Nurses Expose Critical Loopholes in the 2026 Healthcare Regulatory Bill and Push for Revision

 Nurses under the auspices of the University Graduates of Nursing Science Association (UGONSA) have identified critical loopholes in the proposed 2026 Healthcare Regulatory Bill and have formally engaged the leadership of the National Assembly to demand urgent legislative review. This engagement was conveyed through a comprehensive memorandum, Ref No. UG/NAT/26/NIG/NASS/01 dated April 08, 2026,
addressed to the President of the Nigerian Senate and the Speaker of the House of Representatives, with copies forwarded to the Chairmen of the Senate and House Committees on Health.   Below is the details of the memo:

 

The Senate President/Speaker, House of Representatives

National Assembly Complex
Three Arms Zone
P.M.B. 141
Abuja, Federal Capital Territory

Your Excellency, Sir,

Re: Legislative Review and Proposed Amendments – 2026 Healthcare Regulatory Bills

We respectfully submit this memorandum highlighting critical provisions in the 2026 Healthcare Regulatory Bills that may undermine professional autonomy, encourage quackery, and disrupt interdisciplinary healthcare governance in the Nigerian health system. While these Bills aim to modernize healthcare regulation, certain provisions, especially within the  Nursing and Midwifery Council of Nigeria (NMCN) and the Medical and Dental Council of Nigeria (MDCN)  frameworks, pose significant risks to professional autonomy, equity, and interdisciplinary collaboration in Nigeria’s healthcare system. A detailed review of the Bill confirms that, unlike the Pharmacy Council of Nigeria (PCN) Bill, the NMCN Bill fails to explicitly require that the Chairman be a registered Nurse or Midwife. This omission creates a legal loophole that could allow non-nursing professionals or external appointees to lead the NMCN, a highly specialized professional regulatory body. Again, unlike the Medical and Dental Practitioners Bill , 2026 (MDCN), the NMCN Bill does not contain any explicit provisions addressing quackery, unlawful practice, impersonation, or institutional liability. This omission significantly weakens the regulatory authority of the NMCN and exposes the nursing and midwifery profession, and by extension, public safety, to grave risks. The Nursing and Midwifery Council of Nigeria Bill also prioritizes reducing Council size without safeguarding proportional and sectoral representation. Unlike the Pharmacy Council of Nigeria Bill and Medical and Dental Practitioners Bill, it risks excluding critical voices from clinical, academic, and regulatory sectors. This weakens policy quality, reduces professional influence, and exposes governance to dominance by narrow or external interests.

Section 4(1) of the National Hospital for Women and Obstetric Fistula (Establishment) Bill, 2026, which sets out the composition of the Management Board of the Hospitals, equally raises a serious concern regarding equity in professional representation. As presently framed, the Board includes a part-time Chairman, the Medical Directors of the hospitals (who are all Medical Doctors), the Federal Chief Nursing Officer, one representative of the medical profession, one representative of other health professions, and two persons representing community interests. This arrangement creates a clear structural imbalance by allocating multiple seats to the medical profession, while all other health professions are compressed into a single shared seat. Such a composition is neither equitable nor reflective of the multidisciplinary nature of fistula prevention, treatment, rehabilitation, and long-term care. Effective management of women’s health and obstetric fistula requires meaningful input from nursing, pharmacy, physiotherapy, laboratory science, counselling, social work, and other allied professions. Concentrating representation in favour of one profession undermines inclusive governance, weakens interdisciplinary collaboration, and risks marginalizing key contributors to patient care. Because Board decisions are determined by majority, this imbalance could translate into institutional dominance by one profession, to the detriment of balanced policy development and holistic service delivery. The Bill should therefore be amended to ensure separate and adequate representation for major healthcare professions, including explicit inclusion of Heads of Nursing Services of the Hospitals in the Boards. This will promote fairness, strengthen governance, and improve patient outcomes through broader professional participation in decision-making.

The Bill as currently drafted also appears to confer expansive and exclusive regulatory powers on the MDCN over areas that are legally and professionally governed by other statutory bodies. Some provisions, particularly those assigning authority “to the exclusion of any other person or body”, risk creating institutional monopoly, suppressing interdisciplinary collaboration, and undermining existing regulatory frameworks. Healthcare delivery is inherently multidisciplinary. No single profession should dominate or regulate others. Doing so not only violates principles of professional autonomy and fairness but weakens the entire health system. Nigeria already operates a well-established structure of professional regulation, including, the Nursing and Midwifery Council of Nigeria (NMCN), Pharmacy Council of Nigeria (PCN), Medical Laboratory Science Council of Nigeria (MLSCN), among others. Allowing one profession to assume control over others would create legal conflicts between Acts of Parliament, undermine professional development, reduce morale among healthcare workers and negatively impact patient outcomes. We are therefore calling for the removal of monopoly clauses, protection of jurisdiction of existing regulatory councils, establishment of interprofessional regulatory frameworks and inclusion of all core healthcare professions in governance structures. Nigeria’s healthcare system can only grow to world-class standard when it is driven by collaboration, mutual respect, and shared responsibility rather than subjugation and professional domination.

