SUBMISSION DATE: 4/07/2014 DRAFT Nurse Practitioner Accreditation Standards Australian College of Nursing (ACN) is pleased to provide feedback on the Australian Nursing and Midwifery Accreditation Council s (ANMAC) DRAFT Nurse Practitioner Accreditation Standards. QUESTION 1: Do the DRAFT Nurse Practitioner Accreditation Standards sufficiently enable the development of capability as an attribute of nurse practitioner practice? Yes, in ACN s view the mix of teaching approaches in the DRAFT Nurse Practitioner Accreditation Standards sufficiently enables the development of capability as an attribute of nurse practitioner practice. ACN is of the view that Standard 2: Curriculum framework sufficiently enables capability development in nurse practitioner candidates. In particular, the approaches to teaching and learning c, e, f and g in criterion 2.3 of Standard 2 will contribute to developing nurse practitioners capability. QUESTION 2: Is the National Prescribing Competencies Framework an appropriate resource for inclusion in the DRAFT Nurse Practitioner Accreditation Standards? Yes, the National Prescribing Competencies Framework is an appropriate resource for inclusion in the DRAFT Nurse Practitioner Accreditation Standards. ACN considers the inclusion of the National Prescribing Competencies Framework in the DRAFT Nurse Practitioner Accreditation Standards to be appropriate because the Framework s five vertical and two horizontal competency areas reflect abilities fundamental to safe clinical prescribing. Further, including the Framework in the DRAFT Nurse Practitioner Accreditation Standards would ensure the alignment of nurse practitioner programs of study with the Health Professional s Prescribing Pathway (HPPP) developed by Health Workforce Australia. QUESTION 3: Do you support the term integrated professional practice replacing professional experience in the DRAFT Nurse Practitioner Accreditation Standards? Yes, ACN supports that the term integrated professional practice replaces professional experience in the DRAFT Nurse Practitioner Accreditation Standards. In the DRAFT Nurse Practitioner Accreditation Standards, the concept of integrated professional practice is identified as a significant element of the standards. Standard 3: Program Development and Structure identifies integrated professional practice as sufficient to enable the student to function as a safe, autonomous and collaborative nurse practitioner and is planned to constitute a sizeable component of nurse practitioner education in terms of hours. Given the importance of the introduction of the term integrated professional practice, ACN is of the view that the DRAFT Nurse Practitioner Accreditation Standards would benefit from the inclusion of a more detailed definition of this term and examples of experiences that should be made available to student nurse practitioners. Greater guidance would ensure that integrated professional practice hours represent a high-quality learning experience for the candidate and clarify the responsibilities of health services and education providers. 1
QUESTION 4: Do you support the specification of a minimum number of integrated professional practice hours in the DRAFT Nurse Practitioner Accreditation Standards? Yes, ACN supports the specification of a minimum number of integrated professional practice hours in the DRAFT Nurse Practitioner Accreditation Standards. Specifying a minimum number of professional practice hours is likely to benefit nurse practitioner candidates learning and skill acquisition and will promote greater consistency across education programs. To ensure candidates high-quality learning experiences, more detailed guidance should be provided concerning ANMAC s expectations of the learning outcomes to be achieved. In our view, it should not be assumed that completion of a minimum number of hours automatically equates to candidates achievement of a particular level of competence or capability. QUESTION 5: Do you support 500 hours as the specified minimum number of hours? Yes, ACN in principle supports 500 hours as the specified minimum number of hours. However, as noted in the Consultation Paper (page 15), no published evidence is available specifying best practice in terms of the integrated professional practice hours required. Candidates enter nurse practitioner programs from a broad range of professional backgrounds and with highly variable professional experience in advanced roles. While 500 hours is an arbitrary number which is likely to be insufficient in some cases and excessive in others, ACN believes it to be a reasonable minimum. By our calculation, 500 hours of integrated professional practice equates to just over three months Full Time Equivalent (FTE). In our view, this is an appropriate amount of integrated professional practice to include in a two-year program of study. The specified number of hours should be revised when evidence about best practice becomes available. QUESTION 6: Do you support this minimum number of hours being supernumerary? No, ACN does not support that the entirety of this minimum number of hours of integrated professional practice should be supernumerary. ACN agrees in principle that supernumerary hours foster the development of nurse practitioner capability and provide high-quality learning experiences. However, in ACN s view, the requirement that all nurse practitioner candidates must complete 500 supernumerary hours of integrated professional practice is likely to pose considerable practical and financial difficulties for a significant number of students. Most candidates will need to arrange for leave in order to complete these hours but their employers may be unable to release them. ACN members consulted in the preparation of this submission noted that employers are not always able to support nurse practitioner candidates learning and development needs with paid or unpaid leave. Rural students or students preparing to enter less common specialties may face additional difficulties. These students may need to travel (and fund the associated costs) in order to complete supernumerary hours of integrated professional practice in their specialty. An alternative approach to specifying a minimum number of supernumerary integrated professional practice hours would be to stipulate that candidates and education providers jointly develop learning contracts based on the student s individual learning requirements. Learning contracts could take into account the student s professional background and the educational opportunities available in his or her workplace. Under this model, candidates with significant experience and/or significant support and supervision in their workplaces would be required to do fewer supernumerary hours. In contrast, candidates with less professional experience and/or workplaces that are less suited to candidates educational needs may be required to complete a higher number of supernumerary hours. Such learning contracts could also specify the intended learning outcomes of supernumerary hours for individual candidates. 2
