Submission to the Department of Health: Independent Nursing & Midwifery Practice National Framework Proposal and ERB Alignment (2022–2026)

In December 2025, the Irish Association of Advanced Nursing and Midwifery Practitioners (IAANMP), in partnership with Dr Susan Kent of ArrowHealth, submitted Independent Nursing and Midwifery Practice: A National Framework Proposal to Empower the Profession and Strengthen the System to the Department of Health. The framework sets out a structured, evidence-informed approach to enabling independent nursing and midwifery practice under existing statutory authority and demonstrates alignment with the Expert Review Body (ERB) recommendations for the period 2022–2026.

The proposal is situated within the context of sustained pressure across the Irish health system, including rising chronic disease prevalence, emergency department overcrowding, delayed discharges and high levels of preventable hospital activity. These challenges persist despite the largest nursing and midwifery workforce to date, expanding advanced practice and prescribing capacity, and national data indicating that approximately one third of hospital admissions are preventable or nursing sensitive. Independent nursing and midwifery practice is already occurring across services, but without a nationally consistent pathway or governance structure.

Implementation of the framework does not require legislative change. Existing statutory provisions, including the Health Act 1970, the Nurses and Midwives Act 2011 and the Enhanced Nurse and Midwife Contract (2019), provide the legal basis for autonomous practice and direct contracting. The framework aligns with Sláintecare principles, the HSE National Service Plan 2025, the Programme for Government, Department of Health research priorities and the ERB report.

A central feature of the proposal is the operationalisation of ERB Recommendation 28 on the evaluation, development and implementation of independent practice models. More broadly, the framework advances ERB priorities relating to professional autonomy, leadership visibility, expansion of advanced practice, doctoral and research pathways, full utilisation of skills across integrated care, digitalisation, governance reform and contractual modernisation.

The evidence base underpinning the proposal draws on national data and existing Irish service models, including ANP and AMP led services, community specialist teams, minor injury units, maternity pathways and independent providers. Reported outcomes include hospital avoidance rates of 25–35 per cent, high levels of patient satisfaction, reductions in emergency presentations and readmissions, and positive social return on investment. The proposal discusses structural barriers, particularly restricted access to diagnostics and prescribing, which continue to limit both the full realisation of independent practice and the accurate capture of the clinical, system and economic impact of nursing and advanced practice nursing.

The proposed model establishes a whole-profession, three-tier continuum of autonomous practice at generalist, specialist and advanced levels. PCRS-enabled independent contracting would support tariff-based reimbursement, outcomes visibility, integrated diagnostic and referral pathways, and improved continuity of care. Leadership and governance proposals include the establishment of a Chief Nursing and Midwifery Officer role within the HSE, national DNP and DMP pathways, structured evaluation of 2026 pilots and a national indemnity framework.

A briefing was sent to the Chief Nursing Officer outlining the proposed framework. The briefing sets out the administrative actions required to progress implementation and seeks engagement to support ERB implementation, Sláintecare delivery and the national nursing and midwifery workforce strategy.

Full Document Submission

CNO_DOH Dec 2025 Independent Nursing and Midwifery Practice- A National Framework Proposal to Empower the Profession and Strengthen the System- A Response to the Expert Review Body on Nursing and Midwifery

 

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Mr. David Delaney

David is the newly elected Secretary. He currently works in the Emergency Department of University Hospital Limerick. David graduated from the University of Tasmania in Australia and started his career in cardiac care. From there he worked in the Intensive care units of the Royal Hobart Hospital, Tasmania, the Royal Prince Alfred, Sydney, St. James Hospital, Dublin and University Hospital Limerick. He is currently a Clinical Skills Facilitator in the Emergency Department of University Hospital Limerick. He has previously studied a postgraduate diploma in Intensive Care Nursing with NUI Galway and is currently in his dissertation year of this Masters in Advanced Nursing Care also with NUI Galway. David will be a registered Advanced Nurse Practitioner once his MSc is complete. David also holds a position on the student subgroup of the International Council of Nurses NP/APN network.