NARM Accountability and Appeal Policy

I. Overview

The North American Registry of Midwives (NARM) recognizes its responsibility to protect birthing families and the integrity and value of the Certified Professional Midwife (CPM) certification by taking an active role in evaluating allegations of misconduct by CPMs or CPM applicants. A CPM or CPM applicant who is the subject of a written complaint (the “Respondent”) is required to participate in the disciplinary process. Failure or refusal by the Respondent to participate shall result in revocation of the CPM credential or rejection of the CPM application.

II. Initiating Complaints

  1. Complaints must be received within two (2) years of the conclusion of care or complaints originating from a State regulatory board or quality assurance (QA) program must be received within 90 days of completion of said regulatory or QA investigation.
  2. Complaints must be initiated through the NARM Complaint form or by request to accountability@narm.org.
  3. Complaints may be initiated by:
    1. a midwifery client;
    2. a state licensing board or regulatory body;
    3. a state QA Program;
    4. an individual or entity with direct knowledge of relevant facts and circumstances sufficient enough to warrant a complaint; or
    5. a CPM applicant.
  4. Complaints against a Respondent who is a CPM applicant
    1. If the CPM applicant is engaged in the Portfolio Evaluation Process (PEP), the complaint must include their preceptor as Respondent
    2. If the CPM applicant is enrolled in a MEAC accredited education program, the complaint will be referred back to the educational body for internal review
    3. if the CPM applicant is enrolled in a MEAC accredited education program the complaint will be referred back to the educational body for internal review
  5. A complaint may be made against a midwife whose CPM certification has been revoked, expired, or retired. NARM cannot require a midwife who is not a CPM to participate in the NARM Accountability Process, however participation is a requirement of recertification should the midwife apply to recertify.

III. Basis for Accountability Review

  1. NARM may address any complaint or concern that falls into the following categories:
    1. Fraud or deceit in an application, reapplication, or other communication to NARM, including, but not limited to, providing a false or misleading statement and/or knowingly assisting another to obtain or attempt to obtain NARM’s certification or recertification by fraud or deception.
    2. Irregularity regarding the NARM Examination, including, but not limited to, providing or receiving unauthorized assistance before, during, or after an exam, providing false information to gain admittance to an exam, or impersonating another examinee.
    3. Misrepresentation of certification or violation of NARM’s personal and/or intellectual property rights, including, but not limited to, unauthorized access, possession of, use of, distribution of, or access to NARM’s: exams; certificates, name, trade name, certification mark, service mark, trade dress or trademark; or other personal and/or intellectual property.
    4. Chronic or acute abuse of alcohol, prescription medications, street drugs, or other substances that produce intoxicating effects; new onset or ongoing instances of cognitive impairment caused by physical or mental conditions such as injury, illness, or degenerative disorders that impair the Respondent’s professional performance as a CPM.
    5. Limitation or sanction by a federal, state, or private licensing board, administrative agency, association, or health care organization relating to public health or safety, or midwifery practice.
    6. Conviction of, plea of guilty to, or plea of nolo contendere to a crime directly relating to midwifery practice and/or public health and safety.
    7. Engaging in conduct not consistent with professional standards, including, but not limited to: any practice that creates unnecessary danger to the life, health, or safety of a client or their baby (fetus or neonate) or a neonate in the Respondent’s care; or any practice that is contrary to the ethical conduct appropriate to the midwifery profession. Actual injury to a client or baby (fetus or neonate) need not be shown.
    8. Unprofessional conduct that includes any actions or omissions that compromise client safety, quality of care, or professional integrity.Examples include: failure to collaborate with other health professionals when client safety/well-being may be compromised; misrepresentation of a drug, procedure, substance, device, or supplement in a manner inconsistent with widely accepted standards; or falsification of health records.
    9. Breaches of confidentiality including but not limited to disclosure of client protected health information (PHI), sharing of identifying photos, videos, or stories on social media or in another social manner without permission.
  2. NARM will not address complaints:
    1. Without sufficient information including the name of client, a description of the event, and identification of the applicable complaint category described in III (A).
    2. That do not indicate a violation of midwifery practice standards.
    3. About financial disputes between the midwife and the client
  3. NARM reserves the right in its discretion to address a complaint or concern not set forth above. NARM reserves the right in its discretion to dismiss any complaint it deems unfounded.

IV. Priority Cases

  1. Receipt of a complaint(s) about a CPM that poses potential severe and immediate danger to birthing families may result in immediate actions by NARM Accountability Review Committee (ARC) in conjunction with the approval of the NARM Executive Director, including termination or suspension of certification or referral to outside authorities.
  2. Receipt of a complaint about a CPM who has previously been found at fault and sanctioned for one or more of the categories in section III (A), where the new complaint represents an urgent situation that poses immediate danger to birthing families, NARM ARC in conjunction with the approval of the NARM Executive Director may take immediate actions:
    1. To ensure time to conduct a thorough and fair accountability review of the complaint while protecting birthing families and the integrity of the CPM credential, NARM may suspend a Respondent’s CPM certification.
    2. The Respondent will be notified via certified mail and email, and the suspension will be effective immediately upon receipt of notice.
    3. If the Respondent practices in a state in which a state licensing board or regulatory agency has jurisdiction, NARM will notify said entity of the complaint immediately upon issuing the suspension.
    4. NARM Accountability Program, understanding the implications of temporary suspension, will give priority status in hearing the complaint review in order to achieve a timely resolution..
  3. Compliance with the suspension notice
    1. Respondent will notify all current clients in writing of suspension of the CPM credential within two (2) weeks
    2. Respondent will remove “CPM” designation from all documents, advertising, and social media until and if suspension is lifted
  4. Failure to comply with the suspension notice will result in revocation of the CPM credential.
    1. Failure to sign certified mail receipt of notice of suspension will result in revocation of the CPM credential.
    2. Failure to sign and return the Acknowledgment of Accountability Policies and Procedures will result in revocation of the CPM credential
    3. It is the responsibility of CPM or applicant to maintain a current mailing address with NARM.
    4. Failure to participate in the accountability review will result in revocation of the CPM credential.

