Consultation document lacked rigour.

The Nursing Council's consultation document on the title for second-level nurses trained after 2000 does not include a well-argued justification for either of the titles offered--nurse assistant (NA) or registered assistant nurse (RAN), according to NZNO's submission. Compiled by professional services manager Joy Bickley Asher, from members' contributions, the submission stated the consultation document made no allowance for proposing an alternative title and contained no well-argued justification for either of the titles. "A thoughtful discussion of what a nursing title actually means and an explanation of the rationale behind the selection of the two options would have been helpful," the submission stated.

The Nursing Council has received 145 submissions, from both organisations and individuals, which Marion Clarke said was a good response. The consultation process had been "extremely robust", she said.

NZNO's submission said members were concerned about public safety and current confusion around the titles. The Council's attempt to remove that confusion has had the opposite effect. The confusion and the accompanying shrinkage of scopes of practice had resulted in the loss of second-level nursing skills and knowledge. "NZNO EN and NA members have suffered financial, professional and personal damage," the submission states.

NZNO members had a range of views on the titles--support for the EN title for all and support for both NA and RAN. The arguments in favour of RAN were that it identified the person as a nurse; the holder was regulated and accountable; and it made it clear to members of the public that the holder was assisting registered nurses.

NZNO's submission said consultation on the title of the second-level nurse, "as designed and driven by the Nursing Council", had failed to produce a consensus on what the most appropriate title might be. Debate and discussion needed to be based on well-honed arguments and also on the rights of individuals and collectives to have their say. "The combination of these two processes will result in an enhanced level of decision making, while respecting the dignity of all nurses," the submission concluded.

In its submission, the national EN section committee called for the EN title for all second-level nurses. The submission criticised the Council's consultation processes throughout the debate and pointed out that the Council had never directly consulted with any ENs or NAs on the issue. The EN title was internationally recognised. A number of nursing bodies claimed the EN title was confusing but the NA title had caused confusion between the regulated and unregulated health workforce. The submission also called on the Council to show more support for ENs' experience; to reintroduce the former EN scope of practice; and to raise the level of the NA qualification on the New Zealand Qualifications Authority (NZQA) framework. It is currently at level 4. The Council with consider the analysis of the submissions at its March meeting. Clarke pointed out that, despite the title change from EN to NA for those trained post-2000, NAs were still qualifled to work as nurses in the field in which they were trained.

The Council would be considering the scope of practice issues and NZQA qualification level but did not have a timeframe for that as yet.