Issue Overview

 The Nursing and Midwifery Council Bill (NMCN), 2026 does not specify that the Chairman must be a Nurse or Midwife, unlike the Pharmacy Council Bill which clearly restricts leadership to pharmacists. The Nursing and Midwifery Council of Nigeria Bill lacks a Vice Chairman, risking leadership gaps, instability, and external interference unlike the Medical and Dental Practitioners Bill. The NMCN Bill also reduces Council size without ensuring sectoral representation, risking weak governance, poor policy decisions, and dominance by narrow or external interests. Furthermore, the NMCN Bill lacks provisions criminalizing quackery, protecting professional titles, and holding institutions accountable—unlike the Medical and Dental Practitioners (2026) (MDCN) Bill. This gap enables unqualified practice, increases public risks, increases maternal and neonatal risks, weakens enforcement, and erodes public trust. A new provision should prohibit unregistered practice, protect titles (Nurse/Midwife), criminalize impersonation and fraudulent registration, and impose penalties on individuals and institutions employing unqualified personnel, with strong enforcement powers for the NMCN. In addition, the Medical and Dental Practitioners Bill, 2026 introduces provisions that expand MDCN’s authority into multidisciplinary domains and establishes exclusive regulatory control over areas already governed by other statutory councils. This raises concerns regarding regulatory overreach and structural imbalance within the healthcare system. Section 4(1) of the National Hospital for Women and Obstetric Fistula Bill creates a governance imbalance by allocating multiple seats to the medical profession while all other health professions share a single representative. This undermines equity and fails to reflect the multidisciplinary nature of fistula care. Since Board decisions are by majority, it risks dominance by one profession and marginalization of others.

Why This Matters

The absence of leadership qualification safeguards and lack of succession plan for the chairman for the NMCN bill creates a legal loophole that may allow non-nurses to regulate the nursing profession. The NMCN Bill cuts Council size without guaranteed representation, risking professional marginalization, poor decisions, and external control over the largest healthcare workforce. Excluding quackery provisions from the Nursing and Midwifery Council of Nigeria Bill endangers patients, weakens regulation, and enables unsafe practice. Strong criminalization is essential to protect lives, ensure accountability, and uphold standards. Moreover, healthcare delivery depends on teamwork, specialized expertise, mutual professional respect and autonomy. Any attempt to centralize authority on the MDCN or skew board membership in favour of the medical profession weakens collaboration, creates institutional conflict, and reduces system efficiency.

Key Concerns

Mandatory Requirement for a Nurse/Midwife as Chairman of the Council

The absence of professional qualification requirement for Chairman in the NMCN Bill forms a critical governance gap. This omission constitutes a serious governance, legal, and professional risk that must be urgently addressed in the interest of fairness, patient safety, and regulatory integrity. A professional regulatory Council must be led by members of the profession it regulates. This principle is consistent with global best practices in professional governance and is essential for maintaining credibility, accountability, and informed decision-making. Nursing and midwifery regulation requires deep experiential knowledge of clinical care, education, ethics, and workforce realities in the profession—competencies that can only be meaningfully provided by qualified and experienced practitioners within the profession. The failure to enshrine this requirement in law undermines the autonomy and independence of nursing and midwifery practice. It exposes the profession to potential external influence, weakens internal governance structures, and risks policy decisions that may not align with the realities of patient care. Ultimately, such a gap may compromise regulatory effectiveness and adversely affect patient outcomes. Moreover, this omission raises significant constitutional concerns regarding equity, fairness, and non-discrimination. Allowing other professional councils to be led exclusively by members of their own profession while denying nursing and midwifery the same standard creates an unequal and unjust regulatory framework.

Recommended Amendment: To safeguard professional integrity and ensure effective regulation, the Bill should be amended to include that the NMCN Borad Chairman MUST be a Registered Nurse or a Registered Midwife.

Suggested legislative wording: “The Chairman of the Council shall be a registered nurse or midwife with not less than fifteen (15) years post-registration experience and demonstrable leadership within the profession. No person who is not duly registered under this Act shall be eligible for appointment as Chairman of the Council.”

 Weak Governance and Succession Structure in the NMCN Bill

Unlike the Medical and Dental Practitioners (2026) (MDCN) Bill, which expressly provides for the office of a Vice Chairman and thereby creates a clear line of internal succession, the Nursing and Midwifery Council of Nigeria (NMCN) Bill appears to lack a similarly defined governance and succession framework. This omission creates a structural weakness in the administration of the Council. Without a clearly designated officer to act in the absence, incapacity, removal, or vacancy of the Chairman, the Council may be exposed to leadership uncertainty, administrative disruption, and avoidable external interference in its internal affairs. Such a gap is particularly concerning in a professional regulatory body that is expected to maintain continuity, institutional stability, and professional independence. A bill establishing a major professional council should not leave questions of succession to discretion or improvisation. Where succession is not expressly provided for, there is a greater risk that external authorities may influence interim leadership arrangements in ways that could undermine professional autonomy.

Recommended Amendment: The NMCN Bill should be amended to expressly provide for the office of a Vice Chairman, drawn from registered senior members of the nursing and midwifery profession, who shall act whenever the Chairman is absent or when the office becomes vacant pending the appointment or election of a substantive replacement.

Suggested legislative wording:  “There shall be a Vice Chairman of the Council who shall be a registered nurse or midwife of not less than 15 years post-qualification experience, and who shall perform the functions of the Chairman whenever the Chairman is absent, unable to act, or where the office of the Chairman becomes vacant pending the appointment of a new Chairman.”

