Deborah Bellamy, Primary Care Business Manager, outlines what revalidation is, how nurses can prepare for revalidation and how managers can support them, and also summarises the specific differences between existing post-registration education and practice (PREP) requirements and revalidation.
The Report of the Mid Staffordshire NHS Foundation Trust Public Inquiry (2013), chaired by Sir Robert Francis, raised concerns that the PREP requirements were inadequate to assess nurses in a sufficiently rigorous way. This led to a review of the process and, following consultations, pilots, surveys and stakeholder engagement, from April 2016 revalidation will become the way that all nurses and midwives renew their place on the register. With over 650,000 nurses and midwives currently on the register, the time has come to engage with this process.
The main aim of revalidation is to ensure that nurses and midwives continue to practice safely and effectively and are aligned with the requirements of professional registration throughout their careers. Based on the Nursing & Midfery Council’s (NMC) Code for nurses and midwives (March 2015), all practice nurses will need to ensure they are informed and equipped to undertake revalidation, which builds on current PREP requirements.
Although there will undoubtedly be some challenges inherent in implementing revalidation, and some concerns have already been expressed as to the time that completing this will take, the NMC has made clear that revalidation is about promoting good practice across the profession in its entirety, and is a positive move forward.
What is revalidation?
Revalidation underpins a nurse’s individual responsibility to maintain fitness to practise, incorporating standards of the NMC Code into day-to-day practice and personal development. It fosters involvement in wider professional networks and debates and aims to decrease professional isolation and strengthen public confidence. It builds on existing PREP requirements and elements such as recording Continuing Professional Development (CPD) activities and completing the requisite number of practice hours remain. It has been devised to relate to all practice settings, including areas where nurses and midwives practice independently.
The process of revalidation will involve nurses and midwives compiling five pieces of feedback from patients, colleagues and other sources, producing five reflective accounts, having a reflective professional discussion with another NMC registrant and proving to an “appropriate confirmer” and subsequently the NMC that the standards of the Code are being met.
Revalidation will need to be undertaken every three years, and differs from annual registration (also known as annual retention). It should be noted that as of November 2015, nurses and midwives who fail to renew their NMC registration on time are removed from the register immediately as there is no longer a grace period for late payment of fees. Applying to regain registration would need to be made through the readmission process and can take from two to six weeks, during which time individuals would not be eligible to practise.
This table outlines revalidation requirements and indicates whether these are new or existing.
The current system is for all nurses and midwives to pay an annual fee. This renewal of registration is known as annual retention
From November 2015, nurses and midwives who fail to retain their annual NMC registration on time will be removed from the NMC register immediately and will need to apply for re-admission to the register
No grace period for late payment
Complete required minimum of practice hours: 450 practice hours or 900 if revalidating as both a nurse and midwife
Over a three year time frame
Five pieces of practice-related feedback will need to have been obtained from a variety of sources in the three-year period
NMC recommends notes are maintained and comments around how the information was used for a change in practice observed, which will be useful in preparing for reflective accounts
Prepare and record at least five written reflections and record on the approved NMC form; these can refer to CPD and/or an element of practice related feedback received and/or an event or experience in individual professional practice and how it correlates to the NMC Code
The written reflections must be documented on the reflective accounts form and is a mandatory requirement — there is a reflective accounts form and a separate reflective discussions form which can be downloaded from the NMC website
Have a reflective face-to-face discussion with another NMC registrant
The registered nurse or midwife must sign the specific NMC form, summarise the discussion, and record details
Record details of continuing professional development, which must incorporate 35 hours of CPD, including 20 hours participatory learning or “hands on” hours
Existing PREP standards involve individuals maintaining a personal, professional profile of learning activities and comply with requests to audit how they met this
A CPD log template is recommended and available from the NMC to download
Under revalidation requirements mandatory and statutory training (such as fire) unless specifically related can no longer be used as part of these hours unless specifically relevant to practice
Although the CPD overall hours remain the same (35 hours) 20 must specifically be participatory and mandatory training cannot necessarily be included as it may have been as a PREP requirement
Declaration of health and character
Professional indemnity arrangements
Confirmation by an “appropriate confirmer”
All nurses and midwives will have to prove that they have fulfilled revalidation requirements to an appropriate confirmer
Process for NMC-registered professionals
Applications for revalidation must be completed through the NMC online portal. Individuals will need to open an NMC online account, which may be accessed through the website. This site can be used to check their re-registration date which will subsequently become their revalidation date. The NMC will inform nurses and midwives 60 days in advance of this date. As such, individuals should inform the NMC of any contact amendments.
Requirements of revalidation
Nurses and midwives must maintain accurate records of CPD activity. When logging information, nurses should be mindful of the CPD structure. For each event logged, an account of the subject and how it correlates to practice, the dates on which the activity was undertaken and the number of hours (including the number of participatory hours) undertaken should be recorded and linked to the most pertinent section of the NMC Code, along with evidence that the activity was undertaken.
Mandatory training not directly related to practice, such as fire training or health and safety, may no longer be included as part of the 35 hours of CPD. Conversely, if mandatory training supports and enables practice development it may count towards the required CPD hours. An example of this could include attending mandatory training on safeguarding when working with vulnerable groups.
Five pieces of practice-related feedback will need to have been obtained in a three-year period. This information may be gathered from a range of sources, including patients, service users, students and colleagues. It could be specific feedback about an individual, or about the wider primary care team or organisation through complaints, team performance reports and serious event reviews. This can be formal or informal and can be in either written or verbal formats. In order to keep a record of this activity the NMC recommends notes be kept and comments around how the information was used to bring about a change in practice which will in turn be valuable when preparing reflective accounts.
