28 March 2022

To:          National Department of Health

Provincial Departments of Health

Private Health Care Providers     

All stakeholders

SUBJECT:      IMPAIRMENT COMMITTEE FINDINGS: POOR MANAGEMENT OF SCHEDULED SUBSTANCES/     MEDICINES IN HEALTH ESTABLISHMENTS

1. PURPOSE

• Share the findings/trends of the Impairment Committee (IC) regarding mismanagement of scheduled substances/medicines with the National Department of Health, Provincial Departments of Health, Private Health Care Providers and other relevant stakeholders.
• To remind Registered Nurses and/or Midwives of their role in managing scheduled substances/ medicines in health establishments in line with relevant policies and protocols.

2. BACKGROUND

• The IC is one of the standing committees established by the South African Nursing Council (SANC) in terms of section 51 of the Nursing Act, 2005 (Act No.33 of 2005). The Committee is appointed to manage practitioners who are registered in terms of section 31 (1) of the Act, who are deemed unfit to practice nursing due to disability or impairment. Most of the cases received by IC relate to abuse of scheduled substances/medicines. In dealing with these cases, the Committee has noted with concern the deteriorating vigilance in the management of scheduled substances/medicines in healthcare establishments, both public and private, which leads to abuse of these substances/ medicines by Health Care Professionals.
• On analysis of the reported cases, the IC established that practitioners had access to these substances/ medicines in any of the following ways:
• When Registered Nurses and/or Midwives issue and administer prescribed scheduled substances/ medicines alone.
• Scheduled substances/ medicines cupboard keys not kept in line with applicable policies.
• Scheduled substances/ medicines not co-checked during hand over and in every shift change, leaving discrepancies to go unnoticed.
• Counting and recording of the quantities of scheduled substances/ medicines administered not done in line with applicable institutional policies or common best practices

• Prolonged use of prescribed scheduled substances/ medicines, which leads to dependency. For example, Registered Nurses and/or Midwives who were involved in car accidents or have had major operations which lead to addiction and abuse.

3. TELL-TALE SIGNS OF NURSE PRACTITIONERS WHO MAY BE ABUSING SCHEDULED SUBSTANCES/ MEDICINES

The following are some of the warning signs that the nurse may be using or addicted to scheduled Substances or medicines:

• Scheduled substances/ medicines to be discarded kept in a syringe for no apparent reason;
• Registered Nurse and/or Midwife frequently borrowing scheduled substances/ medicines from other wards or visiting the wards/ healthcare establishments at awkward times;
• Registered Nurse and/or Midwife requesting colleagues to countersign in the register for scheduled substances/ medicines which they did not witness being dispensed;
• Inaccurate recording and questionable entries;
• Erasing or ‘overwriting’ of drug book entries, instead of following standard operating procedures;
• Registered Nurse and/or Midwife often volunteering to administer scheduled medications; and
• Registered Nurse and/or Midwife frequently offering to count scheduled substances/ medicines, to make sure the count is correct.

4. ROLE OF PRACTITIONERS IN MANAGEMENT OF SCHEDULED SUBSTANCES/ MEDICATIONS

• It remains the obligation of the Registered Nurse and/or Midwife to ensure that all scheduled substances/medicines are ordered, controlled, administered and disposed of in terms of the given protocols, policies and procedures of the institution.
• Registered Nurses and/or Midwives must ensure that Enrolled Nurses/Nursing Auxiliaries ARE NOT allowed to keep the keys to the controlled medicines and substance cupboard and to check and administer scheduled medicines alone.
• Scheduled medicines must be prescribed by a doctor except in emergency situations as per institutional protocol.
• Registered Nurses and/or Midwives are personally liable for all unprofessional conduct while performing their duties.
• The person in charge of the ward or nursing unit will remain accountable for all nursing care provided.

5. ROLE OF NURSE MANAGERS IN MANAGEMENT OF SCHEDULED SUBSTANCES/ MEDICATIONS

• Nurse Managers must develop and implement policies and procedures with regards to the ordering, safe keeping and administration of scheduled substances/ medicines.
• There should be strict monitoring of compliance to policies and procedures to assist Nurse Managers to prevent possible addiction and/or abuse.
• Nurse Managers must report incidences of alleged addiction or abuse to the SANC, so that the alleged practitioner is managed under the Impairment Programme, failure of which, the Nurse Manager will be charged for unprofessional conduct.

6. The contents of this circular must be brought to the attention of all practitioners and all managers in all health establishments.

7. For further information in respect of this circular, kindly contact Dr NJ Muswede, Senior Manager: Professional Practice at jmuswede@sanc.co.za or Tel: 012 420 1008.

