Policy paper

Proposals for changing the system of midwifery supervision in the UK

Published 22 January 2016

A framing document from the UK Chief Nursing Officers (CNOs), their professional midwifery officers, the Nursing and Midwifery Council, the Royal College of Midwives and a representative of the Local Supervising Authority Midwifery Officers.

Introduction

Statutory supervision of midwives has been criticised, closely examined and found to be flawed. As a consequence of her investigations into complaints about maternity services at Morecambe Bay NHS Foundation Trust Dame Julie Mellor, the Parliamentary and Health Services Ombudsman, published, having discussed it with her UK counterparts, ‘Midwifery supervision and regulation: recommendations for change’ (PHSO, 2013).

The Ombudsman identified 2 important principles to form the basis of proposals to change the system of midwifery regulation:

• midwifery supervision and regulation should be separated
• the Nursing and Midwifery Council (NMC) should be in direct control of regulatory activity

As a result of this, the NMC commissioned the King’s Fund to review statutory supervision in the UK and they published their findings (The King’s Fund, 2015) for consideration by the Council in January 2015. The review found that statutory midwifery supervision had an unclear relationship with the regulatory function of the NMC and with the proper role of the employer or service provider in effecting systems of sound clinical governance. Its removal will mean employers and providers of midwifery services will have to ensure they have processes to measure and improve quality, offer choice and support women through pregnancy, birth and the postnatal period. The King’s Fund review recommended that:

The NMC as the health care professional regulator should have direct responsibility and accountability solely for the core functions of regulation. The legislation pertaining to the NMC should be revised to reflect this. This means the additional layer of regulation currently in place for midwives and extended role for the NMC over statutory supervision should end.

Concerns about statutory supervision of midwives also emerged from the Morecambe Bay Investigation, March 2015, chaired by Dr Bill Kirkup. This was established by the Secretary of State for Health in September 2013 following concerns over serious incidents in the maternity department at Furness General Hospital. The investigation found that the Local Supervising Authority system for midwives was ineffectual at detecting manifest problems, not only in individual failures of care but also with the systems to investigate them. The report recommended an urgent response to the King’s Fund findings with effective reform of the system. These proposals address that need for reform.

At its meeting in January 2015 the Council considered the King’s Fund review recommendation and accepted it. The chair of Council has accordingly written to the DH Minister responsible calling for the government to provide an opportunity to amend the NMC’s legislation.

This paper outlines the next steps in that legislative process and makes proposals for the redesign of a future system of supervision for midwives.

Legislative process

In Learning not Blaming the Department of Health accepted this recommendation and committed to changing the law as speedily as possible. The most suitable legislative vehicle is a Section 60 Order (of the Health Act 1999), which is a statutory instrument used to amend existing law and can be used to remove midwifery supervision from statute. Parliamentary time has to be identified and the passage of the new law could take 12 to 24 months. It is likely the new law could be in place in spring 2017. A period of public consultation on the Draft Order, which will be an opportunity for stakeholders to comment on the proposed legislation (rather than the proposed model of supervision), has been built into this timetable.

In the meantime, statutory supervision of midwives as it is currently framed must continue until the law changes. The NMC and the Local Supervising Authorities (LSAs) will need to develop strategies for ensuring that the Midwives Rules and Standards continue to be met in the interim.

The new legislation will need to achieve a number of changes across the UK. Including:

• the LSAs will be disestablished; this function will be held separately in each of the UK countries by NHS England, Healthcare Inspectorate Wales, the Public Health Agency in Northern Ireland and the Health Boards in Scotland
• the Local Supervising Authority Midwifery Officer (LSAMO) designation will cease to exist as a statutory entity
• the statutory function of the Supervisor of Midwives (SoM) will cease
• the statutory powers of entry afforded Supervisors of Midwives will no longer be needed
• the current Midwives Rules and Standards 2012 will be revoked and as a consequence the processes and products specified in these Rules will cease to be statutory matters
• the statutory Midwifery Committee at the NMC will cease, this is in line with the Law Commission Report which found the committee to be anomalous^{[footnote 1]}, consequently the NMC is currently considering how it secures midwifery advice to the Council

