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by Anne Crandles
22 April 2016

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Blog: Nurse revalidation

There have been bucket loads of information on revalidation for nurses but managers also need to know what it means for them and the practice. Here, we outline how the surgery can play its part in this new process

The Nursing and Midwifery Council’s (NMC) Code of Conduct1 was updated in March last year. The changes have been widely publicised so your nurses should be aware of these – but what about you? Are you clear about what has changed, what is now required of your nurses and what this means for you as the practice manager and the practice as a whole?

The NMC Code of Conduct 2015
The 2015 Code progresses the good work of previous NMC Codes of Conduct in order to ensure appropriate professional standards of practice and behaviours for all registered nurses and midwives in the UK, totalling almost 700,000 professionals. This latest iteration requires nursing staff to put people first and to practise in ways that are effective and will maintain safety. The intention is to deliver consistently good nursing practice and enhance the public’s trust in midwives and nurses. These themes are underpinned by a set of professional standards, such as a duty to be honest and sincere, to voice concerns, to offer assistance in an emergency (even if this happens outside the practice) and to make suitable use of all communication methods including social media.
Significantly, the Code introduces revalidation,2 a new three yearly registration process for NMC members. It began this April and will oblige nurse professionals to evidence that their practice reflects the Code’s standards.

The process – and what this means for the practice manager
Nurses will have received information from several sources regarding the revised Code, and revalidation in particular, but for your own peace of mind it would be a good idea to check that your nurses are fully conversant with what is expected of them – and when. Although the responsibility for registration will rest with your nurse(s), providing support and help throughout revalidation would be good staff management and also means that you are up to speed with where each of your nurses are in terms of preparation, submission and successful re-registration. The main steps in the process are as follows:

Registering – According to the NMC, revalidation is a straightforward, electronic process. This means nurses must register for an online account, so verifying that staff have done so should be your first task.
Every nurse will be emailed a renewal notice 60 days before his/her registration is due to expire. I am sure that many practice managers will already be in the habit of keeping a note of this date in the nurse’s personnel records but if not, now might be a good time to start. Some nurses will have already received this notification, ie, those nurses and midwives who are due to re-register during April or May 2016. Do you know if this applies to any of your nurses? If so, is he/she busy gathering information for a portfolio?

Requirements – There are seven main or requirements to be carried out:
1. Nurses must complete a minimum of 450 hours of practice over the three-year period since the last registration date. This may seem a lot but in reality equates to 12 working weeks for a full-time nurse. Any nurse falling short of the requisite hours must undertake, and finish, an approved return to practice programme prior to the due registration date. Note that for a dual nurse/midwife role this requirement increases to 900 hours.
2. Thirty-five hours of continuous professional development (CPD) must be undertaken and evidenced. Twenty of these hours must be participatory, ie, in a learning environment with other nurses.
3. Five pieces of practice-related feedback (positive or negative) should be identified, these could be patients’ or carers comments or from items at practice team meetings and minutes.
4. From this feedback the nurse must write up five reflective reports, demonstrating how any learning has subsequently improved practice and meets with NMC standards.
5. These reports should then be discussed with a registered peer (a registrant).
As before:
6. A health and character statement, including any convictions, cautions, must be provided.
7. The nurse must make a declaration that professional indemnity is in place.  
There is an expectation that the work for revalidation will be carried out in the year leading up to registration. This means that any work prepared in the last year under the previous ‘Prep Standards’ will still be acceptable but work dated earlier than this may be queried by the NMC.
The practice manager could assist nursing staff in many ways, eg, providing feedback, possibly granting some preparation time, supplying evidence for revalidation portfolios. Again, this would allow the practice manager an opportunity to monitor and record the nurses’ progress – perhaps using a spreadsheet or Gantt chart 3 for each individual nurse.

