Last month, solicitor Laura Paton explored the importance of revalidation in the eyes of Care Quality Commission. In this article, Nicole Ridgwell considers how the process of revalidation translates into the care home environment
Revalidation replaced the Nursing and Midwifery Council’s (NMC) post-registration education and practice (Prep) requirements in April 2016 as the mandatory route to renewing registration with the regulatory body. This new system was quickly adopted into the Care Quality Commission’s (CQC) (2014) guidance for staff and employers. The CQC firmly believes that revalidation is central to the employer’s duty to demonstrate that their nursing employees continue to meet their professional standards.
Providing up-to-date practice
The essence of revalidation is to ensure that all nurses and midwives remain up to date within their chosen fields. This must be evidenced through a mixture of documented practice hours, participation in training sessions, practice-related feedback, reflective discussion, and reflective writings (Paton, 2017).
Adding to the previous Prep requirements, revalidation asks NMC registrants to reflect on the role of the Code (NMC, 2015a), and proactively demonstrate that their daily practice and personal development meets the standards it sets out. The Code, puts the ability to ‘practise effectively’ at the centre of a registrant’s role, and as such, emphasis must be given to ensuring that learning and training during revalidation is directly applicable to a registrant’s chosen field.
Potential problems in social care
The new obligations on registrants to share and reflect with colleagues could be seen to pose potential difficulties for those working in care home environments. As acknowledged in the Foundation of Nursing Studies (2016) video, A Practical Guide to Revalidation for Nurses Working in Social Care, there is the tendency for nurses within adult social care to feel isolated from their profession. Nurses in care homes can often find themselves working with few, if any, registered colleagues, and lacking easy access to the training courses that would be available through large social care providers, or the NHS organisational structure.
However, what may seem like a daunting exercise is easily solved with a little forward planning and engagement between employer and nursing staff. Registrants might want to investigate the range of courses available through organisations such as the Royal College of Nursing in order to satisfy the revalidation obligation for 20 of the 35 hours of continuing professional development (CPD) to be ‘participatory learning’ (involving interaction with other professionals). However, they should also remember that the interaction with other professionals can either be face-to-face or in a virtual environment— the NMC has purposefully declined from prescribing any particular type of CPD. NMC guidance leaves it to the individual registrant to decide which learning activities are most useful for their development as a professional. Nurses working within care homes should therefore consider the needs of their residents when deciding what training to attend. This is, one would hope, what any sensible professional was already doing, and would continue to do, whether or not it was prescribed by their regulator.
The registrant must also engage with another registered nurse to meet the requirement of completing a reflective discussion. Where there is only one NMC-registered staff member within a care home, the registrant and their employer should consider what other possibilities are available to them within their local vicinity. If, for example, there is another care home nearby, arrangements could be made for a one-to-one meeting between the two care homes’ nursing staff. This is not a huge ask, as revalidation only requires one reflective discussion covering a nurse’s five written reflective accounts to take place every 3 years, whereas failure to revalidate means that a nurse is not legally able to practise in the UK.
It is important that the reflective discussion partners are able to explore with each other how each of their written accounts could be used to reflect upon and improve their practice. As a result, while there is no requirement that the partners work within the same establishment, it may be of more benefit if they work within the same sector. It could even be argued that a ‘fresh pair of eyes’ is more beneficial to such a discussion than a meeting with a colleague with whom the nurse works every day.
Nurses and employers should remember that while the reflective discussion partner must be a registered nurse, the ‘confirmer’ need not be. It is the confirmer’s duty to check that the registrant has met all the requirements for revalidation. They are not being charged with assessing a registrant’s fitness to practise and could therefore be the registrant’s line manager or suitable senior within the care home, regardless of their registration status with the NMC. It is useful to be aware that the NMC strongly recommends that confirmation takes place as part of the regular appraisal process, although this is not strictly necessary. Nurses struggling to decide who should be their confirmer should make use of the NMC confirmer tool (NMC, 2017).