Another new requirement is that nurses record at least five written reflective accounts over the three-year period and document these on the approved NMC form. This must relate to CPD or an event or experience in professional practice, including practice-related feedback and how this relates to the Code. An example of a reflective account could be for the nurse or midwife to produce narrative on a specific topic arising from feedback, such as consent and confidentiality, and identify how that relates to the Code. Within this account the nurse of midwife should outline the learning points identified, the CPD activity involved, feedback garnered and how practice changed or improved as a result.
To fulfil requirements, these reflective accounts will need to be discussed with another NMC registrant. The NMC expects the reflective discussion to be face to face and that the registered nurse or midwife records a summary of the discussion and signs the form, which should include his or her details.
Reflective feedback is not new to nurses and individual reflection enables skills around this practice to be developed. The NMC is keen that reflective practice is used to identify opportunities for change and improvements.
The NMC will require individuals to make a declaration that they have complied with revalidation requirements and recommends this confirmation is obtained in the final 12 months of registration. Verification that revalidation requirements have been met will need to be sought from what is known as an “appropriate confirmer”.
Nurses and midwives are advised to use their counsel as to who should provide this confirmation. The NMC advocates the line manager should be considered wherever possible and he or she does not necessarily have to be an NMC-registered nurse or midwife. In circumstances where there is more than one employer or the nurse or midwife carries out more than one role, individuals will need to obtain confirmation which covers all of their practice, identifying the most appropriate person to provide this. Other health professionals regulated in the UK, such as a doctor, dentist or pharmacist, will also be able to provide this confirmation.
However, if using a non NMC-registered nurse or midwife as a confirmer, the reflective discussion element will need to have been undertaken with another NMC-registered nurse or midwife before seeking confirmation.
As with PREP requirements, appropriate cover under an indemnity arrangement must be in place for revalidation, and evidence of this should be kept. A health and character declaration will also need to be provided which include declarations of convictions or criminal offence or formal cautions issued. Nurses and midwives must be able to affirm they are in a state of health that enables safe and effective practice without supervision, after any reasonable adjustments are made by their employer.
How to prepare
All nurses and midwives will have received a copy of the NMC Code and should ensure they are familiar with this. They could start to gather feedback from client groups or colleagues to contribute to practice-related feedback and trigger reflection and contemplation, identifying learning points and modification of practice as a result.
Current PREP portfolios should be used as a baseline for evidence as all nurses and midwives ought to have a personal and professional profile. This may include certificates of attendance of training, other learning activities, plaudits or complaint letters and evidence of supervision, either clinical or non-clinical.
Practice meetings or educational half days could also form a basis for practice related feedback or reflective discussion. It should be remembered that how individual nurses and midwives meet the new requirements will differ, based on their scope of practice.
Providing support as a manager
Understandably, revalidation will create concerns for some individuals, but knowledge of the new requirements and structure will enable managers to offer targeted support. While nurses and midwives are ultimately responsible for maintaining professional registration, by raising awareness and managing expectations managers can help to prepare nursing staff for the process.
By clarifying which nurses and midwives are due to revalidate in 2016, managers can prioritise them for support. Managers can also aid staff by ensuring that appraisals and one-to-one reviews are up to date and checking for identified but so far unmet learning needs and how these may be fulfilled. This could involve pointing nurses towards a wide range of learning opportunities, both formal (such as taught courses) and informal (such as reading about issues relevant to practice, or engaging in a pertinent social media discussion, participating in research and reflection, shadowing a colleague or working in a specialist clinic aligned with professional areas of interest).
Revalidation aims to increase employers’ and managers’ awareness of NMC regulatory standards and promote debate around any practice concerns before they escalate. It may increase access to and participation in appraisals and wider CPD opportunities and it is suggested that, where feasible, confirmation discussion should form part of the nurse or midwife’s annual appraisal.
The NMC is clear that there is no obligation for managers to provide specific support to the nurses and midwives employed within the practice. Conversely, as an employer of regulated professionals, good practice requires nurses and midwives to be supported to deliver safe and effective care.
Resources, forms and templates
Both the NMC and RCN have produced checklists and downloadable templates for completion.
Nurses and midwives are recommended to maintain their professional portfolio, as they did with PREP, and revalidation evidence can also be kept here. There are no specific requirements to store documents electronically or upload this into NMC Online for revalidation applications. If a nurse or midwife is selected to provide further information to verify evidence, reflective discussion and confirmation forms will need to have been completed in manual, paper form, as opposed to electronically. This is important as creating, storing or sharing this information by electronic means may generate an obligation to register with the Information Commissioner because identifying information about another NMC-registered nurse or midwife confirmer could be included.
There are five separate templates and forms that nurses and midwives should use to record how they have met revalidation requirements. Some of these are mandatory while others are recommended as good practice, as outlined below. Nurses must ensure these are competed in hard copy/paper formats as per NMC directions.
The five forms, which can all be accessed from the NMC website, are as follows.
Practice hours log template (recommended). This enables nurses and midwives to record their 450 hours of practice (900 hours if registered as both a nurse and midwife).
Continuing professional development log template (recommended). This is for recording details of 35 hours of CPD (including 20 participatory or “hands on” hours).
Reflective accounts form (mandatory). This is an essential component needed to record five written accounts of CPD and/or their practice-related feedback and/or an event or experience in practice and how this correlates to the Code.
Reflective discussion form (mandatory). Must be used to record reflective discussion with another NMC registered nurse or midwife.
Confirmation forms (mandatory). Must be completed and stored as manual paper form, as opposed to electronically in order to avoid an obligation to register with the Information Commissioner.
There are many resources available to help individuals and managers prepare for revalidation. E-portfolio tools are being developed and should soon be available. The NMC has developed guidance and training materials to support employers and staff including an Employers guide to revalidation.
Last reviewed 12 January 2016