All District Health Boards
20 April 2022
Dr Susan Calvert
Tumu Whakahaere me te Pouroki: Chief Executive and Registrar
Te Tatau o te Whare Kahu | Midwifery Council
By email: [email address]
Dear Sue,
Re: Scope of Practice feedback
Please accept this feedback on behalf of the DHB Midwife Leaders.
This feedback represents the majority view of the 20 DHB Midwife Leaders (Deb Pittam and Chris
Mal on both declared conflict of interest and therefore are exempt from this feedback). In preparing
this feedback the group has considered the aspirations of the Council and the CRG for a broader and
more comprehensive scope, alongside the realities of our current workforce and the exceptional
pressure we experience in providing safe maternity services to our communities.
Overal we are very supportive of the proposal to align the scope with Te Tiriti o Waitangi, and the
desire to pursue more equitable and cultural y safe midwifery care.
Our feedback draws attention to some concerns we have about the proposed changes and potential
unintended consequences that should be considered by Council. We then make some suggested
wording changes that may satisfy these concerns.
1. Expanding the scope to include al sexual health, al infant health, and al whānau health
significantly expands the role of the midwife and wil inevitably see midwives working
exclusively in these new fields. This wil lead to the dispersion of the workforce over the
scope of the role and wil result in fewer qualified midwives being available for pregnancy;
labour and immediate postnatal care, which has been the unique domain of a midwife.
Resulting in an increased risk to public safety.
2. Expanding the scope to include al sexual health, al infant health, and al whānau health
significantly expands the role of the midwife resulting in a much larger knowledge and skil s
base required to qualify. The impact of this is either to expand the undergraduate
programme to cover the new knowledge and skil s resulting in a significantly longer
undergraduate programme acting as a barrier to enrolment, or to accepting that midwives
wil be under-qualified at the point of registration with a consequent risk to public safety.
3. Expanding the scope to abandon time parameters for the role i.e. from preconception to six
weeks postpartum, leaves employed midwives vulnerable to redeployment into non-
maternity wards to fil nursing shortages. Resulting in staff disenfranchisement and
increased attrition, increasing risk to public safety.
4. Lack of clarity around what care can be provided on the midwife’s sole responsibility and
what can be provided as part of a wider health care team. This potential y creates problems
when practitioners step outside the intention of the scope and deliver care they are not
qualified to provide for example prescribing anti-hypertensives, or treating asthma. Similarly
it may give the impression that care is only delivered under the supervision and delegation
of a doctor.
5. The scope makes no mention of locations of care, this in the past has protected the right of
midwives to provide homebirth, and while this protection may not stil be needed, would it
be a problem to include this just to be on the safe side?
6. The use of the word whānau to replace the words woman and pregnant people was not wel
understood and is likely to be open to confusion. Whilst we understand that the CRG had a
high level of comfort with this term to be a generic term for pregnant people the word
whānau has a much wider use in Aotearoa and is therefore is likely to be open to significant
misinterpretation. Inevitably this confusion wil lead to a legal chal enge at some point in the
future.
The scope could be written as fol ows without changing the intent:
Te Tiriti o Waitangi is embedded in the practice of a kahu pōkai / midwife in Aotearoa New Zealand.
The kahu pōkai / midwife provides cultural y and clinical y safe care, drawing upon evidence to
enable wāhine / women / people sexual and reproductive health, preconceptual, pregnancy, birthing,
postnatal and infant health and wel being within the wahine journey from preconception to 6 weeks
postpartum on their own responsibility and in any context including home.
The Council may also wish to consider adding sexual health, infant health, and whānau health as an
extended scope with accompanying credentialing programme for those that wish to do this as occurs
with other workforces.
Yours sincerely
Carolyn Coles
National Chair, DHB Midwifery Leaders
