HAVE YOUR SAY
SUBMISSION TEMPLATE
Endorsement for Scheduled Medicines for Midwives
Prepared by Homebirth Australia for use by women, families, supporters of homebirth, and midwives - adaptable to your perspective Closing date: 5 June 2026 | Email: [email protected] | Subject line: Feedback: Endorsement for scheduled medicines for midwives public consultation
Why this consultation matters for you as a consumer
Endorsement is the prescribing authority that allows a midwife to prescribe medicines and access Medicare. The number of endorsed midwives in Australia directly affects how many private midwives are available to women choosing homebirth or community-based midwifery. Most of the proposed changes to endorsement are positive for access and are supported. However, the changes interact closely with the Safety and Quality Guidelines (SQG) - if the SQG simultaneously restricts private practice (especially through the second-midwife insurance requirement), the workforce gains from these endorsement reforms will be lost.
How to use this template
This template was prepared by Homebirth Australia to help individual submitters respond to the NMBA's public consultation on the Endorsement for Scheduled Medicines for Midwives. The consultation closes on 5 June 2026. You can find the full consultation documents at this link. Be mindful there are three consultations currently open - we are submitting in the two furthest down the page, so you will have to scroll past the first one.
Who is this template for?
This template is designed to be used by anyone who wants to make a personal submission, including: women, families and supporters of homebirth (consumer perspective); privately practising midwives; registered midwives who are considering moving into private practice, or who attend homebirths as a second; and any midwife who wants to have a say on the proposed changes. The suggested wording in this template is written in the first person ('I') and is consumer-focused by default. If you are a midwife or other practitioner, you can easily adapt the wording to reflect your perspective - for example, replacing 'I want access to a private midwife' with 'I want to provide private midwifery care to the women in my community'. The substantive concerns set out in the template apply across consumer and practitioner perspectives.
Endorsement is the prescribing authority that allows a midwife to prescribe medicines and access Medicare. The number of endorsed midwives in Australia directly affects how many private midwives are available to women choosing homebirth or community-based midwifery. Most of the proposed changes to endorsement are positive for access and are supported. However, the changes interact closely with the Safety and Quality Guidelines (SQG) - if the SQG simultaneously restricts private practice (especially through the second-midwife insurance requirement), the workforce gains from these endorsement reforms will be lost.
How to use this template
This template was prepared by Homebirth Australia to help individual submitters respond to the NMBA's public consultation on the Endorsement for Scheduled Medicines for Midwives. The consultation closes on 5 June 2026. You can find the full consultation documents at this link. Be mindful there are three consultations currently open - we are submitting in the two furthest down the page, so you will have to scroll past the first one.
Who is this template for?
This template is designed to be used by anyone who wants to make a personal submission, including: women, families and supporters of homebirth (consumer perspective); privately practising midwives; registered midwives who are considering moving into private practice, or who attend homebirths as a second; and any midwife who wants to have a say on the proposed changes. The suggested wording in this template is written in the first person ('I') and is consumer-focused by default. If you are a midwife or other practitioner, you can easily adapt the wording to reflect your perspective - for example, replacing 'I want access to a private midwife' with 'I want to provide private midwifery care to the women in my community'. The substantive concerns set out in the template apply across consumer and practitioner perspectives.
Completing your submission
You can either download the NMBA provided document template for submission,
record your responses within that document, and email it to [email protected]
OR you can complete the survey version within a web browser.
You can either download the NMBA provided document template for submission,
record your responses within that document, and email it to [email protected]
OR you can complete the survey version within a web browser.
Step 1.
Select “Organisation” or “Individual” as relevant (most using this guide will select individual)
Step 2.
Add your name and organisation, or N/A if you prefer not provide it
Step 3.
Select the response relevant for you as far as publishing your submission (or not)
Step 4.
Read each question and select the relevant answer (Yes/No/Prefer not to answer). The yellow [write your answer here] sections in square brackets are where you personalise the wording in the document version, the survey version will give you a text box after selecting your answer and clicking the arrow to continue. Here is where to share your own story, the specific impact on you, or your community. In our response template below is suggested wording you can keep, edit, or replace. You can also simply write N/A if you prefer not to expand on your answer.
You can shorten or lengthen any suggested answer we have provided. A short, personal submission is more powerful than a long generic one. Even answering one or two questions is valuable.
Step 5.
If you used the document template response, email your completed submission to [email protected] with the subject line 'Public consultation: SQG' (for the SQG template) or 'Feedback: Endorsement for scheduled medicines for midwives public consultation' (for the Endorsement template). If you are using the survey version, you can simply hit ‘submit’ at the last question.
