An Expired Licence, a Portal Problem and Pressure From the Owner
You are the nurse manager of a 60-bed private hospital. During a licence audit you discover that one of your senior nurses, Mrs B, has a practising licence that expired eight months ago. She has continued to work full-time, including night-duty in-charge, and has signed controlled-drug records and discharge summaries during that period. She says the Nursing and Midwifery Council of Nigeria portal rejected her payment three times, that a 'senior officer' told her she could keep working while the matter was resolved, and that she has not completed any continuing professional development activities for two years because 'the hospital never organised any'. The hospital owner tells you not to 'make a problem' because Mrs B is popular with patients and the hospital is short-staffed. You also find that two newly employed nurses have provisional registration letters but no full licence.
1. Determine Mrs B's legal and professional position and your obligations as nurse manager.
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A practising licence is not a formality; it is the evidence that a nurse is currently registered and permitted to practise. If Mrs B's licence expired eight months ago, she has been practising without a current licence. That is a regulatory offence and a professional issue, regardless of whether the portal failed or a senior officer gave verbal reassurance. Verbal reassurance is not a licence, and it should have been confirmed in writing. Her signatures on controlled-drug records and discharge summaries during the unlicensed period are also a serious governance problem because they represent acts performed without practising status.
As nurse manager, your first duty is patient safety and lawful practice. Remove her from clinical duties and from any position of sole charge immediately. Do not roster her for medication administration, controlled-drug checks or discharge documentation until a valid licence is produced. Inform the medical director or owner in writing of the risk and your decision. Support Mrs B to regularise her status but do not collude with continued practice. Treat her fairly and confidentially, but do not let popularity or staff shortage override the legal requirement. Document the audit finding, the action taken and the evidence of her licence status.
2. Set out the steps for regularising her licence, including CPD and any interim restrictions.
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Ask Mrs B to provide written evidence of her current registration status from the Council. Advise her to apply for renewal or late renewal immediately, pay any outstanding fees and penalties, and complete the continuing professional development required for renewal. The hospital's failure to organise CPD does not remove her personal obligation; she must keep evidence of her own learning. If the Council requires a restoration or additional process because of the lapse, she must follow it. She should not return to clinical work until the Council issues a valid licence, not merely until a payment is made.
In the interim, consider only duties that do not require a practising licence and that are clearly permitted, such as administrative audit work, and only under supervision and with the owner's written approval. Do not use her as a substitute ward nurse, do not allow her to sign clinical documents, and do not let her act as night-duty in-charge. Keep the restrictions in writing and review them when the licence is produced. If the Council confirms that the lapse requires formal inquiry, cooperate fully. Record the dates, the advice given and the evidence provided, and avoid discussing the matter with other staff who do not need to know.
3. Advise the hospital owner on the risks of continuing to roster unlicensed staff and the action required for the newly employed nurses.
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Explain that continuing to roster unlicensed staff exposes patients to care from practitioners who are not accountable to the regulator, may invalidate professional indemnity cover, and can expose the hospital and its management to regulatory and legal consequences. It also creates a documentary problem: controlled-drug records and discharge summaries signed by an unlicensed nurse may be challenged. Staff shortage is a real risk, but it does not justify unlawful practice; the safer response is to escalate to the owner for temporary staffing, reduce admissions or arrange locum cover.
For the two newly employed nurses, obtain copies of their registration letters and clarify what provisional registration permits. Provisional registration usually carries conditions, including supervision, and does not authorise independent practice or sole charge. Confirm their status with the Council, roster them only within those conditions, and set a date for full registration. Audit all clinical staff licences, create a renewal tracking system with reminders, require CPD plans, and report the audit outcome to the owner in writing. The message should be practical rather than punitive: the hospital can support renewal, but no unlicensed person may be rostered to provide nursing care.