Although these statutory elements of supervision will disappear it is for employers to decide how to effect the changes relating to these posts and the post holders. For example, LSAMOs and SoMs commonly have roles that often extend beyond statutory supervision into issues around safeguarding and service quality. The value added by the post holders to the system and the quality of services to women and babies should be recognised in designing the future system and in reviewing their roles. The legislative changes will bring an end to the LSA, LSAMO and SoM functions but will not mean automatic disestablishment of these roles and their non-statutory responsibilities.

These legislative changes do not mean an end to supervision, only to its statutory components. The developmental and supportive nature of supervision is important to the profession and for outcomes to women and babies. This culture of developmental and supportive supervision should be preserved.

Protected title and function

These proposed legislative changes will preserve:

• the protected title of ‘midwife’
• the protected function of ‘attendance on a woman in childbirth’, which means that, other than in an emergency or as part of training, only a midwife or medical practitioner can deliver a baby

There are no changes to the scope of midwifery practice, which is much wider than the narrow protected function above and is reflected in the standards of competence for registered midwives and the NMC Code.

The NMC understands that midwives are used to having a familiar and midwifery-specific source document that captures their regulatory framework. They will provide such a document in due course.

Roles and responsibilities

The Nursing and Midwifery Council’s role is to:

• inform the Department of Health in shaping the change to the statutory framework for regulation
• carry out its role in the current arrangements, and support others to do so, until they are superseded
• implement changes to the regulatory model and be accountable for its operation
• review the Midwives Rules and Standards and consider whether there is any content that does not relate to statutory supervision or is not otherwise adequately covered for regulatory purposes in its Code and associated guidance
• assist midwifery leaders in shaping a new, non-statutory approach to supervision

Department of Health’s role is to:

• secure appropriate legislative change
• convene and support partners in the design of a managed transition for supervision
• identify risks associated with the withdrawal of statutory supervision and ensure that they are appropriately managed

Chief Nursing Officers, government midwifery officers, Local Supervising Authority Midwifery Officers and Royal College of Midwives (RCM) contribution is to:

• provide leadership to the process of shaping a future direction for supervision
• ensure their subject matter expertise supports continuity prior to the change and shapes the future
• manage the risk jointly and take responsibility for ensuring the new system is embedded and that statutory supervision continues until legislation is amended

Employers of midwives and providers of services are to provide:

• accountability for the quality and safety of their midwives including conducting audits of midwifery practice
• effective clinical governance and performance management in response to concerns
• good quality annual appraisal for midwives
• fulfilment of the responsibilities associated with employing and deploying registered professionals ensuring they can practise in accordance with the NMC Code and maintain their registration (in accordance with the new NMC system of revalidation which will make the current Notification of Intention to Practise forms obsolete)
• remuneration (or not) of new supervisors
• a selection of new supervisors

Shared responsibilities to:

• manage the risks and pursue continuity and quality in the current midwifery framework until legislative change takes effect
• communicate effectively with the midwifery community and interested parties and manage the transition between the 2 systems
• identify and broker the implications of changes for others such as the system regulators and commissioners (for sector partners, not the NMC) to ensure that a new model of supervision focussed on professional support and development demonstrably meets quality criteria of effectiveness, safety and experience

Nursing and Midwifery Council processes

The NMC’s role is in the first instance to pursue and influence legislative change. It is initiating an internal project to plan and manage the transition, including the communication of changes. It will support the current system until legislative change is achieved.