Reduction of Nursing Representation in the NMCN Bill

The proposed amendment to the Nursing and Midwifery Council of Nigeria (NMCN) Bill emphasizes a reduction in the size of the Council without establishing safeguards for proportional and sectoral representation within the nursing profession. This approach contrasts with the Pharmacy Council of Nigeria (PCN) bill, which maintains strong professional dominance, and the Medical and Dental Practitioners (2026) (MDCN) bill, which retains broad representation from multiple professional associations. By focusing primarily on numerical reduction rather than balanced representation, the NMCN Bill risks creating a governance structure that does not adequately reflect the diversity of the nursing profession, especially across clinical practice, academia, administration, and regulatory leadership. Reduced representation diminishes the ability of nurses and midwives to effectively shape policies affecting their profession. Failure to ensure representation from clinical, academic, and regulatory sectors undermines comprehensive decision-making. Furthermore, a smaller, non-representative Council may become susceptible to dominance by a narrow group or external interests.

Recommended Amendment: To ensure equity, inclusiveness, and professional integrity, the Bill should incorporate minimum representation thresholds for members of the Nursing and Midwifery professions.

Suggested Legislative Provision: “Not less than seventy percent (70%) of the members of the Council shall be registered nurses and midwives, drawn from diverse areas of practice including clinical services, academia, administration, and professional associations, with due consideration for experience and professional standing.”

Proposed Insertion of a quackery section in the NMCN Bill

Insertion of new section — Offences relating to quackery and unlawful practice

(1)  No person other than a person duly registered and licensed under this Act shall—
(a) for, or in expectation of reward, practise or hold himself or herself out to practise as a nurse, midwife, nurse practitioner, or in any other nursing or midwifery capacity recognised under this Act;
(b) take or use the title “Registered Nurse”, “Nurse”, “Midwife”, “Registered Midwife”, “Nurse Practitioner”, or any abbreviation, initials, addition, description, uniform, badge, insignia, seal, or device implying that he or she is authorised by law to practise nursing or midwifery in Nigeria; or
(c) without reasonable excuse, use any name, title, description, document, stamp, prescription form, professional identification, or representation implying that he or she is qualified, registered, licensed, or authorised to practise nursing or midwifery under this Act.

(2) A person who contravenes subsection (1) of this section commits an offence and is liable on conviction—
(a) in the case of a first offence, to a fine of not less than ₦1,000,000 or to imprisonment for a term of not less than one year, or to both; and
(b) in the case of a second or subsequent offence, to a fine of not less than ₦2,500,000 or to imprisonment for a term of not less than two years, or to both.

(3) Any person who, for the purpose of procuring registration, enrolment, licensing, renewal of licence, or entry of any qualification or other matter under this Act—
(a) makes a statement which is false in any material particular;
(b) submits a forged, altered, fraudulently obtained, or misleading certificate, licence, transcript, testimonial, or other document; or
(c) impersonates a registered nurse or midwife, commits an offence and is liable on conviction to a fine of not less than ₦1,000,000 or imprisonment for a term of not less than two years, or to both.

(4) Any person employed by the Council or by any institution who knowingly makes or permits any falsification in any register, roll, licence, record, or official document relating to registration or practice under this Act commits an offence and is liable on conviction to a fine of not less than ₦1,500,000 or imprisonment for a term of not less than two years, or to both.

(5) Where an offence under this section is committed by a body corporate, hospital, clinic, maternity home, school, agency, or other institution, and it is proved that the offence was committed with the consent or connivance of, or is attributable to any neglect on the part of, any chairman, chief executive, chief medical director, medical director, director of nursing services, manager, matron, secretary, proprietor, or other principal officer of that body, such officer and the body corporate shall be deemed to be jointly and severally guilty of that offence and shall be liable to be prosecuted and punished accordingly.

(6) Any person who knowingly employs, engages, presents, deploys, or retains an unregistered or unlicensed person to practise, perform, or offer nursing or midwifery services commits an offence and is liable on conviction—
(a) to a fine of not less than ₦2,000,000;
(b) to imprisonment for a term of not less than one year; or
(c) to both such fine and imprisonment.

(7) For the purposes of subsection (6), a person shall be deemed to have knowingly employed or engaged an unregistered or unlicensed person where that person failed to carry out reasonable verification of the individual’s registration and current practising licence status with the Council.

(8) In addition to any criminal liability under this section, the court may order—
(a) closure or suspension of the hospital, school, unit, facility, or establishment in which the offence occurred, pending compliance with this Act;
(b) forfeiture to the Council of any forged licence, identification, stamp, seal, badge, or document used in committing the offence; and
(c) publication of the conviction in such manner as the court or the Council may determine.

(9) The Council may collaborate with law-enforcement agencies and other relevant regulatory authorities for the investigation, prosecution, and suppression of quackery in nursing and midwifery practice.

Proposed Amendment to the Composition of the Management Board – National Hospital for Women and Obstetric Fistula Bill, 2026

The Bill grants multiple seats to Medical Directors (one per hospital), all of whom are medical doctors; Provides only one seat for all other healthcare professions combined, including nursing, pharmacy, physiotherapy, and laboratory science. This results in disproportionate dominance by one professional group; marginalization of other critical healthcare stakeholders; and a governance structure that does not reflect the multidisciplinary nature of fistula care. Board decisions are made by majority vote, and quorum is relatively small. A professionally skewed board can systematically pass decisions without meaningful input from other healthcare disciplines. This undermines fairness, inclusiveness, and technical robustness in policy decisions.

Proposed Replacement of Section 4(1): Delete Section 4(1)(e): “a representative of other health professions”.

Substitute With the Following Provision:  “(e) one representative each from the following healthcare professions: (i) Nursing and Midwifery; (ii) Pharmacy; (iii) Medical Laboratory Science; (iv) Medical Rehabilitation/Physiotherapy; (f) the Heads of Nursing Services of the respective Hospitals.

