MIPP submission to Senate Inquiry

Inquiry into the administration of health practitioner registration by the Australian Health Practitioner Regulation Agency (AHPRA)

MIPP has made a joint submission with Australian Private Midwives Association (APMA). To access all the submissions received by the committee,
click here

The matters addressed in this submission are in response to our experiences during the recent transition from individual State and Territory-based regulation of the midwifery profession to the national regulation of the midwifery profession under AHPRA.

We draw to the attention of the Inquiry the following matters, which will be discussed in more detail in the body of this submission:
1. AHPRA’s administration of the registration process for Medicare benefits
.1 Midwives are required by AHPRA to provide a reference from hospital midwife manager or obstetrician when applying for notation as eligible for Medicare benefits. This is an unreasonable request for many privately practising midwives.
.2 ‘Prescribing’ course. Midwives who apply to AHPRA for notation as eligible for Medicare benefits are required to sign an undertaking to complete within 18 months of recognition as an eligible midwife, an accredited and approved program of study determined by the Board to develop midwives’ knowledge and skills in prescribing ...” There is at present no such course available for midwives.
.3 Some midwives have experienced unacceptable delays and a lack of fairness in processing applications for notation as eligible midwife.
.4 We draw to the attention of the Inquiry the implications for consumers/ private clients of midwives whose applications have been delayed without good reason.
.5 We assert that there is a strong potential for misunderstanding in the obstetric and hospital midwifery communities as to the meaning of collaboration. Legislation that privileges obstetricians, placing them in a supervisory role for midwives, must be repealed.

2. The administration by AHPRA of complaints against privately practising midwives
.1 A privately practising midwife’s registration had been suspended prior to the changeover to the new legislation. This midwife has been unable to work and earn a living, yet she has not yet been given an opportunity to present her case in person, or to have her suspension lifted.
.2 At least two midwives have recently had conditions (supervised hospital practice) placed on their registrations without any investigation into the complaint. This is as effective as a suspension, with the midwife losing her ability to earn a living while the conditions apply.

3. Professional Indemnity Insurance. AHPRA, through the Nursing and Midwifery Board (NMBA), is currently in the process of drafting requirements for insurance for midwives. We wish to draw this to the attention of the Inquiry, as midwives in private practice are the only professional group unable to purchase indemnity insurance to meet the requirements of the national legislation.