Redesigning supervision for midwives

The ending of statutory supervision of midwives does not mean the end of all forms of supervision for midwives. It is essential that systems and processes of good clinical governance and professional performance continue to exist and are built upon for the future. There is also an imperative to ensure that the new system of supervision covers the full role of the midwife. Definitions of the scope and role of the midwife, which currently appear in the NMC’s Midwives Rules and Standards, 2012^{[footnote 2]}, also need to be considered as part of the new system.

The King’s Fund review identified that issues such as development and support of the midwife through supervision, mentoring and preceptorship are perceived as beneficial, even if there is no clear evidence that they improve clinical outcomes. The developmental and supportive nature of supervision should be preserved along with 24 hour access to clinical decision-making and support. This recognises that well supported and developed staff contribute positively to outcomes for service users.

The NMC and the UK chief nursing officers and their professional midwifery officers are committed to this and are leading a design for the future. In collaboration with the Royal College of Midwives and the UK LSAMO Forum, they are setting principles on which to base a design for future supervision which will apply to all practising midwives whether they are in the NHS, the independent sector, self-employed or any other setting. However, supervision needs to be proportionate and recognise the importance of managing risks and promoting safety. Most risk is in clinical practice and a system of clinical supervision is important for those midwives.

Peer review (rather than clinical supervision) will be necessary for those midwives in leadership and education roles, for example, and not in clinical practice. Such midwives are legitimately practising midwifery and are also registered with and regulated by the NMC.

In testing these concepts of clinical supervision and peer review with midwifery leaders it has become apparent that the term ‘supervision’ has some negative and ‘blue-collar’ connotations. However, a suitable substitute term, which has broad support, has not been found^{[footnote 3]}. It is therefore the intention to use the term ‘midwifery supervision’ for the newly designed system. This will comprise clinical supervision for those in clinical practice and peer review for those practising midwives outside clinical practice. This will fit with the NMC’s new system of revalidation.

In redesigning supervision a clear distinction needs to be drawn between revalidation as a registrant, appraisal as an employee (where relevant) and supervision as a professional. Regulation is about threshold standards, the employer process is about performance in a role and the professional supervisory focus is about the support and development of midwives beyond threshold standards with an emphasis on continuous quality improvement. The principle of public protection through supervision needs to be preserved.

The principles for midwifery supervision as a professional are that:

• it maintains and improves quality and thereby protects the public
• for those midwives in clinical practice, the system should be framed as clinical supervision (which need not espouse any one particular model of clinical supervision) and peer review for those midwives not in clinical roles
• a system of midwifery supervision is a vital aspect of contemporary midwifery practice and needs supervisors of sufficient expertise and experience to support the midwife in practise
• midwifery supervision should be at least an annual event and also be proactively accessed at times when support and advice are needed on a 24 hour, 365 days of the year basis
• midwifery supervision is a proactive, developmental and supportive partnership between a midwife and the supervisor and links to effective clinical governance
• supervisors may or may not be in managerial roles or the supervisee’s line manager, but do need to be practising midwives themselves
• supervisors are adequately prepared and experienced enough to be both critical and supportive
• supervisors are selected by heads of midwifery and peer feedback should be used to inform the selection process
• alignment with the NMC Code (2015) is essential
• alignment with the NMC revalidation process is essential and will be the same process for all its registrants
• the NMC should hold only information about practising midwives that contributes to protection of the public; it is therefore unlikely that the Local Supervising Authority Midwifery Officer (LSAMO) database (hosted and maintained by NHS England for the UK) will need to be kept for regulation purposes – on this premise, keeping or transferring the database is a matter for negotiation by the affected parties
• employers ensure that all their practising midwives are subject to supervision
• all practising midwives seek supervision even if they are self-employed or do not work regularly for one employer consistently
• any new system must not be more costly than the present system
• for the majority of midwives who are employed, there should be clarity about the legitimacy and distinctiveness of supervision as a facet of professional good practice and appraisal as a responsibility of the employer

The responsibilities for individual midwives are described in Annex 1.

It is expected that each UK country chief nursing officer will convene a time limited task force to work through the implications of these principles and take steps to embed them in practice. Their early thinking and in-country context is captured in Annex 2.