The full proposed Revised Board Composition in Section 4(1) should read:

The Board shall consist of:

(a) a part-time Chairman;

(b) the Medical Directors of the Hospitals;

(c) a representative of the Federal Ministry of Health not below the rank of Assistant Director;

(d) one representative of the medical profession;

(e) one representative each of: Nursing and Midwifery, Pharmacy, Medical Laboratory Science, Medical Rehabilitation/Physiotherapy

(f) the Heads of Nursing Services of the respective Hospitals

(g) two persons nominated by the Minister of Health to represent community and patient interests, including women’s health advocacy.

Regulatory Overreach in the Medical and Dental Practitioners (2026) (MDCN) Bill

The Bill grants MDCN authority over Laboratory Sciences, Genetic Testing, Aesthetic Practice, Alternative Medicine Practice, and Assisted Reproductive Technologies. These areas are multidisciplinary fields and areas already regulated by other councils.

Monopoly Clause in the MDCN Bill

The phrase “to the exclusion of any other person or body” creates regulatory monopoly, suppression of other professions and risk of abuse of power.

Risk of Constitutional Breach in the MDCN Bill

The Bill, in its current form, raises significant constitutional concerns under the Constitution of the Federal Republic of Nigeria 1999, particularly in the area of equality and non-discrimination . This is because the Bill appears to create a disproportionate regulatory advantage for one healthcare professional group over other duly recognized healthcare professions. This portends a serious concern under Section 42 of the Constitution, which guarantees freedom from discrimination on the basis of status, association, or profession. By subjecting multiple independent healthcare professions to the oversight or control of a single profession, the Bill risks institutionalizing professional inequality, undermining the legal standing of other healthcare regulatory bodies and creating a biased hierarchy not supported by constitutional principles. If not amended, such provisions may constitute an official endorsement of discrimination, as they fail to uphold equal recognition and autonomy of all healthcare professions within Nigeria’s legal framework.

Policy Position

We strongly affirm that each healthcare profession must be regulated by its own independent statutory body, constituted and governed by members of that profession, in accordance with global best practices and the equity and fairness principles enshrined in the Constitution of the Federal Republic of Nigeria 1999. Professional self-regulation is fundamental to preserving professional autonomy and identity, ensuring context-specific standards of practice and ethics, promoting accountability through peer-based oversight, and safeguarding the quality and safety of patient care.

 

 

 

Problematic Sections in the Medical and Dental Practitioners (2026) (MDCN) Bill That Need Amendment

SECTION 8(1) – “Exclusion Clause”

Current Issue: “to the exclusion of any other person or body…”  This creates absolute monopoly control.

Amendment Type Demanded: DELETE & REPLACE

Proposed Amendment: Delete “to the exclusion of any other person or body” and replace with “in collaboration with relevant statutory professional regulatory bodies”

SECTION 8(1)(f) – Alternative Medicine Control

Current Issue: Medical and Dental Council of Nigeria (MDCN) assumes control over alternative medicine, which is outside its core mandate.

Amendment Type Demanded: MODIFY

Proposed Revision: “Collaborate with relevant regulatory bodies responsible for complementary and alternative medicine in Nigeria to ensure standards of practice.”

SECTION 8(1)(g) – Clinical Laboratory/Pathology Control

 Current Issue: MDCN regulating “clinical laboratory practice… haematology, microbiology, clinical chemistry…” This directly infringes on MLSCN authority.

 Amendment Type Demanded: DELETE & REPLACE

Proposed Revision: DELETE entire paragraph (g) and REPLACE WITH “Medical practitioners involved in pathology shall operate within the clinical scope of medicine; however, all laboratory diagnostic services shall be regulated by the Medical Laboratory Science Council of Nigeria.”

SECTION 8(1)(h) – Assisted Reproductive Technology (ART)

Current Issue: Exclusive control over Assisted Reproductive Technologies (ART) (a multidisciplinary field)

Amendment Type Demanded: MODIFY

Proposed Revision: “Supervise and regulate assisted reproductive technology in collaboration with relevant professional bodies, including nursing, pharmacy, medical laboratory science, and other allied professions involved in reproductive health services.”

 

SECTION 8(1)(j) – Genetic Testing & Personalized Medicine

Current Issue: Unilateral control over a scientific, multidisciplinary field

Amendment Type Demanded: MODIFY

Proposed Revision: “Regulate medical aspects of genetic testing and personalised medicine in collaboration with relevant scientific and healthcare regulatory bodies.”

SECTION 8(1)(k) – Aesthetic Practice Regulation

Current Issue: Excludes nurses, pharmacy, medical laboratory science, and allied professionals from aesthetic practice

Amendment Type Demanded: MODIFY

Proposed Revision: “Develop guidelines for aesthetic medical practices in collaboration with relevant professional regulatory bodies whose members are involved in such practices.”

SECTION 8(2)(c) – Repetition of Laboratory Control

Current Issue: Reinforces MDCN dominance over Medical Laboratory Sciences

Amendment Type Demanded: DELETE

 Proposed Revision: DELETE Entire subsection 8(2)(c)

SECTION 8(2)(a) – Policy Control

Current Issue: “provide general policy… relating to the practice of medicine and dentistry”. This is acceptable only if limited to its scope, but risky if interpreted broadly.

Amendment Type Demanded: MODIFY

Proposed Revision: “Provide general policy and guidelines relating strictly to the practice of medicine and dentistry, without prejudice to the statutory roles of other healthcare regulatory bodies.”