Select “Organisation” or “Individual” as relevant (most using this guide will select individual)
Step 2.
Add your name and organisation, or N/A if you prefer not provide it
Step 3.
Select the response relevant for you as far as publishing your submission (or not)
Step 4.
Read each question and select the relevant answer (Yes/No/Prefer not to answer). The yellow [write your answer here] sections in square brackets are where you personalise the wording in the document version, the survey version will give you a text box after selecting your answer and clicking the arrow to continue. Here is where to share your own story, the specific impact on you, or your community. In our response template below is suggested wording you can keep, edit, or replace. You can also simply write N/A if you prefer not to expand on your answer.
You can shorten or lengthen any suggested answer we have provided. A short, personal submission is more powerful than a long generic one. Even answering one or two questions is valuable.
Step 5.
If you used the document template response, email your completed submission to [email protected] with the subject line 'Public consultation: SQG' (for the SQG template) or 'Feedback: Endorsement for scheduled medicines for midwives public consultation' (for the Endorsement template). If you are using the survey version, you can simply hit ‘submit’ at the last question.
TEMPLATE
Questions about the revised Registration standard with suggested template responses
You can edit, shorten or replace any wording below. The [square bracket] sections are places to add your own story.
You can edit, shorten or replace any wording below. The [square bracket] sections are places to add your own story.
1. Is the updated content of the proposed revised registration standard helpful, clear, and relevant?
☒ Yes
☐ No
☐ Prefer not to answer
Rationale:
As a consumer I support the direction of the proposed registration standard. The current 5,000 hour requirement is a barrier that has limited the number of midwives able to support women in private practice, including in homebirth. Removing it is a positive step.
[OPTIONAL: add your personal experiences 'I have personally experienced [a long search for a private midwife / difficulty accessing care in my area] and I support changes that increase the workforce available to women like me.']
☒ Yes
☐ No
☐ Prefer not to answer
Rationale:
As a consumer I support the direction of the proposed registration standard. The current 5,000 hour requirement is a barrier that has limited the number of midwives able to support women in private practice, including in homebirth. Removing it is a positive step.
[OPTIONAL: add your personal experiences 'I have personally experienced [a long search for a private midwife / difficulty accessing care in my area] and I support changes that increase the workforce available to women like me.']
2. Do you support the removal of the requirement for 5,000 hours of clinical practice?
☒ Yes
☐ No
☐ Prefer not to answer
Response:
The NMBA's own evidence base supports removal: the Midwifery Futures Australian Midwifery Workforce Project (NMBA 2024); Hull et al. (2024) scoping review of endorsed midwives prescribing in Australia (Women and Birth, 37(2)); Small et al. (2025) scoping review of midwifery prescribing regulation internationally (Sexual & Reproductive Healthcare, 44). The 5,000 hour requirement is not supported by evidence as a threshold for safe prescribing, and it disadvantages new graduates, midwives returning to practice, and rural midwives. Removing it will increase the number of midwives able to provide comprehensive private midwifery care, including for women choosing homebirth.
[OPTIONAL: add your personal experiences eg 'I am a registered midwife who wants to go into private practice and has been unable to complete the hours requirement'/’I am an endorsed midwife in private practice who completed the 5000 hours and did not find those clinical hours provided me with any extra knowledge or experience for endorsement responsibilities’]
☒ Yes
☐ No
☐ Prefer not to answer
Response:
The NMBA's own evidence base supports removal: the Midwifery Futures Australian Midwifery Workforce Project (NMBA 2024); Hull et al. (2024) scoping review of endorsed midwives prescribing in Australia (Women and Birth, 37(2)); Small et al. (2025) scoping review of midwifery prescribing regulation internationally (Sexual & Reproductive Healthcare, 44). The 5,000 hour requirement is not supported by evidence as a threshold for safe prescribing, and it disadvantages new graduates, midwives returning to practice, and rural midwives. Removing it will increase the number of midwives able to provide comprehensive private midwifery care, including for women choosing homebirth.
[OPTIONAL: add your personal experiences eg 'I am a registered midwife who wants to go into private practice and has been unable to complete the hours requirement'/’I am an endorsed midwife in private practice who completed the 5000 hours and did not find those clinical hours provided me with any extra knowledge or experience for endorsement responsibilities’]
3. Do you support the removal of the requirement to specify a context of practice?
☒ Yes
☐ No
☐ Prefer not to answer
Response:
Yes. The administrative requirement to specify a context of practice no longer serves a regulatory purpose. The NMBA's own rationale notes Services Australia has confirmed it is not required for MBS or PBS access. Removing it reduces friction without any safety implication.