Revalidation, midwifery supervision and peer review

The NMC process of revalidation will not feature distinctive provisions for midwifery registrants, but non-statutory supervision will be a source of evidence for the registrant compiling their portfolio for revalidation and for review by the confirmer. Clinical supervisors could be chosen by midwives to be their confirmer for revalidation.

Future supervisors

Supervisors of the future need to be adequately prepared and experienced enough to be both constructively critical and supportive: poor practice cannot be perpetuated or condoned. Heads of Midwifery will take the lead role in designating suitable midwives to be supervisors and ensuring they have an adequate number to cover all their employees. Peer feedback should be used to inform the selection process to ensure supervisors command the confidence of the midwifery workforce. Midwives will need access to an individual supervisor but consideration could be given to group supervision and networks of supervisors to ensure there is appropriate cover and sharing of information and best practice.

Arrangements for supervising self-employed midwives and those not consistently in employment (such as some agency midwives) and those not in NHS employment will be no different from any other midwives. However, Independent Midwives UK (IMUK)^{[footnote 4]} is proposing to establish a system for their members that offers a new level of support and advice to those practising independently and are self-employed. For example, they intend to:

• support and advise their members undergoing investigation
• help their members to audit practice and record development as a contribution to their continuing professional development activities to support the requirements of revalidation
• check the registration details of their member midwives on the NMC register, ask for declaration of any investigation and support development and audit
• set out the main requirements of membership and indemnity as well as supporting guidelines for practice

The changes as they affect independent and self-employed midwives who are not members of IMUK will need to be examined and approved by the relevant country task force.

The NMC will no longer appoint statutory supervisors or set standards for their preparation or selection. However, training for supervisors will be needed to ensure these changes are embedded in practice and that they are properly equipped as stewards of quality to take on the challenges of clinical supervision. The Preparation of Supervisors of Midwives (PoSoM) course should be adapted to major on clinical supervision, leadership and clinical governance. This will reflect that statutory supervisory investigations will cease and that all such concerns will be dealt with through robust clinical governance structures and fitness to practise procedures as appropriate. Consideration could also be given to having a foundation core to the programme and then progression to major on clinical supervision or leadership as pathways for the new generation of midwifery leaders. The advocacy role of midwives in supporting the women in their care also needs to be incorporated into undergraduate and post-graduate education. There is a fear that, since some of this was undertaken by statutory supervisors of midwives in an impartial way, midwives will be under confident and cautious of being criticised by their employer in advocating for their women. Midwives in the future will need to grow in confidence to advocate for their women especially when they wish to make atypical choices.

The NMC currently sets standards for the ratio of statutory supervisors to midwives. This will no longer be an appropriate matter for the professional regulator with no leverage over whether the standard is met. It will be for the sector to decide whether ratios play a role in safety and quality.

Undergraduate midwifery education

The NMC will continue to have the powers to set standards of education for midwives.

Further access to advice

One of the side benefits of the Supervisor of Midwives role is that they were clustered onto rosters to provide 24 hour cover for midwives and women needing advice at any time. A similar system should continue to exist, especially for women needing access to a senior and experienced midwife, however, it is recognised this now needs separating from supervision. Service providers, including independent midwives, should consider how to provide this to reflect the needs of the women they serve and the support their midwives need.

Midwifery leadership: the Local Supervising Authority Midwifery Officer function

There is concern that the loss of the LSAMO function will result in a loss of midwifery leadership across the UK. Some LSAMOs execute functions beyond that of their statutory requirement and are involved in issues such as safeguarding and improving quality of care and services. Employers need to consider how best to preserve these functions.

LSAMOs are required to conduct annual reviews of statutory supervision and report them to the NMC as described in the Midwives Rules and Standards 2012. These will no longer be required.

