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7 December 2007 
						Susan Yorke 
						Registrar 
						Midwifery Council of New Zealand
				
				
						Dear Susan
				
		
		
				
						Consultation on the Midwifery Council Fees for the 
						2008/2009 year
				
		
		
				Thank your for the opportunity to participate in the consultation process. 
				We have discussed the issues with our members    and prepared this response 
				based on their views. 
				It appears three essential matters are to be considered. These are: 
				MSR fee subsidy 
				Fees for additional services 
				Disciplinary levies 
				We have considered each in turn and comment as follows.
		
		
				
						MSR 
				
		
		We have considered the points raised in the Council’s 
		discussion paper. We note NZCOM have set the standard 
		MSR fee at $530 for the current year. We have checked and 
		we have been advised the fees payable to reviewers are $40 per 
		review, plus mileage after the first 30 kilometres plus 
		childcare costs if incurred. So far as we have been able to 
		check, this equates to an average of $70 per reviewer per 
		review or $140 per review. Admittedly there will be some 
		variation in these costs but we cannot see how these costs could exceed, on 
		average, $200 per review.
		
				Naturally, there will be some administration costs per review. Based on a full 
				time staff member at say, $45,000 per annum plus overheads at 30% of gross 
				salary, the total costs would be in the region of $58,500.
		
		
				With approximately 1,000 LMC midwives and 1,500 core midwives, the total 
				number of reviews each year would be in the region of 1,500 based on an 
				annual review for each LMC and a three yearly review for core midwives. 
				That gives a cost per review for administration of around $40, making a total 
				of $240 per review. It is extremely difficult to see how an annual fee of $530 is 
				justified, even allowing for the need to make provision for future 
				development of the review process and the need to provide training for 
				reviewers.
		
		
				We note the Council proposes to continue it’s policy of subsidising the cost 
				of MSR. We note the effect of the subsidy of MSR for core midwives largely 
				benefits the DHBs and other employers. We also note it is these 
				organisations which pay the annual practicing certificate fee for the 
				employed midwives.
		
		
				Effectively, the subsidy on the MSR fee is a rebate back on the annual 
				practicing certificate fee for all midwives. In discussions with our members, 
				it was very apparent there is a definite lack of clarity and understanding
				around this issue, particularly amongst LMC midwives whose attention 
				focuses rather more on what they perceive to be a high annual practicing 
				certificate fee.
		
		
				We note NZCOM may choose to reduce the MSR fee paid by members. This 
				is, of course, entirely their decision and may encourage midwives to join or 
				retain their membership although, again, this effective subsidy appears to be 
				not well understood by midwives. We consider the issue would benefit from 
				a great deal more clarity and better understanding amongst 
				midwives.
		
		
				We suggest a better approach, more transparent and less 
				likely to lead to misunderstanding would be for Council to 
				cease subsidising the cost of the MSR and reduce the annual 
				practicing certificate fee accordingly. NZCOM would then charge the 
				unsubsidised cost of the MSR of, based on the discussion paper, $450.
				Financially, for all parties– Midwifery Council, NZCOM, DHBs, other employers and midwives–there would be no difference at all. However therewould be far better understanding amongst all parties of just what money was going where and for what purpose.
		
				
						Fees for additional services
						 
				
		
		We have considered the fees as outlined in the table in the discussion
		document. While we would generally support a “user pays” approach, we can
		appreciate it may be appropriate to effectively subsides fees in some
		circumstances. For example, we can understand how, given the current
		shortage of midwives nationally, the Council may see it as appropriate to
		undercharge for registration by a new graduate, given the
		new graduate has not had the opportunity to benefit
		financially from their new qualification and is almost
		certainly holding a substantial student loan. However, we
		do feel some fees could be adjusted as follows:
		
				
						
								Registration by an overseas midwife 
						
				
		
		Overseas midwives are generally recruited by DHBs and
		other employers and the costs of New Zealand
		registration are a cost of that recruitment, borne by the
		employer. We suggest the fee could be significantly
		increased to greater reflect the cost of such registrations.
		We suggest a fee of $1,333.33 plus GST would be more
		appropriate.
		
				
						
								Application to re 
						
						‐ sit the National Midwifery Exam 
				
		
		We suggest the fee for re 
		
				‐ 
				sitting the exam should be
				 
		
		higher than for a first attempt to reflect the increased cost
		 
		to the Council. We suggest a fee of $266.67 plus GST
		 
		would be appropriate. Alternatively, the fee to sit the
		 
		exam could remain the same with an additional fee
		 
		payable to re
		‐ sit. 
		
				
						
								Reconsideration of exam result 
						
				
		
		We suggest the fee should be much closer to the cost of
		 
		the service. A fee of around $266.67 plus GST would seem
		
				more appropriate 
		
		
				
						
								Sit exam at another NZ venue
						
				
				 
				We suggest the fee should at least cover the costs of this service, especially
				as the differential is small.
		
		
				The changes we suggest would not make much difference to the overall
				financial position of the Council but would move some costs to the users of
				the services and may allow some small lessening of the annual practising fee.
		
		
				We support the Council’s policy of discounting the fees payable for a New
				Zealand graduate for their first full year practising certificate as entirely
				appropriate. We also support the Council’s policy of reducing annual
				practising certificate fees each quarter. We suggest there should be a
				minimum fee payable regardless of when the fee is paid, say $100, with the
				balance of the fee being reduced by a quarter each quarter. This would
				recognise the Council incurs similar costs regardless of when the fee is paid.
		
		
				
						Disciplinary Levy
						 
				
		
		While we understand the view of the Council in spreading the costs relating
		to the Professional Conduct Committee and the Health Practitioners
		Disciplinary Tribunal across the profession, we are concerned regarding
		costs which may be incurred for the disciplinary proceedings in respect of
		members of the profession who have not engaged in the re
		
				‐ 
				certification
		
		programme.
		
				We suggest it would be appropriate in at least these cases for some of the
				costs of proceedings to be charged to members against whom such
				proceedings are being taken. The extent to which the costs could be
				recovered is open to debate but it is felt midwives who have not engaged in
				the programme have effectively avoided incurring the costs which have been
				incurred by others who have engaged in the programme and therefore have
				obtained a financial benefit from their lack of engagement. On those
				grounds it would seem appropriate, unless there is good cause not to do so,
				for an appropriate financial penalty to be imposed.
		
		
				Thank you for the opportunity to contribute and we hope 
				our comments are useful
		
		
				
						Yours sincerely
						 
						Tony Mansfield
						 
						Chief Executive