☒ Yes
☐ No
☐ Prefer not to answer
Response:
Yes. The administrative requirement to specify a context of practice no longer serves a regulatory purpose. The NMBA's own rationale notes Services Australia has confirmed it is not required for MBS or PBS access. Removing it reduces friction without any safety implication.
4. Do you support the requirement that midwives must lodge a complete application for endorsement within 12 months of completing an NMBA approved endorsement qualification?
☒ Yes
☐ No
☐ Prefer not to answer
Response:
I support timely application in principle - recency of training is important to safe practice. I also support the proposed case-by-case mechanism for midwives who do not lodge within 12 months.
However, I am concerned that the case-by-case mechanism may operate unpredictably for midwives completing endorsement as part of a broader further qualification (say Advanced Diploma or Masters degree), or midwives experiencing common life-circumstance interruptions like parental leave or illness. Anything that discourages midwives from completing endorsement reduces the workforce available to women.
I ask the NMBA to publish, in the proposed Guidelines, a clear list of categories that automatically attract favourable consideration in the case-by-case process: Master's program completers, parental leave, certified illness, caring responsibilities, rural relocation, and similar.
[OPTIONAL: add your personal experiences where relevant eg 'I am a registered midwife who wants to go into private practice who has completed the endorsement qualification but has not yet applied for endorsement due to xyz reasons’]
☒ Yes
☐ No
☐ Prefer not to answer
Response:
I support timely application in principle - recency of training is important to safe practice. I also support the proposed case-by-case mechanism for midwives who do not lodge within 12 months.
However, I am concerned that the case-by-case mechanism may operate unpredictably for midwives completing endorsement as part of a broader further qualification (say Advanced Diploma or Masters degree), or midwives experiencing common life-circumstance interruptions like parental leave or illness. Anything that discourages midwives from completing endorsement reduces the workforce available to women.
I ask the NMBA to publish, in the proposed Guidelines, a clear list of categories that automatically attract favourable consideration in the case-by-case process: Master's program completers, parental leave, certified illness, caring responsibilities, rural relocation, and similar.
[OPTIONAL: add your personal experiences where relevant eg 'I am a registered midwife who wants to go into private practice who has completed the endorsement qualification but has not yet applied for endorsement due to xyz reasons’]
5. Would the proposed updates result in any potential negative or unintended effects for people requiring healthcare, including priority members of the community who may choose to access services provided by an endorsed midwife?
☐ Yes
☒ No
☐ Prefer not to answer
Rationale::
The proposed updates should have positive effects on healthcare access for women, particularly in rural and regional areas. The NMBA itself notes 'Rural, remote, and regional communities continue to face challenges in accessing healthcare including midwifery services' (Discussion section, p.14). The exception is the 12-month application deadline, which, if inflexibly applied, could disadvantage midwives in postgraduate study or with life interruptions.
☐ Yes
☒ No
☐ Prefer not to answer
Rationale::
The proposed updates should have positive effects on healthcare access for women, particularly in rural and regional areas. The NMBA itself notes 'Rural, remote, and regional communities continue to face challenges in accessing healthcare including midwifery services' (Discussion section, p.14). The exception is the 12-month application deadline, which, if inflexibly applied, could disadvantage midwives in postgraduate study or with life interruptions.
6. Would the proposed updates result in any potential negative or unintended effects for Aboriginal and/ or Torres Strait Islander Peoples?
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
The proposed updates should expand the endorsed midwife workforce. Aboriginal and Torres Strait Islander women have particular reasons to seek private midwifery, including Birthing on Country and continuity of carer. The NMBA should monitor whether the changes are increasing access for Aboriginal and Torres Strait Islander women and Aboriginal and Torres Strait Islander midwives specifically, and engage CATSINaM on implementation.
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
The proposed updates should expand the endorsed midwife workforce. Aboriginal and Torres Strait Islander women have particular reasons to seek private midwifery, including Birthing on Country and continuity of carer. The NMBA should monitor whether the changes are increasing access for Aboriginal and Torres Strait Islander women and Aboriginal and Torres Strait Islander midwives specifically, and engage CATSINaM on implementation.