Yours sincerely,

(signed)

MS SA MCHUNU                                                                                                    DATE

REGISTRAR AND CEO

SOUTH AFRICAN NURSING COUNCIL

23 March 2022

To:          National Department of Health

Provincial Departments of Health

Nursing Education Institutions (NEIs)    

All stakeholders

SUBJECT: ARTICULATION FROM THE LEGACY TO THE HIGHER EDUCATION QUALIFICATIONS SUBFRAMEWORK (HEQSF) – ALIGNED NURSING QUALIFICATIONS

1          PURPOSE

1.1       The purpose of this circular is to provide information to the National Department of Health, Provincial Departments of Health, Nursing Education Institutions (NEIs) and other relevant stakeholders on the engagement between the South African Nursing Council (SANC) and the Council on Higher Education (CHE) regarding articulation possibilities from the legacy to the HEQSF- aligned nursing qualifications.

2          BACKGROUND

2.1       Transformation in education, specifically higher education in South Africa which is spearheaded by the Minister of Higher Education and Training, has necessitated transformation in all earning fields, including Nursing Education. The introduction of the HEQSF, as part of South Africa’s National Qualifications Framework, created a need to align the Nursing qualifications with the HEQSF. There was a conscious decision by the nursing profession that all nursing qualifications should be under higher education for ease of progression and articulation.

2.2       The SANC has throughout the years since 2010 shared progress about the transformation with National Department of Health, Provincial Departments of Health, Nursing Education Institutions (NEIs) and other relevant stakeholders, including unions, in various platforms e.g. circulars, SANC electronic news, SANC stakeholder forums meetings, Nursing Indaba and workshops etc.

2.3       In 2016, the Minister of Higher Education and Training, in line with the provision of the Higher Education Act, 1997 (Act 101 of 1997, declared through a notice published in a gazette, that the last enrolment date for the first-time entering students into academic programmes that are not aligned to the Higher Education Qualifications Sub-framework (HEQSF) was 31 December 2019. It therefore meant that the legacy programmes, including legacy nursing education programmes will no longer be offered after this date except to complete the pipeline students.

2.4       The minimum requirements for admission to higher education are prescribed by the Minister of Higher Education and Training and not the SANC. In terms of the Higher Education Act of 1997 as amended, the decision to admit a student to higher education is the right and responsibility of the higher education institution, herein referred to as Nursing Education Institutions.

2.5       The Department of Higher Education and Training, through the Council on Higher Education (CHE), has further made determinations regarding progression (career-pathing) to be followed by persons who undergo the HEQSF-aligned qualifications. However, a clear articulation pathway from legacy qualifications to the new HEQSF-aligned qualifications is not yet determined. This is negatively affecting nurses who underwent the legacy qualifications but may not meet the minimum requirements to access the new HEQSF-aligned qualifications. This has highlighted the importance of initiating a discussion about articulation with the CHE.

3          PROGRESSION AND ARTICULATION

3.1       To mitigate the anticipated challenge, the SANC conducted a three-day workshop from 3-5 March 2021, whose purpose was to identify similarities and differences between the legacy and HEQSF-aligned nursing qualifications in order to determine if there were gaps in learning content between the old and the new qualifications, and if there were, what would it take to bridge them. Nursing Education and Training stakeholders were represented. The findings were to assist SANC in mapping out articulation pathways for the nurses who underwent the legacy qualifications.

3.2       The report of the findings of the workshop, including recommendations, was presented and approved by Council of the SANC. The Council further resolved that the recommendations should be discussed with the Council on Higher Education (CHE) since CHE is the Quality Council for Higher Education.

3.3       Much as there have been several engagements held between SANC and CHE about the proposed recommendations on articulation pathways, no concrete agreements have been reached regarding the matter, especially regarding the access to the post-graduate diploma programmes by nurses who underwent the four-year diploma programme from Public Colleges of Nursing; and access by nurses who underwent Bridging programme for Enrolled Nurses with a Midwifery qualification. The agreement was that once the decision had been reached, the Nursing Education Institutions would be informed formally. The SANC was hoping that by this time a conclusion would have been reached, however this is not the case.

3.4     Progress will be provided as and when there are agreements that are reached.

For further information in respect of this Circular, you are advised to contact Ms SJ Nxumalo, Acting Deputy Registrar: Professional Affairs at (012) 420 1022 or on e-mail at: jnxumalo@sanc.co.za

Yours sincerely,

(signed)

MS SA MCHUNU                                                                                                    DATE

REGISTRAR AND CEO

SOUTH AFRICAN NURSING COUNCIL