SECTION 21 – Approval of Courses & Institutions

Current Issue: MDCN given broad power to approve training institutions—potential spillover into other professions

Amendment Type Demanded: MODIFY

Proposed Addition: “Provided that this authority shall not extend to training programmes or institutions regulated by other statutory healthcare professional councils.”

NEW CRITICAL SECTION TO BE INSERTED

Amendment Type Demanded: INSERT NEW SECTION

Title: Professional Autonomy Clause and Interprofessional Collaboration Framework

Proposed Text: “Notwithstanding any provision of this Act, no healthcare profession shall be placed under the regulatory authority of another profession. Each profession shall be independently regulated by its statutory council established by law. Where any aspect of healthcare practice involves multiple professions, regulatory oversight shall be exercised through a collaborative framework involving all relevant professional councils.”

LEGAL BASIS FOR AMENDMENTS

This proposal is supported by existing Nigerian laws, which recognize and uphold the principle of independent and autonomous professional regulation across the healthcare sector, including: Medical Laboratory Science Council of Nigeria Act (Cap M25 LFN 2004); Nursing and Midwifery (Registration, etc.) Act (Cap N143 LFN 2004); Pharmacy Council of Nigeria Act (Amended 2022) and National Health Act (2014). These laws establish independent regulatory authority for each profession, which must not be overridden.

Conclusion

The 2026 Healthcare Regulatory Bills contain critical structural and legal flaws that threaten professional autonomy, patient safety, and effective healthcare delivery in Nigeria. The Nursing and Midwifery Council of Nigeria (NMCN) Bill weakens its own profession by failing to mandate that leadership (Chairman)  be drawn from nursing, lacking a clear succession structure, omitting anti-quackery provisions, and reducing council size without ensuring fair representation. These gaps expose the profession to external control, unsafe practices, and poor governance. Conversely, the Medical and Dental Practitioners Bill (MDCN) expands its authority beyond its core mandate, introducing monopoly-like provisions that encroach on other healthcare professions. This risks institutional dominance, suppresses interdisciplinary collaboration, and conflicts with existing regulatory laws. Additionally, governance structures such as the Board composition in the National Hospital for Women and Obstetric Fistula Bill create professional imbalance by favoring the dominance of medical profession while marginalizing other key healthcare disciplines. Collectively, these issues undermine equity, violate principles of fairness and non-discrimination, and weaken Nigeria’s multidisciplinary healthcare system. The National Assembly must urgently amend the Bills to remove monopoly clauses, protect the autonomy of all professional councils, strengthen the NMCN with proper governance and anti-quackery provisions, and ensure equitable representation across professions. Ultimately, Nigeria’s healthcare system can only achieve global standards through collaboration, mutual respect, and balanced governance and not by professional dominance or subjugation.

Signed

  Nurse Opeyemi Ojo                                                            Nurse Philip Eteng

UGONSA National President                                        UGONSA National Secretary

 

CC:

Chairman, Senate Committee on Health

Chairman, House of Reps Committee on Health

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Nurse Consultant: UGONSA writes HCSF, counters NAMDA's Petition

The Head of Civil Service of the Federation (HCSF),

Federal Secretariat Complex,

Shehu Shagari Way, P.M.B. 248,

Garki, Central Business Area, Abuja.

 

Madam,

Official Response from the University Graduates of Nursing Science Association (UGONSA) to the Nigerian Association of Medical and Dental Academics (NAMDA) position on Consultant Cadre for other Healthcare Professions

To: The Honourable Head of Service, Federal Civil
Service of the Federation, and to all stakeholders in Nigeria’s health sector

UGONSA has read with grave concern the petition written to your office by the Nigerian Association of Medical and Dental Academics (NAMDA) tilted “PETITION ON THE THREAT TO PATIENTS SAFETY IN THE NATIONS’ HOSPITAL SYSTEM: THE NEED TO STOP THE CREATION OF UNNECESSARY AND ILEGAL CADRES OF HOSPITAL CONSULTANTS AT THE ONGOING NATIONAL COUNCIL ON ESTABLISHMENT MEETING HOLDING IN KANO”.

We categorically reject the assertion that creating regulated cadres of consultant nurses (or accredited advanced nursing roles) will “derail clinical management” or inherently put patients at risk. On the contrary, international evidence and authoritative policy bodies show that enabling nurses to practice at the top of their education and training strengthens health systems, improves access and patient outcomes, and is an essential response to workforce shortages (Institute of Medicine, 2010; Kennedy et al., 2012; Laurant et al., 2018; Royal College of Nursing [RCN], 2021;  World Health Organization, 2021; American Association of Managed Care Nurses [AAMCN], 2025). Below, we state the facts, cite the evidence, and propose safe, practical policy safeguards for Nigeria.

1.       The “consultant” title is not the exclusive preserve of medical doctors. It is used safely in other health systems: NAMDA argues that the title consultant in hospitals is unique to doctors and confers exclusive ultimate responsibility for patient care. The international reality is different. In the United Kingdom, for example, consultant-level nursing posts (commonly called Nurse Consultant) are an established, regulated senior clinical role with defined responsibilities, clinical leadership, service development, education, research, and professional governance, operating within multi-disciplinary teams (Royal College of Nursing [RCN], 2021).