QUESTION 7: Do you support the DRAFT Nurse Practitioner Accreditation Standards incorporating the viva voce clinical examination as part of student assessment? Yes, ACN does support that the DRAFT Nurse Practitioner Accreditation Standards incorporate the viva voce clinical examination as part of candidates assessments. However, ACN considers that a single, summative viva voce does not offer candidates the best opportunity of having their actual competence in the clinical application of knowledge and skill evaluated. ACN members (including a number of endorsed nurse practitioners) consulted in the preparation of this submission considered the summative viva voce examination to be a significant source of anxiety for most candidates. For this reason, a single summative viva voce examination may not be an accurate method of assessing a candidate s actual clinical reasoning abilities. ACN members felt that viva voce examinations are particularly valuable when they are used as teaching tools, as well as elements of assessment. Formative viva voce examinations can develop candidates skills as well as assess them. ACN members argued that, rather than relying on a single summative viva voce nurse practitioner courses should incorporate small formative viva voce clinical examinations throughout the course. Formative viva voces also prepare candidates for the final viva voce examination by familiarising them with the examination s format. ACN proposes the modification of Standard 5.5 to include c. formative and summative viva voce clinical assessments. Currently, the Nurse Practitioner Accreditation Standards state that Nurse practitioners should be included as part of [the multidisciplinary team assessing summative viva voce examinations] where possible (Standard 5, page 30, footnote 46). In ACN s view, this requirement should be strengthened with Standard 5 stating that this panel of examiners must include at least one endorsed nurse practitioner. The inclusion of an endorsed nurse practitioner should ensure that candidates knowledge and skill are assessed appropriately from a nursing perspective. QUESTION 8: Do you support the DRAFT Nurse Practitioner Accreditation Standards specifying a student entry criterion into the nurse practitioner program that has increased alignment to the NMBA Endorsement as a Nurse Practitioner Regulation Standard and includes: a) current general registration as a registered nurse b) demonstration of requisite experience in advanced practice nursing as specified in the NMBA s Endorsement as a Nurse Practitioner Registration Standard c) a postgraduate qualification in a speciality field that has prepared the student for advanced practice ACN believes that it is desirable that ANMAC standards align with Nursing and Midwifery Board of Australia s (NMBA) standards. However, in ACN s view the NMBA s Endorsement as a nurse practitioner registration standard should be used as guidance regarding students ability to achieve these standards with completion of the course rather than as an entry requirement. Further, ACN believes that the requirement for demonstration of requisite experience in advanced practice nursing as specified in the NMBA s standard is problematic for the following reasons: Firstly, as no agreed national definition of advanced practice exists an objective assessment of candidates advanced practice roles will be difficult to achieve. Secondly, ACN believes that preparation for an advanced practice nursing role should be the educational goal of a nurse practitioner course. The entry requirement of an equivalent of three (3) years full-time experience in an advanced practice role excludes nurses who seek to prepare themselves for practicing in an advanced role through undertaking a nurse practitioner course. If potential candidates no longer have to demonstrate advanced practice experience then this change will break the circle of exclusion for nurses who wish to become nurse practitioners to practice in an advanced role but are unable to access the education required because they do not have the advanced practice experience. ACN is mindful that removing the requirement of 3 years advanced practice experience will leave candidates unable to gain NMBA endorsement at course completion. ACN proposes that ANMAC and NMBA may seek to collaboratively 3
review the 3 year advanced practice requirement in order to enable nurses to build their careers without undue barriers being placed in their way. Further, ACN would like to make ANMAC aware that criterion c) excludes candidates working in small and/or emerging specialty areas that are not supported by postgraduate education at Australian universities (e.g. movement disorders and Parkinson s Disease). ACN proposes that ANMAC consider including alternative ways for candidates to demonstrate that they have the knowledge and cognitive skills required for advanced practice. For example, candidates who do not hold a postgraduate qualification in a specialty field may provide a portfolio evidencing their advanced practice knowledge and skills. ACN suggests that such portfolios may include: tertiary qualifications in a health related field outside nursing, leadership of or participation in quality improvement and/or research activities relevant