In Scotland and Wales the Heads of Midwifery give the strategic direction required at Board level and they have close connections with the chief midwives of the two governments. Each of the UK countries have a government official, who is a registered midwife, to advise ministers on midwifery matters. The new system needs to ensure there are networks of representative midwives who have access to the midwifery government advisors and replace the national LSAMO forums.

Midwifery leadership: the head of midwifery function

Given the changes to statutory supervision of midwives and the functional roles that will cease as a consequence there is a need to bolster the preparation of those wishing to be heads of midwifery. There is a need to raise the profile of heads of midwifery as leaders and stewards of quality with the populations they serve, their employing organisations, clinical governance leads, commissioning or contracting organisations and service inspectors. Heads of midwifery need close relationships between executive nurses in NHS providers.

Maternity Services Liaison Committees

Maternity Services Liaison Committees reinforce the service user perspective as equal partners and should look for good practice in the services with which they liaise.

Practical considerations

The changes to these statutory functions result in some consequences which need addressing separately from these proposals. There are risks that the UK LSAMO Forum have articulated which are non-statutory. A task force in each UK country will be set up by each chief nursing officer to review and resolve these risks. Such non-statutory risks are:

• a lack of development opportunities and support for self-employed midwives and agency midwives
• a vacuum being left regarding provision of professional midwifery advice regionally
• potentially closing down of the UK wide LSA database with a loss of knowledge, information, data and the capacity to share data
• that no audits of maternity services will be conducted resulting in a lack of benchmarking against national standards
• that no annual reports will go to the NMC resulting in reduction in information sharing with the main stakeholders with a consequent reduction in the available expertise in providing advocacy for women and complex care planning
• that removal of the LSA function will result in a reduction of support for Heads of Midwifery
• whether midwifery supervisors should be remunerated or not

In addition, these changes to the statutory function affect the way the UK countries will embed and manage the future of midwifery supervision. Currently, the regulation of nurses and midwives by the NMC is a matter which is reserved to the UK Parliament. Therefore legislation to remove the statutory supervision of midwives from the NMC’s governing legislation will not be required to be laid in the Scottish Parliament. However, although the 4 countries are working to introduce a new and consistent system of employer led professional supervision, this will not be based in legislation and will ultimately be the policy responsibility of each country to develop and operate. Ultimately, proposals for a four country model will need the separate policy approval of the Health Ministers in each country.

Royal College of Midwives – monitoring the new system

Helpfully, the RCM have published a discussion paper, ‘Reframing midwifery supervision’. This sets out their views and makes 11 recommendations. They recognise that the removal from statute creates an opportunity to shape a new model and framework for effective clinical midwifery supervision.

They are particularly keen to ensure that the new system goes beyond a model reliant on professional drive and employer motivation to make it effective and have proposed that system regulators and other bodies are involved in monitoring the new system. They suggest:

To protect women and babies from risk and harm employers, providers of midwifery care and individual midwives themselves must have in place processes which support midwifery supervision and the development of midwives as skilled practitioners. Such processes must feed into effective clinical governance arrangements. System regulators such as CQC, Monitor and the Trust Development Authority and commissioners of services in England (and their equivalents in the devolved nations) must assure themselves that the safety and efficacy of maternity services are supported by effective midwifery supervision. In this context midwifery services cannot be deemed to be well led if they do not have effective midwifery supervision.

In supporting effective midwifery supervision organisations should monitor their services to support continuous quality improvement. Maternity services networks (where they exist in England, and using similar arrangements in the other UK countries) should create processes for monitoring the outcomes of midwifery supervision to assure their effectiveness.

In testing these proposals with the relevant organisations in England, Monitor and the Trust Development Authority have made it clear that they consider midwifery supervision to be an important aspect of professional practice and a key component of safe care. However, monitoring midwifery supervision would not fit their core organisational purpose. They do not do anything similar for the other professions. The CQC is a regulator and does explore the systems that organisations have in place to provide safe and effective care. Issues such as training and development and, where appropriate, supervision and mentoring, could appear in the safe or well led elements of their inspections. However, this does not mean the CQC will be able to ‘regulate’ midwifery supervision after its abolition from statute.

