriate maternity services?  If planning a homebirth appropriate services would be a tertiary hospital as a country hospital would have to transfer any complication.  does this mean that anyone outside CPD won’t qualify for a homebirth?

With these issues in mind, the ACM Consultation and Referral Guidelines and the principles and practices outlined in the draft NHMRC National Guidance on Collaborative Maternity Care are a key element of this Safety and Quality Framework.

They may be key elements but to the framework but the ACM guidelines are just GUIDELINES and women don’t have to follow them.

Should the NMBA decide to use this framework in a code or guideline, they will hold responsibility for regulating compliance with it.

So the NMBA haven’t decided to use the framework yet?  This seems to go from bizarre to unbelievable.

Minimum Quality and Safety Requirements for Interim Exemption from Insurance

In addition to holding current registration in their State or Territory, or with the Nursing and Midwifery Board of Australia after 1 July 2010, to comply with the exemption from the insurance requirement of the National Registration and Accreditation Scheme midwives need to be able to provide evidence outlined in  below:

• Principle Requirement Evidence
• Consumer Value Consumer friendly consent template Templates
• Written information detailing evidence informed materials Consumer information package
• Process for complaint management Documented process, including complaint escalation information
• Consumer participation Women involved in case and peer review
• Consumer satisfaction Templates

• Clinical performance & evaluation Clinical standards Documented evidence informed clinical practice guidelines on which practice is based e.g NHMRC, NICE, or state & territory guidelines
  Referral pathways Clearly articulated referral pathways for referral and /or consultation in accordance with ACM Consultation and Referral Guidelines

• Comprehensive clinical notes to share with other health professionals engaged in the woman’s care
  Clinical indicators/KPI Reporting of all births as per each state & territory requirement
  Clinical audit Comprehensive clinical notes to guide reflective practice and enable review and evaluation of care provided
  Clinical Risk Incident & adverse event reporting Documented process in accordance with state and territory requirements
  Sentinel event reporting Documented process in accordance with state and territory requirements

• Documented involvement in case investigation.
  Risk profile analysis Documented process for identification and evaluation of clinical risk and evidence of correcting, eliminating or reducing these risks
  Professional Development Maintenance of professional standards Complies with NMBA minimum standards
  Awareness and monitoring of new procedures and practices Involvement in professional organisation/s and documented schedule for formal practice review and mentoring processes
  Competency standards- ensures appropriate skills and experience Demonstrates practice in accordance with ANMC national competency standards for the Midwife
  Continuing professional development Documented evidence of attendance at ongoing and regular education and research activities determined by the NMBA standard relating to CPD

Maintenance of professional portfolio

We are obviously going to be inundated with paper work in triplicate. The expectation that we will share out notes it the one thing I find totally outrageous. Women cant even access their own results. All the information is only retrievable through freedom of information. if I rang a GP and asked for access to my clients notes can you imagine the response.

So ultimate conclusion, this is a waste of money and we will have to see if it ever gets looked at in any way.

We are left with the insurance situation.  If we can access insurance other than through the commonwealth continuing to practice is fine at the moment as nothing changes.  Once the MNBA have sorted out their shit it will be reviewed if we can meet the necessary requirements.

I’m keeping my eye out for the suggested insurance from the ACM and ANF.

I would like to than my lovely friend Sarah for her clear and concise thinking

Related posts:

1. Quality & Safety Framework and Eligibity
2. Draft guide to eligibility
3. Exemption!
4. Homebirth Debate
5. Make a difference? Join the protest