2.       Strong, high-quality evidence shows advanced nursing roles are safe and effective, and improve healthcare access, quality and satisfaction: Evidence-based summaries reach the following conclusions: A major Cochrane review and updates on nurse-led primary care show that substituting nurses for doctors in many primary-care tasks produces similar or better patient health outcomes and higher patient satisfaction, with no clear increase in harm (Laurant et al., 2018). Nurses tend to have longer consultations, and evidence shows at least equivalence for many conditions. Systematic reviews and mixed-methods evaluations of nurse consultant roles (UK and international literature) report improvements in service quality, patient experience, chronic disease management, and workforce development, while noting that well-designed role specification and outcome measurement are essential (RCN, 2021). Where roles are well-structured and evaluated, benefits follow.  Reviews of advanced nursing practice reported consistent improvements in access, chronic disease self-management, and patient satisfaction when Advanced Practice Nurses (APNs), Nurse Consultants, or Clinical Nurse Specialists provide care (AAMCN, 2025). The evidence supports expanding appropriately trained nursing roles to meet unmet needs.  Empirical evidence thus shows that when nurse consultant roles are regulated, educated, and integrated into team governance, outcomes are improved or equivalent to those of physician-led care across many services (Kennedy et al., 2012; Laurant et al., 2018; AAMCN, 2025).

3.       Leading global policy bodies recommend nurses be enabled to work at full scope — Nigeria should align with those recommendations: The Institute of Medicine (IOM; now the National Academy of Medicine) landmark report The Future of Nursing: Leading Change, Advancing Health (2010) concluded that health systems must enable nurses to practice to the full extent of their education and training, expand opportunities for nurses to lead and redesign care, and increase the proportion of nurses with higher levels of education. The IOM made clear that removing scope-of-practice barriers and supporting advanced practice is vital to meet population needs. This remains a cornerstone reference for global health system workforce reform.  The World Health Organization’s Global Strategic Directions for Nursing and Midwifery (SDNM) 2021–2025 likewise urges Member States to strengthen nursing education, regulation, leadership, and practice so nurses can contribute maximally to universal health coverage. That policy recognizes advanced nursing roles as part of the solution to workforce shortfalls and service gaps.

4.       Nigeria has a demonstrable workforce gap — task-sharing and advanced nursing roles are proven, necessary mitigation strategies: Nigeria faces a severe physician shortage and large regional maldistribution of doctors. International comparisons and country data show physician densities in Nigeria are far below WHO-recommended levels; health system resilience demands complementary approaches. Deploying regulated advanced nursing roles is a proven strategy to expand access (particularly in primary care and underserved areas) without lowering standards. Example: where doctor supply is constrained, nurse consultants/nurse practitioners/advanced nurses in many countries provide primary care, emergency care, and chronic-disease management safely and cost-effectively, reducing waiting times, improving continuity of care, and improving outcomes.

5.       The concerns NAMDA raises about accountability, scope, and budgets are addressable — regulation, accredited training, and governance can fix them: NAMDA’s letter raises three recurring fears: (A) loss of clinical accountability, (B) role confusion and conflict, and (C) budgetary bloat. UGONSA responds with practical, evidence-based policy solutions:

A. Legal and clinical accountability — solution: embed advanced nursing roles in statute and regulation. Define clearly (in law/regulation/appointment letters) where medical ultimate responsibility lies and where advanced nurses have autonomous authority (e.g., prescribing, diagnostics, counselling, rehabilitation) under defined scopes. International models use collaborative practice agreements, professional regulation, and hospital governance (credentialing, privileging, clinical guidelines) to ensure clarity.

B. Role clarity and team functioning — solution: adopt national competency frameworks, accredited postgraduate programmes (MSc/Doctoral/APN curricula), formal credentialing, and job descriptions that specify decision-making limits, referral triggers, and escalation pathways. The UK, Canada, Australia, and the US have used these governance mechanisms successfully.

C. Cost/budgeting concerns — solution: pilot with objective evaluation. Where advanced nursing roles reduce admissions and readmissions, improve chronic disease outcomes, or increase clinic throughput, any higher grade pay is offset by system gains (reduced avoidable admissions or readmissions, improved throughput). Evidence from multiple health systems indicates cost-effectiveness and cost reduction. Nigeria has the potential to cut healthcare costs through nurse consultants/advanced nurse practice cadres, as data from countries that have implemented it show.

 

6.        International practice: how countries manage consultant/advanced nursing roles (short examples): United Kingdom (NHS) — Nurse Consultant posts exist within trusts with clear job plans: leadership, expert practice, education, and research. These are senior clinical roles defined by employers and regulated by the Nursing Council. They do not remove physician accountability for acts requiring a medical license.

United States & Canada — Advanced Practice Registered Nurses (APRNs), Nurse Practitioners (NPs), and Clinical Nurse Specialists (CNSs) deliver primary care, emergency triage, and specialist clinics under state/provincial regulation; many jurisdictions have independent prescribing and diagnostic authority after credentialing. Cochrane and other systematic reviews find equivalent or better outcomes for many services (Laurant et al., 2018).

Australia — Nurse practitioner roles operate with clear legislation and clinical governance; outcomes and access improvements are documented wherever nurse practitioners were introduced into underserved settings.

These examples show that titles alone are not the threat. The threat (or benefit) is defined by whether roles are accompanied by regulation, training and governance. Nigeria can adopt the best practices to improve the fortune of our distressed health system.