In Scotland, discussions are underway with the main stakeholders to explore the mechanism by which the CNO can be assured that midwifery supervision standards are being met in practice. Healthcare Improvement Scotland is the national organisation that supports improvement in the quality of healthcare, through the provision of standards and guidance, delivering scrutiny activity, and providing quality improvement support for healthcare providers. The CNO and her officials will explore the potential for governing midwifery supervision in the light of that landscape.

Given this context there could be a UK-wide leadership role here for the RCM in developing standards for supervision, guidance for employers, commissioners and system regulators to demonstrate how they consider effective midwifery supervision should be conducted in practice. This should reflect the principles adopted by the 4 UK countries and relate to how midwifery supervision contributes to effective clinical governance systems and the NMC proposals for revalidation.

Proposals in summary

The proposals are:

• an overarching system of midwifery supervision will be devised, which will be put in place when statutory supervision is removed; this will meet the need for clinical supervision for midwives in clinical practice and peer review for practising midwives who are not in clinical practice
• the new system will be employer led, professional model
• that the NMC will focus on using its regulatory functions (to include revalidation from April 2016) to protect the public
• each UK country will convene a task force (by the chief nursing officer of each country) to examine and embed the principles (outlined in the principles for midwifery supervision above), to bolster the preparation of heads of midwifery as leaders and stewards of quality (outlined in supervisors of the future and that the NMC will no longer appoint statutory supervisors above), resolve the non-statutory risks created by removing the LSAMO function (outlined in the changes to statutory functions above) and to oversee the transition from a statutory model of supervision to an employer led, professional model

Conclusion

The UK CNOs, their professional midwifery officers, the NMC, the Royal College of Midwives (RCM) and the UK LSAMO Forum are committed to playing their respective roles in transition responsibly. They all support a proportionate approach to midwifery regulation on the one hand and the availability of good professional support and development for all midwives.

References

Law Commission (2014) Regulation of Health and Social Care Professionals in England

NMC and LSAMO UK Forum (2008) Modern supervision in action. A practical guide for midwives

PHSO (2013) Midwifery supervision and regulation: recommendations for change

The King’s Fund (2015) Midwifery Regulation in the United Kingdom

NMC Code (2015) Professional standards of practice and behaviour for nurses and midwives

Annex 1: The midwife and supervision

Adapted from NMC and LSAMO UK Forum (2008) ‘Modern supervision in action. A practical guide for midwives.’

Midwife as an accountable practitioner, supported and empowered

It is your responsibility, in maintaining current registration with the NMC, to:

• identify and meet the NMC requirements for revalidation
• meet, at least annually, with your clinical supervisor and confirm this to the NMC via your on-line account
• notify your intention to practise annually to the NMC via your on-line account
• have a working knowledge of how the following NMC publications guide your practice: ‘NMC Midwives rules and standards’ (2012 until they are revoked); ‘The NMC Code. Professional standards of practice and behaviour for nurses and midwives’ (2015)

Your responsibility, in meeting the needs and expectations of mothers and babies, is to:

• identify, notify and report issues that adversely affect the safety of mother and/or baby
• report critical incidents through the appropriate clinical governance system
• act as an advocate for women
• contribute to risk management and clinical governance

Your responsibility, in maintaining your fitness to practise, is to:

• identify and meet the NMC requirements for revalidation
• access and use evidence to inform your practice
• reflect on practice outcomes
• obtain feedback and evaluate your own practice to ensure competence is maintained
• identify your education needs in relation to developing new areas of competence

Annex 2: Context in each of UK countries

Northern Ireland

Northern Ireland has standards for clinical supervision for nursing outcomes against which are reported to the chief nursing officer as part of an assurance framework. This will be extended to midwifery.