Anecdotal reports prior to the launch of revalidation suggested that nurses were most concerned about the new requirement to obtain five pieces of practice-related feedback (Godfrey, 2016). In this respect, care homes are arguably better placed than the more anonymous environments of a large hospital or even a local GP surgery. As per CQC requirements, care homes should be actively seeking feedback on a regular basis, meaning that nurses in this sector should find relative ease with this aspect of revalidation.
Care home nurses receive both formal and informal feedback from residents, their families, and from the large multidisciplinary group of professionals with whom they interact on a daily basis. When considering that feedback can come in the form of verbal conversation, cards, notes and care home surveys, the fact that revalidation only requires five instances to be recorded over the 3-year period suddenly makes this aspect of revalidation far less of a chore, and more a rather rewarding opportunity to formally store the compliments and comments that care home nurses are normally too busy to record.
Reading the guidance
Registrants may also initially struggle with the formalised language used in some of the guidance documents. Again, thinking strategically about the advantages of the care home environment can reassure nurses and employers that the revalidation requirements easily translate to the care home setting.
For example, the NMC reflective accounts template form asks registrants to identify five individual CPD activities and/or practice-related feedback and/or events encountered within practice. The form then asks the registrant to state what they learnt from this experience and how their practice changed or improved as a result. As it is central to the revalidation process, the example must be linked back to the Code, with the registrant identifying the experience as being relevant to one or more its four sections:
- Prioritising people
- Practising effectively
- Preserving safety
- Promoting professionalism and trust.
There are numerous revalidation ‘how to’ guides available from bodies such as the NMC and the Royal College of Nursing that provide helpful examples of how experiences can be used as reflective examples. For example, a safeguarding incident can be readily linked to ‘preserving safety’, while feedback from and reflection on a residents’ survey is an obvious example of ‘prioritising people’. It is simply a matter of being mindful of the requirements and making a mental note when a useful example offers itself within a nurse’s daily practice.
The duty to revalidate
The duty to ensure that a registrant meets all the requirements of revalidation rests solely on the nurse. That said, the CQC’s Regulation 18(2)(c) requires that:
‘[Employees must] be enabled to provide evidence to the regulator in question demonstrating, where it is possible to do so, that they continue to meet the professional standards which are a condition of their ability to practise or a requirement of their role.’ (CQC, 2016)
It is therefore in the home’s interests to help facilitate the revalidation process. Where written resident/family questionnaires, surveys or complaints specifically mention a nurse employee, care home employers should ensure that the nurse in question is made aware of this and given a copy. Likewise, where conversations cite the practice of a nurse employee, employers should make a record and feed it back to the employee. Not only should this be done as a matter of course as a responsible employer, but it also aids the employee to meet the steps to revalidation, and provides evidence that will help the home during CQC inspections.
The NMC’s (2015b) Employers’ Guide to Revalidation helpfully sets out the ‘minimum support’ a nurse should expect from their employer, and compares this to that which should be ‘reasonably expected’. For example, within the minimum support cited within ‘guidance, tools and support’ is signposting nurses to the NMC website, whereas the assistance to be ‘reasonably expected’ should:
- Provide further information about who in the organisation can act as a confirmer and/or reflective discussion partner as detailed in the NMC’s requirements
- Review whether informal organisational systems could be implemented to allow for participatory CPD learning
- Incorporate communication about the requirements for the online revalidation process and timings into local communication systems
- Remind nurses and midwives of their obligations of confidentiality under the Code and the Data Protection Act.
Following these simple steps will help demonstrate that employers aware and respectful of their obligations, while actively safeguarding themselves by providing concrete evidence for the CQC during care home inspections.
Ultimately, the revalidation process has been designed to encourage nurses to reflect on the NMC Code and ensure that their practice adheres to these standards. It can therefore only be in an employer’s best interests to ensure that they take these simple steps to ensure that their employees are the best that they can be; for the residents, for the staff as a whole, and for the care home’s demonstration of CQC compliance. NR
- Revalidation is central to the duty on employers to demonstrate that their nursing employees continue to meet their professional standards
- The revalidation process has been designed to encourage nurses to reflect on the NMC Code
- Guidance from the Nursing & Midwifery Council allows the registrant to decide which learning activities are most useful for their development
- Revalidation is only completed every 3 years, making it less of a time-sink than many people realise