7.       What UGONSA proposes (practical, safety-first roadmap): UGONSA is not asking for ad-hoc titles or tokenism. We propose a staged, defensible policy:

Legal/regulatory framework — the Federal Ministry of Health, working with the Nursing and Midwifery Council of Nigeria (NMCN), National Assembly, and legal drafters, should define legal scopes for Advanced Practice Nurses/nurse consultant-level roles (titles, privileges, limits). This will remove ambiguity and make accountability explicit.

Accredited postgraduate training — all consultant nurses and advanced practitioners must complete accredited postgraduate programmes (master’s level or equivalent; doctoral capability for consultant-level practice as required) with defined competency outcomes.

Federal Ministry of Health Guided Credentialing & hospital privileging — hospitals must credential and privilege based on competencies; the Federal Ministry of Health, in collaboration with the Office of the Head of the Civil Service of the Federation, should define staging protocols to guide referrals and escalations to higher levels of care.

Pilot programmes and evaluation — implement pilots in primary care deserts and tertiary specialty clinics with robust outcome measurement (safety, mortality, readmissions, patient satisfaction, cost) and publish results publicly.

Collaborative practice & clear patient safety protocols — define where medical ultimate responsibility applies (e.g., certain surgical interventions), and where advanced nurses may autonomously manage care (e.g., chronic disease clinics, triage, wound care, palliative care) with mandated referral and escalation rules.

National workforce planning — use the WHO SDNM and IOM recommendations as frameworks to scale advanced practice where workforce shortages are most acute.

8.       Direct rebuttals to some specific claims in the NAMDA petition.

NAMDA: “Consultant pharmacist/nurse roles add no clinical value in hospitals.”

UGONSA Response: International empirical reviews show that pharmacist/nurse consultants add immense value in clinical leadership, service redesign, medication management, diagnostic leverage, system thinking, and patient-centered care that improve access, outcomes, and satisfaction. Where roles are poorly implemented, benefits are muted. Therefore, the remedy is better role design and evaluation, not prohibition.

 

NAMDA: “Appointment to consultant rank is a political back-door and will create role confusion.”

UGONSA Response: Nursing is a globally trusted profession. The trust is why the care of humanity is entrusted to nurses. Nurses must be allowed to advance professionally and academically to continue to add value to the care mandate entrusted to them.  NAMDA should have rather emphasized transparent job criteria, advertised vacancies, competency-based appointment, and statutory regulation for the nurse consultant cadre, and not the denial of role evolution. The RCN/NHS model shows that formalized appointment and job planning are workable safeguards.

 

NAMDA: “We will not work in an environment with these roles.”

UGONSA Response: UGONSA urges constructive collaboration, not threats. Multidisciplinary teams are the future of safe, quality health care; clinical governance frameworks protect patient safety and professional responsibilities for all cadres (IOM, 2010). UGONSA stands ready to discuss specific NAMDA concerns in a joint stakeholder forum.

Conclusion

Nigeria’s health system faces real shortages and growing demand. The Institute of Medicine and the World Health Organization are explicit: nations must enable nurses to practice to the full extent of their training and education, educate nurses to higher levels, and expand nursing leadership in the health system and care redesign. The international evidence shows that advanced nursing roles are safe and often advantageous when implemented with robust regulation and governance. UGONSA therefore reaffirms that we strongly support the creation of regulated, accredited consultant/advanced nursing roles where those roles are defined by law, backed by accredited education, and integrated into hospital governance with clear scopes and accountability. We invite the Office of the Head of Civil Service to galvanize the Federal Ministry of Health, the Medical and Dental Councils, the Nursing and Midwifery Council, NAMDA, Nigeria Medical Association, National Association of Nurses and Midwives, Pharmaceutical Society of Nigeria,  and other stakeholders to establish a joint technical working group to draft legal/regulatory frameworks, an accreditation pathway, pilot sites, and outcome metrics for the consultant cadres of other healthcare professions and to do so in full public view. UGONSA is ready to lead and collaborate on this evidence-based reform to ensure Nigeria’s hospitals deliver safe, accessible, efficient, evidence-based, and modern care for all Nigerians.

Signed:

Nurse Opeyemi Ojo                                                                Nurse Eteng Philip

UGONSA National President                                                UGONSA National Secretary

 

References

American Association of Managed Care Nurses. (2025). Nurse consultant job description. https://careers.aamcn.org/career/nurse-consultant/job-descriptions

Institute of Medicine. (2010). The future of nursing: Leading change, advancing health. The National Academies Press. https://pubmed.ncbi.nlm.nih.gov/24983041/

Kennedy, F., McDonnell, A., Gerrish, K., et al. (2012). Evaluation of the impact of nurse consultant roles in the United Kingdom: a mixed method systematic literature review. J Adv Nurs., 68(4), 721-42. https://doi:10.1111/j.1365-2648.2011.05811.x. 

Laurant, M., van der Biezen, M., Wijers, N., et al. (2018). Nurses as substitutes for doctors in primary care. Cochrane Database System Review, 16, 7(7):CD001271. https://doi:10.1002/14651858.CD001271.pub3.

Royal College of Nursing. (2021). Consultant level nursing. https://www.rcn.org.uk/Professional-Development/Levels-of-nursing/Consultant

World Health Organization. (2021). Global strategic directions for nursing and midwifery 2021–2025.  https://www.who.int/publications/i/item/9789240033863

 

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NURSING INTERNSHIP PLACEMENT CRISIS: UGONSA WRITES CO-ORDINATING MINISTER OF HEALTH AND SOCIAL WELFARE ON GRADUATE NURSES’ INTERNSHIP PLACEMENT CRISIS

 

The Co-ordinating Minister of Health and Social Welfare,

Federal Ministry of Health (FMoH),

New Federal Secretariat Complex, Phase 111, Ahmadu Bellow Way,

Central Business District,

P.M.B.083, Garki, Abuja,

Nigeria.