The chief nursing officer has also commissioned a review of midwifery supervision and its initial emerging main issues are:

For women:

• over half of the women who engaged in the review were aware of the Supervision of Midwives framework
• women see this an additional support to them especially in terms of support for their birth choices and they see it as vital area of professional support for midwives
• more engagement with women is needed

For midwives:

• there was a unanimous plea for the supervision of midwifery to remain in Northern Ireland
• all of the professionals strongly expressed their views on the importance of maintaining the annual supervision of midwifery review
• the implementation of midwifery led care in alongside consultant units and in standalone midwifery led units is expanding; therefore the role of the supervisor of midwives was seen as an immense professional and advisory support (24/7) in today’s contemporary midwifery practice
• the retention of the framework was seen to be of vital importance especially in light of the NMC Revalidation process
• there appeared to be immense support of Northern Ireland to migrate to a system of having fulltime SoM’s positions who would provide on-call 24/7 for the entire region (as opposed to 5 trusts simultaneously providing this service), which would provide a consistency of approach in terms of professional information, support and advice
• there was a lot of interest in exploring elements of the restorative model of supervision used mainly in social work and health visiting services; this model aims to increase the resilience of the professionals by ensuring they can act on risk appropriately as well as improving the delivery of care extended to women
• there was clarity on the need to have strong links with midwifery supervision that are aligned with the trust governance processes to provide additional assurances
• the investigatory aspect of midwifery supervision was seen as an area that required an element of independence; there was an expression of contentment with the proposal from the NMC on this aspect of regulation.

These findings will frame a sustainable approach in Northern Ireland which will function beyond the change in statute. They are also examining the possibility of using a model of ‘restorative’ supervision (already used in social work and health visiting), which aims to increase the resilience of professionals, manage risks appropriately and improve the delivery of care. The findings of Northern Ireland will be shared with the other UK countries.

Scotland

Heads of midwifery have a well established strategic and leadership role for midwifery within the NHS Boards. Scotland is currently undertaking a literature review to inform the new model of clinical and peer supervision and will convene a taskforce in the autumn to take forward recommendations, subject to Ministerial approval. Evaluation of the new midwifery supervision model is planned alongside implementation and discussions are underway related to governance of supervision standards in practice and how the skills and experience of the existing LSAMO can contribute within the new landscape.

Wales

The supervisory structure in Wales has recently been reviewed and a new system has been successfully adopted. There is now a system of rotational supervisors of midwives which will be sustained once the legislative changes to remove the LSA and LSAMO functions have been effected.

However, the Welsh Government is also consulting on ensuring all health professional registrants have access to clinical peer supervision. Their Green Paper, ‘Our Health, Our Health Service’ was issued on 6 July 2015 for consultation until 20 November 2015.

England

In England the LSAMO posts will be replaced by 4 regional lead midwives covering the North, South, London and Midlands and East regions of NHS England. These regional lead midwives will advise on all maternity matters at local and regional level and work within a new governance framework for midwifery supervision. The will be supported by a sub-structure of midwives across the regions. The number and nature of these posts will be determined following consultation on a proposed structure. This affects the 7 LSAMO and 9.6 whole-time-equivalent support supervisors of midwives and their secretariat currently in post.

1. Law Commission (2014) ‘Regulation of Health and Social Care Professionals in England’. The remit of the project was to review the UK law relating to the regulation of healthcare professionals and, in England only, the regulation of social workers. ↩

2. Particular concerns have been expressed about Rules 2 and 5. ↩

3. To replace the supervisor of midwives job title the term ‘midwife advocate’ has been suggested, but, although the concept of advocacy is important, the overriding view is that this sounds too much like advocating for midwives rather than protecting women and babies. Its adoption is therefore not recommended. ↩

4. IMUK is the membership organisation for independent, self-employed midwives in the UK. Their membership comes with an insurance package. They are not an organisation that provides midwifery services. ↩