Deliberation on proposed amendments
to the Nurses Registration Ordinance (Cap 164)
7pm-10pm, 22 March 2023, Room 505B, The Legco Complex
On Licensing Examination:
1. Examination is the most objective and fair assessment of all. The pathway of admitting nurses via examination should be maintained even though new pathways are paved.
2. Having said that, the Nursing Council Licensing Examination is overly demanding on hard facts and lacking in applied nursing assessment. A major overhaul is needed. A revamped examination that assesses applied nursing care more accurately is expected to come with a much higher passing rate.
3. Means of assessment other than examination are possible and these can be explored.
On Importing Non-locally Trained Nurses:
1. Most agree that importing non-locally trained nurses are helpful to replenish manpower, at least in the short term. The cornerstone of human resources should still be local nursing education.
2. Locally trained nurses should be given priority over non-locally trained nurses in employment and specialist nurse training opportunity.
3. Mentoring will be an essential process in amalgamating non-locally trained nurses into the working community. As a reference, months are generally required for newly graduated locally trained nurses. Mentoring involves additional work for the middle-grade staff nurses, which may be unwelcoming when workload is already overwhelming.
4. Retention of staff and increased capacity for training of local nurses are proper means to address manpower insufficiency in the long run.
5. Nursing is a caring profession. Language should be considered.
On Limited Registration / Enrolment:
1. The vetting of credentials should be placed under the sole jurisdiction of the Nursing Council of Hong Kong, with or without consultation with local higher educational institutions that provide nursing programs.
2. As a prerequisite, applicants must have completed a form and duration of training like their counterparts in Hong Kong, and the curriculum should be comparable.
3. As an alternative, registration or enrolment by a renowned non-local regulatory body is acceptable provided that those regulatory bodies require their applicants to be conversant with specified core competencies.
4. Applicants must be of good standing.
5. If admission under this route is mainly for RCHs and other NGOs, where skills are top in the consideration, some consider that only EN should be included, while universities which may wish to employ non-locally trained RN should consider the Special Registration route instead. Others hold a somewhat different view that RN should also be included in the limited registration regime, as organizations such as HA or DH may also employ RN under limited registration.
6. Participants generally agree that 3-year or the employment period, whichever the shorter, is appropriate for a term of limited registration / enrolment.
7. Nurses working in a community setting such as RCH often work alone. They are expected to make independent decision and be capable of working alone without support from other healthcare staff. More rather than less experience is required of them.
8. Tertiary institutions with nursing schools may provide evening programs as a form of mentoring for nurses newly admitted to Hong Kong via Limited Registration.
9. The Limited Registration / Enrolment for a nurse may be renewed indefinitely provided he/she secures employment from the same employer. Consequently, the number of imported nurses will be cumulative. Job opportunity for locally trained nurses in the future may be impaired. The Government may consider setting annual quota which may be adjusted year on year depending on manpower need.
10. There should be in place mechanism to stop renewing Limited Registration / Enrolment when manpower becomes adequate, otherwise the employment opportunities of locally trained nurses may be impaired.
On Special Registration / Enrolment:
1. Admission criteria can be: (1) nursing school of graduation, (2) registered or enrolled with renowned non-local regulatory bodies with demonstrable core competencies acceptable to Hong Kong.
2. The curriculum of an applicant’s training must be comparable to that of Hong Kong.
3. The vetting of credentials must be placed under the sole jurisdiction of Nursing Council of Hong Kong.
4. Incoming nurses under the Special Registration should hold a Bachelor degree or at least an associate Bachelor qualification.
5. Applicants must be of good standing.
6. Most participants expressed deep concern of the validity of on-job assessment made by the employers. At least it must be a form acceptable to NCHK.
7. EN should be excluded from the Special Registration / Enrolment regime. EN manpower is adequately addressed by Limited Enrolment.
8. Apart from HA and DH, universities and tertiary educational institutions should be allowed to employ RN on Special Registration.
9. 6 Years is an acceptable period of working in the specified employment before granting full registration
10. An exit assessment should be in place to ensure the nurse is competent in general nursing. Full registration allows a nurse to practice generally and across all specialties, while he/she may only have worked in 1 – 2 specialties during the entire course of Special Registration.
11. The form and content of the exit assessment should be decided by the Nursing Council of Hong Kong, in consultation with local tertiary nursing institutions if appropriate.
12. An exit assessment similar to the practical part of the NCHK Licensing Examination, which comprises (1) wound dressing care, (2) administration of medicine and (3) health assessment is one example.
13. The Nursing Council of Hong Kong may exercise discretion in exempting the exit assessment on an individual basis.
14. Some proposes Special Registration should be a route reserved for Specialist Nurses. RN who are already Specialist Nurses may be admitted under the Special Registration and migrate to full Registration after a designated period of satisfactory performance. The Nursing Council of Hong Kong should be vested with the authority to vet whether the credentials of an applicant qualifies as Specialist Nurse, in consultation with the Hong Kong Academy of Nursing Ltd if necessary.
1. Nurses’ registration should not be segregated by employment. The schema has the undesirable effect of segregating nurses who work in the community from those in hospitals.
An Alternative Proposal:
1. Special Registration, one offered, has no turnback from a full registration unless the nurse scores unsatisfactory performance. An exit assessment provides remedy to a limited extent.
2. We therefore propose an alternative pathway as follows:
a. Universal entrance into the Limited Registration scheme
b. To be followed by migration to Special Registration scheme according to merit (say, after 4 years), this places a new check point before entrance into Special Registration.
c. The gate keeper should still be the Nursing Council of Hong Kong, in consultation with tertiary educational institutions if necessary.
d. On-job assessment of a form acceptable to NCHK may serve as additional reference.
e. Specialist Nurses, whose credentials are to be vetted by the Nursing Council of Hong Kong, in consultation with the Hong Kong Academy of Nursing Ltd if necessary, may enter the Special Registration scheme at any time.
f. RN (Specialist or non-Specialist) may apply for full Registration after a minimum of 2 years of Special Registration. The minimum period working under Limited or Special Registration before full Registration is 6 years.