Celebrated FGM specialist suspended

World-renowned specialist midwife and female genital mutilation (FGM) campaigner Comfort Momoh has been suspended from the Nursing and Midwifery Council (NMC) register for six months writes The Nursing Times.

An NMC panel found she committed misconduct on numerous occasions between 2012 and 2017, and that her fitness to practise was therefore impaired.

“Her role appears to have been completely devoid of any adequate and necessary supervisory oversight” NMC report

Dr Momoh, until 2017, worked as an FGM specialist midwife at the African Well Women’s Clinic (AWWC), a clinic she set up which specialised in care for survivors of FGM which was part of Guy’s and St Thomas’ NHS Foundation Trust.

While running the AWWC, the panel found she committed misconduct because she failed to properly complete patient documentation, administered medication to patients without a prescription and worked beyond the scope of her practice by treating children who were not pregnant.

The panel said Dr Momoh worked outside of her scope in part because of “uncertainty” regarding her job title and description, meaning she believed the duties she performed were part of her role and responsibilities.

It acknowledged failings by Dr Momoh’s employer to monitor and make clear her job role, that she was not challenged on the errors by the trust, and that she never received a complaint about her care.

The panel also took into consideration her immense contributions to the field of FGM and to raising awareness of it.

Despite these mitigating factors, she was suspended for six months on public interest grounds.

A consultant obstetrician at a neighbouring hospital trust first referred Dr Momoh to NMC’s fitness to practise procedures in August 2017, a few weeks before she retired from her post.

She was accused of practising outside the scope of her practise or role on dozens of occasions, and in particular that she performed duties reserved for a registered nurse, when her nursing registration had lapsed in 2013, leaving her exclusively a registered midwife.

An investigation was then opened into Dr Momoh, which led to the NMC bringing allegations of misconduct involving almost 200 patients against her.

The NMC claimed, and the fitness to practise panel agreed, that she had committed misconduct, acting outside of the scope of her role by accepting referrals and examining patients who were under the age of 18 and not pregnant.

The panel also found that she administered medication to various patients which she lacked a prescriber qualification for – and which were not on the list of reserved medications for midwives.

Further, it was agreed by the panel that she had made numerous failings in patient record keeping over the years.

These included failing to record risk assessments, not recording communications with other professionals, failing to maintain adequate clinical records for patients and other paperwork errors which the panel felt “potentially put patients at risk” of harm. 

Dozens of other allegations were put against Dr Momoh surrounding the scope of her practise, but they were dismissed.

For many, it was deemed there was no case to answer for them. For others, the panel said the facts were not proved because it was in the scope of her practise, or because of a lack of evidence the incidents took place.

For example, it was argued by the NMC that Dr Momoh had acted outside of her role’s scope by accepting and examining adult patients who were not pregnant and performing de-infibulation and smear tests on non-pregnant women.

This, the NMC alleged, all fell under the scope of a nurse, which by 2013, Dr Momoh was no longer registered as.

But the panel found “no clear unequivocal evidence” that Dr Momoh had acted outside the scope of her role in relation to adult non-pregnant women, and said part of the issue was that her employer had failed in its duty to define her job and properly oversee AWWC.

“We apologise that our governance practices so clearly fell short in this case” Guy’s and St Thomas’ spokesperson

Witnesses testified in favour of Dr Momoh’s clinical competence in such procedures.

Other dropped charges included allegations that Dr Momoh had worked outside the scope of her clinical competence by giving psychological or psychosexual counselling and that she had failed to refer patients to specialists.

Further charges were proved, but the panel felt that they did not amount to misconduct, or did not mean her practise was impaired.

In deciding what sanctions to issue, the panel took into account the highly vulnerable nature of AWWC’s FGM patients and the fact that Dr Momoh had used her ‘Doctor’ title – an honorary one given to her from Middlesex University – in communication with professionals, possible leading to “confusion” over her qualifications.

In mitigation, the fact that Dr Momoh is “world renowned” for her FGM work and had led an otherwise unblemished 35-year nursing and midwifery career was noted by the panel.

The fitness to practise report stated that Dr Momoh had “helped raise the awareness of FGM nationally and internationally”.

The hearing documents referred to governance over AWWC, and over Dr Momoh, being “not adequate” in terms of overseeing her role.

Dr Momoh’s line manager, the panel heard, had never seen her in a clinical setting at AWWC and there was “no evidence” of robust supervision or appraisals.

“Throughout the time covered by the charges, [Dr Momoh’s] role in the AWWC appears to have been completely devoid of any adequate and necessary supervisory oversight,” the report stated.

After the publication of the report, a spokesperson for Guy’s and St Thomas’ said: “We apologise that our governance practices so clearly fell short in this case.

“Since the Nursing and Midwifery Council investigation started six years ago we have implemented steps to address this and will now review the final report.”

The panel also acknowledged that Dr Momoh had insight into her actions and that she had “clearly learned” necessary lessons to reduce the risk of repetition.

The panel issued Dr Momoh a six-month suspension from the NMC register, prohibiting her from practising as a midwife for that time.

Nursing Times made attempts to contact Dr Momoh for comment.

By Edd Church, Nursing Times

20 June 2024.