 

Sir,

NIGERIA’S UNIVERSITY GRADUATE NURSES’ INTERNSHIP PLACEMENT

CRISIS: A CLARION CALL FOR YOUR KIND IMMEDIATE INTERVENTION ON CENTRALIZED POSTING SYSTEM

 

The National leadership of the University Graduates of Nursing Science Association (UGONSA), also known as Graduate Nurses Association of Nigeria (GNAN), a professional association of Nigeria Nurses with a minimum university qualification of first degree in Nursing Sciences (B.Sc. Nursing /B.N.Sc.) extends the good wishes of her members to you and other staff of the Ministry.

Honourable Minister, it has become imperative to draw your esteemed attention to the ugly developments and difficulties surrounding the recruitment/placement of Interns of the Nursing profession in Nigerian health institutions.

Sir, recall that the Office of the Head of Civil Service of the Federation (OHCSF) in a circular Ref. No. HCSF/EPO/EIR/CNO/100/ST/97, dated 8th September, 2016 conveyed the 39th meeting decision of the National Council on Establishment (NCE), held in Minna, Niger State on 22nd July, 2016, which approved the one year Internship Programme for graduate nurses (Please see attached circular marked Annexure C). The one year internship programme, which is a fundamental process in the “making of a qualified nurse” is designed to bridge the gap between the theoretical knowledge acquired in the university and the realities in the clinical practice, and equally serves as a prerequisite for issuance of a permanent Nursing practicing License by the Nursing and Midwifery Council of Nigeria (N&MCN), which confers the legal authority to the officer to practice Nursing in Nigeria.

Sir, the disturbing trend/experiences reported by graduate nurses seeking internship placement in various health facilities in recent times, which calls for urgent intervention, are reports of alleged bribery, corruption, and demand for sex from some female candidates before giving a slot for the internship programme. Our association gathered that, some personnel in some facilities “unofficially” demand for payments ranging from two hundred to three hundred thousand naira (#200,000 to #300,000) and more from candidates in exchange for internship position, while others negotiate for monthly deductions from the interns allowances throughout the 12 months duration of the programme. These candidates are often denied slots if they do not comply or pay the requested amount; thereby increasing the number of graduate nurses roaming the streets yearly waiting to be engaged in the internship programme. Sir, this unfolding precarious situation is fast developing into a depressive circumstance as many of the prospective nurse interns have their interns' temporary licenses expired before getting a placement. This ugly situation will warrant them to go back to N&MCN for another process of getting a new one, which further contributes to their waiting time.

Honourable Minister, this situation is worsening by the day, as an estimated 5,000, or more nurses graduate annually from all universities in the country. Some facilities that genuinely engage these interns often complain of lack of capacity and budget constraints to accommodate more interns than necessary in a year; thereby limiting the number of interns they recruit.

Another confirmatory evidence available on the public space that affirmed our request is the recent notice for internship application at the University College Hospital, Ibadan, where nine hundred and five (905) graduate nurses applied, and were scheduled for screening examination on Monday (17/02/2025). Out of which, the hospital can only take a fraction of the applicants, while the majority of them will need to wait for another year, or continue the search for placement in other hospitals (please, see attached). This is just one out of many experiences of such.

Sir, the consequences of these ugly trends are that, while some graduates spent two to three (2 - 3) years searching for facilities for the internship programme, some, during the process, miss some important professional growth milestones. Secondly, the situation puts the future of the nursing profession in Nigeria at stake, as many graduates, out of frustration, migrate to the Western world for further studies and greener pastures. Some graduate nurses have also expressed emotional frustration, anxiety, and depression due to their inability to secure an internship placement after a few years of graduation from the university.

House officers and interns, especially nurse-interns, should be regarded as an essential part of healthcare workforce that plays a vital role in addressing the shortfalls in the healthcare personnel owing to emigration (Japa Syndrome), and their distribution to different health facilities should be seen as a means of balancing these shortfalls in the system.

Prayers/recommendations:

To address this ugly trend, our association hereby recommends the following measures to palliate the situation:

1.      That you adapt the following proposals and present same as a memo to the National Council on Health for consideration and approval

2.      Centralized Interns Application Portal: we call on the honourable Minister to authorize the creation of a Centralized Internship Application Portal, where all universities will forward the names of all graduate nurses yearly, for a centralized placement and posting across the country.

3.      Partnership with States and Privately-Owned Hospitals: We recommend that the Federal Government, through the Federal Ministry of Health, partner and empower States and Privately-owned Teaching and General Hospitals to develop capacity to engage and train nurse interns yearly, according to their capacity.

4.      Mandatory Quota System (MQS) for Teaching Hospitals and Federal Medical Centres: We also advocate that the Ministry issue a direct (publicly available) mandatory quota system to all federal Teaching Hospitals and Federal Medical Centres across the nation for yearly recruitment of nurse interns.

5.      Increase Budgetary Funding to Health Institutions for the recruitment and training of house officers and interns per year.

The association humbly prays that the above prayers/recommendations receive your approval for necessary and immediate action.

Sir, please, accept the esteemed assurances of our association’s highest regard.

Signed:

                                                                                      

Nurse Ojo Opeyemi                                                                                 Nurse Philip O. Eteng

National President                                                                                      National Secretary

 

 

 

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