V. Accountability Review

  1. Following receipt of a complaint, the NARM Case Coordinator or designated staff shall notify the Respondent in writing of the complaint allegations and provide a written request for all records pertaining to the case. The Respondent must respond in writing and submit all records pertaining to the case via a secure portal or certified mail within 14 business days of being notified. Upon receipt of records, NARM will issue a written receipt via email and U.S. mail. Failure to respond to the notice in whole or in part may result in revocation of the CPM or cancellation of the CPM application.
  2. Identity of the complainant shall not be disclosed to the Respondent at any point in the accountability process, including at completion of Accountability Case Review or appeal.
  3. Identity of the Complainant will be disclosed to the Respondent if the complainant is also a Preceptor filing a complaint against a CPM Applicant (see Preceptor Student Accountability Policy)
  4. The Accountability Case Review will be conducted by the Accountability Review Committee (ARC) consisting of the Accountability Case Coordinator, the Accountability Administrator, and three (3) volunteer Accountability Peer Reviewers.
  5. All proceedings, documents, and testimonies of the Accountability Case Review are confidential and may not be disclosed to any individual or entity outside of NARM with the exception of disclosures initiated by subpoena.
  6. All Accountability Review Proceedings and case details are confidential. ARC members shall each be required to sign confidentiality agreements prior to engaging in the Accountability Case Review process.
  7. NARM may disclose findings and sanctions of suspension or revocation to State licensing boards, regulatory agencies, or legal authorities as deemed necessary to protect birthing families and preserve the integrity of the CPM credential.
  8. Respondent has the right to secure legal counsel at any point in the Accountability Review process.

The NARM Accountability Review Procedure can be found at narm.org or may be requested by emailing accountability@narm.org.

VI. Possible Outcomes of Accountability Review

  1. The ARC may render any one or a combination of the following decisions deemed appropriate under the circumstances:
    1. exoneration of the Respondent;
    2. imposition of corrective actions to be performed by the Respondent;
    3. revocation of the CPM certification, NARM Registered Preceptor Registration, or rejection of the CPM application;
    4. Suspension of the CPM certification
    5. notification of a sanction of suspension or revocation sent to to state licensing and/or regulatory entities; or
    6. other sanctions that may be determined by the ARC to be appropriate.

VII. Notification

  1. The following notifications of the ARC’s decision shall be made:
  2. to the Respondent;
  3. to the Complainant; and
  4. in the case of revocation or suspension:
    1. a public notice of revocation shall be posted and shall remain posted online at www.narm.org;
    2. a public notice of suspension shall be posted and shall remain posted until the end of the suspension period and completion of any associated stipulations online at www.narm.org.
    3. states that use the CPM certification for their licensure process shall be notified.

VIII. Appeals

  1. Respondent may submit an appeal of an ARC determination of findings to the Accountability Program.
    1. Requests for appeal must be initiated by contacting NARM at accountability@narm.org.
    2. Requests for appeal must be received by the NARM Accountability Program within thirty (30) days of receipt of NARM ARC notification of final findings and sanctions.
  2. Requests for appeal will be considered by the Case Coordinator and Accountability Administrator with the approval of the NARM Executive Director.
  3. An appeal may be granted if:
    1. the Respondent provides additional material facts and/or circumstances that were not available during the ARC’s deliberations; or
    2. if the ARC made a material error in its deliberations or decision.
  4. Failure of the Respondent to present material facts and/or circumstances in the Accountability Review Process that were knowingly available to the Respondent at the time shall not serve as the basis of an appeal.
  5. NARM Case Coordinator or designated staff will notify Respondent of decision to grant or deny request for appeal.,
    1. Notification will be provided within thirty (30) days of request for appeal.
    2. Notification will be issued via certified mail.
  6. Appeal reviews will be conducted by the NARM Executive Director and ARC.
    1. The ARC will be comprised of the Case Coordinator, Accountability Administrator, and three (3) newly identified case reviewers.
    2. The Accountability Case Reviewers will be appointed by the Accountability Case Coordinator and confirmed to have no prior knowledge of the case and no prior relationship to the Respondent, Complainant or Client.
  7. All findings made by the Appeal committee are to be considered final.
  8. The NARM Appeal Procedure may be requested by contacting NARM at accountability@narm.org.

IX. Preceptor/Student Accountability

  1. Complaints received involving the PEP Preceptor/Student relationship will be addressed by the NARM Accountability Program 
    1. Complaints lodged about Preceptor/Student relationships while participating in a MEAC accredited program will be referred to the educational program.
    2. Complaints meeting the criteria in III (A) above will be subject to review by the ARC.
    3. Complaints that meet the criteria in III(A)(1-3) will be forwarded to a NARM Applications Review Panel.
  2. Complaints involving the PEP Preceptor/Student relationship that meet the complaint criteria in III (A) will be subject to the Accountability Review Process and all notifications, possible outcomes, and right to appeal therein.
  3. Complaints involving the PEP Preceptor/Student relationship must be initiated through the NARM Complaint form or by emailing accountability@narm.org.
  4. The complete Preceptor/Student Accountability Policy can be requested by contacting accountability@narm.org.
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