to nursing, a list of publications and/or a record of continuous professional development undertaken. ACN is also concerned that the requirement for a postgraduate qualification may create financial barriers for prospective candidates if they have to meet full course fees for both the postgraduate qualification in their specialty and the nurse practitioner program. ACN proposes that ANMAC confer with the NMBA whether recognition of a nurse having achieved advanced practice needs to be contingent on a postgraduate qualification in a specialty field. QUESTION 9: Do you support education providers being required to have an endorsed nurse practitioner as the program convenor? No, ACN does not support that education providers are required to have an endorsed nurse practitioner as the program convenor. However, ACN considers it desirable that the course convener is an endorsed nurse practitioner. ACN believes the requirement to have an endorsed nurse practitioner as course convenor to unduly restrict universities pool of suitable applicants for this position. Further, those universities unable to offer a joint appointment with a health service may have difficulties with attracting applicants. Nurse practitioners considering becoming convenors may not take up such a position because they are unwilling to risk losing their endorsement if they cannot practice the hours required to maintain the endorsement. However, ACN believes that universities must be required to have arrangements in place that ensure an endorsed nurse practitioner contributes to convening the program as part of course advisory committees when programs are developed and reviewed. QUESTION 10: How much time would education providers need to ensure that the program convenor is an endorsed nurse practitioner? If education providers are required to have an endorsed nurse practitioner as program convenor, then ACN considers that universities should be given 5 years within which to meet this requirement. QUESTION 11: Do you support the DRAFT Nurse Practitioner Accreditation Standards specifying students have exposure to health care settings that enable the development and application of both generic and specialist knowledge and skills? Yes, ACN supports the DRAFT Nurse Practitioner Accreditation Standards specifying that students have exposure to health care settings that promote the development and application of both generic and specialist knowledge and skills. ACN believes that nurse practitioners must have strong generic skills and capabilities so they are able to practice at an advanced level broadly rather than with a narrow clinical focus. Nurse practitioners ability to practice more broadly from a strong generic foundation enhances nurse practitioners workforce flexibility. A single clinical specialty focus in nurse practitioners education limits them to practice in specific clinical fields even though their endorsement does not constrain their area of practice. Good generic skills also enable nurse practitioners to be more responsive in their care of patients who have multiple diagnoses. 4
QUESTION 12: Do you support the following definition of a suitably qualified multidisciplinary team member? Suitably qualified refers to health care professionals who are recognised by the education and health service providers and clinical peers as having: sufficient qualifications, knowledge and skills to be considered an expert in a specific clinical area; a thorough understanding of the role and scope of nurse practitioner practice, and adequate preparation and training in undertaking Masters Degree AQF Level 9 student assessment. Yes, ACN supports the above definition of a suitably qualified multidisciplinary team member because such a person requires strong clinical as well as teaching and assessment skills. However, ACN notes that the definition given in the consultation document does not appear in the DRAFT Nurse Practitioner Accreditation Standards in its entirety. The definition given as a footnote to Standard 5 contains discrepancies which ACN has highlighted in the text below by underlining the words and phrases differing from the original definition. The following definition appears as a footnote to Standard 5, on page 30: Suitably qualified members refers to health care professionals who are recognised by the Education and Health Service Providers and clinical peers as having: sufficient qualifications, knowledge and skills to be considered an expert in a specific clinical area; an understanding of the role and scope of nurse practitioner practice, and adequate preparation and training in undertaking student assessment. Nurse practitioners should be included as part of this team where possible. We note two omissions in the above definition from page 30, compared to the definition in Question 12: The adjective thorough is missing from the phrase an understanding of the role and scope of nurse practitioner practice. The phrase Masters Degree AQF Level 9 student assessment does not appear. QUESTION 13: Are there other issues, working, gaps or duplications you wish to comment on? OSCE (Objective Structured Clinical Examination) should be added to the list of acronyms. The Australian Nurse Practitioner Association is now known as Australian College of Nurse Practitioners (page 43). The Child and Family Health Nurses Association is now the Maternal, Child and Family Health Nurses Association (page 43). Standard 2 states that the program provider must demonstrate a curriculum philosophy that includes knowledge concepts related to capability theory. This term should be defined in the glossary. A definition of advanced practice nursing should be included in the glossary. Criterion 8.9 in Standard 8 currently reads Nominated professionals in the student s clinical and professional support team undertake assessment of the Nurse Practitioner Standards of Practice within the context of integrated professional practice. ACN suggest that this sentence could be clarified to read, Nominated professionals in the student s clinical and professional support team undertake assessment of the student against the Nurse Practitioner Standards of Practice. 5