Confirmer role – Once the documentation has been completed the nurse must ask a member of the practice team to sign off and confirm that the portfolio meets the NMC’s criteria. While the nurse decides who this confirmer will be, it is highly likely that this will fall to you, the practice manager. It would therefore be sensible to acquaint yourself with what it is you are putting your signature to. The NMC has developed new documentation4 specifically to support this process. It goes without saying that you should keep or copy of each confirmation document.
There should be a face to face discussion prior to confirmation. This is different to the reflective discussion around the five feedback reports that can only be carried out by another NMC member. Whether you are, or are not, the confirmer it would be useful to discuss the Code of Conduct and revalidation at the nurse’s annual appraisal, helping to embed the process into normal practice routines.
Submission – This must be made before the due date – along with the (annual) £120 fee. If your practice has previously paid this fee, could this be the moment to review whether the practice continues to do so? Bear in mind, the nurse is eligible for £24 tax relief on this subscription.
Notification of successful registration will be sent back to the nurse within two working days and these details should also be available online. Be sure to ask for a copy of this for your records too.

Late submission – The nurse must submit, and pay, prior to the due date, or his/her registration will automatically lapse. If this happens, the nurse will have to apply for re-admission. This process can take anywhere between two to six weeks, depending on the nurse’s circumstances and incurs a further fee. Significantly, the nurse cannot practice during this period – with consequences for your services, patients and other nursing staff. Six weeks without a practice nurse, particularly if he/she is your only practice nurse, would be catastrophic for any practice. And even if you can secure a locum nurse for that length of time, who should pay for this?
If this set of circumstances is not already covered in the employment contract, this needs to be addressed. Get some sound legal advice and amend the contract terms as soon as possible. This would have to be discussed openly with staff and the proper procedures followed but would result in an explicit statement regarding the practice’s position on the nurses’ registration and a clear understanding of the consequences of late submission.
If you did have the foresight to add a clause about nurse registration in the contracts it may be possible to take some action. However, before doing so, it would still be wise to seek legal advice regarding what sanctions are permissible and so avoiding falling foul of the Employment Rights Act, 1996.5

Verification – A small, random sample of nurses will be selected for verification checks and asked to supply additional information. This does not mean that there are concerns about the nurse’s safety to practice; the NMC has made it very clear that revalidation is not about assessing fitness to practise. The professional body is merely quality checking its own process
If this happens in your practice, take time to liaise with the nurse, to assess reaction/behaviour and offer proportionate levels of support and reassurance. Be aware that if you were the confirmer for the nurse’s revalidation portfolio then you will also be contacted to double check that you did indeed confirm the documentation.

Support during implementation – Should you, or your nurses, encounter any problems with revalidation, do not panic as there is a plethora of written information and helpful websites, local nursing advisors and unions, eg, Unison and Unite, all able to provide help and support. Above this, programme boards and revalidation groups, with representatives from NMC, NHS and the public, have been set up in each part of the UK to support the implementation of revalidation and to undertake evaluation of the process.  
Benefits for the practice
The Code and its standards are designed to support modern professional nursing practice. Given that practice managers are accountable for the quality and the safe delivery of practice services, the Code should help to reassure you and the GP partners that the procedures carried out, the decisions made and the behaviours displayed by the practice’s nursing team are harm free, effective and appropriate. This will also help to strengthen the patients’ trust and confidence in the practice nursing team.
Longer term, the NMC envisages that revalidation will create a culture of good practice, shared learning, reflection and ongoing improvement that will become an instinctive and natural part of a nurse’s everyday working life. Where better to start this process than in your practice?

Anne Crandles, freelance practice management consultant in Edinburgh.

1. Nursing and Midwifery Council.     The Code for Nurses and Midwives. (accessed 13 February 2016).
2. Nursing and Midwifery Council.  Revalidation. How to revalidate with the NMC (accessed 13 February 2016).
3. What is a Gantt Chart? (accessed 19/1/2016).
4. Nursing and Midwifery Council. Revalidation. Information for Confirmers
(accessed 15 February 2016).
5. ACAS. Pay Deductions (accessed 18 February 2016).