7. Would the proposed updates result in any potential negative or unintended effects for endorsed midwives?
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
The proposed changes are workforce-positive and should not have negative effects on currently endorsed midwives. I also support the proposed update to the wording on the public register (expanded from prescribe-only to administer/obtain/possess/prescribe/supply/use), which is functionally important for endorsed midwives in homebirth practice.
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
The proposed changes are workforce-positive and should not have negative effects on currently endorsed midwives. I also support the proposed update to the wording on the public register (expanded from prescribe-only to administer/obtain/possess/prescribe/supply/use), which is functionally important for endorsed midwives in homebirth practice.
8. Please provide any other feedback on the proposed revised endorsement.
Response:
These endorsement reforms are positive for access to private midwifery and homebirth. They will, however, be largely undone if the simultaneous Safety and Quality Guidelines (SQG) consultation introduces a second-midwife insurance requirement that makes private practice unaffordable in rural and regional Australia. I urge the NMBA to consider the two consultations together. The workforce-positive endorsement changes should not be cancelled out by workforce-restrictive SQG changes.
I also note that endorsement is a prescribing authority, not a homebirth-specific qualification. The midwifery skills required for safe homebirth are developed through caseload practice and mentoring.
Response:
These endorsement reforms are positive for access to private midwifery and homebirth. They will, however, be largely undone if the simultaneous Safety and Quality Guidelines (SQG) consultation introduces a second-midwife insurance requirement that makes private practice unaffordable in rural and regional Australia. I urge the NMBA to consider the two consultations together. The workforce-positive endorsement changes should not be cancelled out by workforce-restrictive SQG changes.
I also note that endorsement is a prescribing authority, not a homebirth-specific qualification. The midwifery skills required for safe homebirth are developed through caseload practice and mentoring.
Questions about the proposed Guideline
1. Is the content helpful, clear and relevant?
☒ Yes
☐ No
☐ Prefer not to answer
Rationale:
I broadly support the proposed Guidelines. My specific points are in the following questions.
☒ Yes
☐ No
☐ Prefer not to answer
Rationale:
I broadly support the proposed Guidelines. My specific points are in the following questions.
2. Is there any content that needs to be changed, removed or added in the proposed Guidelines?
☒ Yes
☐ No
☐ Prefer not to answer
Response:
I ask the NMBA to:
☒ Yes
☐ No
☐ Prefer not to answer
Response:
I ask the NMBA to:
- Reference the role of mentoring in supporting newly endorsed midwives transitioning to independent practice.
- Clearly articulate the interaction between the Guidelines and the SQG, particularly for women choosing homebirth.
- Address PII coverage parameters: confirm in writing with MIGA that coverage extends to women of all risk profiles where informed consent is documented; confirm whether MIGA requires a collaborative arrangement (and if so, explicitly confirm that a Record of Understanding where the woman declines hospital information-sharing can be used in place of said arrangement to maintain PII cover).
- Publish, in the Guidelines, a clear list of categories that automatically attract favourable consideration in the 12-month case-by-case process.
3. Would the proposed Guidelines result in any potential negative or unintended effects for people requiring healthcare, including priority members of the community who may choose to access endorsed midwife services?
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
Positive effects expected through workforce expansion. See Q5 of the Registration Standard section above.
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
Positive effects expected through workforce expansion. See Q5 of the Registration Standard section above.
4. Would the proposed Guidelines result in any potential negative or unintended effects for Aboriginal and/ or Torres Strait Islander Peoples?
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
See Q6 of the Registration Standard section above.
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
See Q6 of the Registration Standard section above.
5. Would the proposed Guidelines result in any potential negative or unintended effects for endorsed midwives?
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
See Q7 of the Registration Standard section above.
☐ Yes
☒ No
☐ Prefer not to answer
Rationale:
See Q7 of the Registration Standard section above.
6. Please provide any other feedback on the proposed Guidelines.
Response:
As a consumer/homebirthing woman/registered midwife/privately practicing midwife, I support the endorsement reforms and urge the NMBA to read this submission alongside my submission on the SQG. The two consultations are deeply interlinked. Workforce-positive endorsement reforms should not be cancelled out by workforce-restrictive SQG reforms.
Response:
As a consumer/homebirthing woman/registered midwife/privately practicing midwife, I support the endorsement reforms and urge the NMBA to read this submission alongside my submission on the SQG. The two consultations are deeply interlinked. Workforce-positive endorsement reforms should not be cancelled out by workforce-restrictive SQG reforms.
Submission addressed to [email protected]. The consultation opens 8 April 2026 and closes 5 June 2026.
