Specialist FGM midwife fitness to practise impaired on public interest grounds

Dr Comfort Momoh (honorary title) was employed as a specialist Female Genital Mutilation (FGM) midwife working within the London Guys and St Thomas’ NHS Foundation Trust FGM clinic, London. She commenced employment at the Trust in 1997 and remained employed there until her retirement on 31 August 2017. During that time she set up the African Well Women Clinic (AWWC) at the Trust and had published articles and spoken about FGM in the UK and abroad.

Wikipedia lists Comfort Momoh’s many awards. In the 2008 New Year Honours, she was appointed a Member of the Order of the British Empire (MBE) for services to women’s healthcare. She was awarded an honorary doctorate from Middlesex University in 2008. In 2011, she won a Gathering of Africa’s Best (GAB) award. She was chosen as 2015 Alumna of the Year by King’s College London, and in 2016, she was awarded a fellowship by the Royal College of Midwives.

On 8 August 2017, the Nursing and Midwifery Council (NMC) received a referral from a consultant obstetrician at University College London Hospitals (UCLH). Following this referral, the Trust conducted internal reviews of her caseload and commissioned an external review by the Royal College of Paediatrics and Child Health (RCPCH) into her practice. The reviews identified concerns surrounding her practice.

A BBC Newsnight investigation in September 2017 revealed concerns about aspects of her work. They were also reported by The Daily Mail.

A Fitness to Practise Committee of the NMC deliberated on Dr Momoh’s misconduct case between May 2022 and June 2024. The 604 page report can be accessed here.

The regulatory concerns broadly covered three separate areas; 

• that she acted outside her scope of practice and/or her professional competencies
• that she failed to appropriately refer patients onto other medical or health care professionals and
• failures in record keeping.

1. ‘In relation to the first regulatory concern, it is alleged that you assessed and examined non-pregnant children without the appropriate paediatric training or qualification. It is also alleged that you assessed and treated non-pregnant women, when you were not a registered nurse. It is further alleged that you administered prescription only medication, other than those within the midwifery exemptions, when you were not a non-medical prescriber. You do not deny that you treated the patients but deny that this was outside of your scope of practice/competencies.

2. The second regulatory concern is linked to the first in that it is alleged that you should have referred the patients to someone who could treat them within the scope of their competence. The concern relates to failing to seek a second opinion in complex cases, failing to appropriately refer patients for psychosexual/sexual health counselling and support, failing to redirect/refer children to a paediatrician, failing to refer for urological/gynaecological review and failing to refer to an appropriately qualified practitioner.

3. The final regulatory concern relates to alleged failures to keep adequate records. These relate to not recording information in the correct documents/format, not recording information accurately/fully, not recording consent, not recording the presence/offer of a chaperone, not recording the use of an interpreter/translator, not completing/sending GP summary letters or other outcome letters or sending these letters with incomplete or inaccurate information, and not recording appropriate safeguarding steps.’

Within the report each concern is outlined in detail as is the rationale for the Committee’s findings. 

Findings

The panel determined that a finding of impairment on public interest grounds is required in respect of her misconduct in relation to examining and assessing children and inadequate record keeping. The misconduct is so serious due to the potential risk of harm to patients.

The panel determined that a finding of impairment on public interest grounds is not required in relation to the administering medication to adult patient/non pregnant patients without a prescription.

‘Your conduct was over a substantial period of time with a significant amount of evidence in relation to the deficiencies in your practice.’

The panel reached this conclusion notwithstanding giving her full credit for the fact that this case has taken some seven years to reach this stage of proceedings and what Ms Bayley (legal representative) has appropriately referred to in her submissions as “the legacy of [your] life’s work”.

The panel was satisfied that a reasonable, well-informed member of the public would expect nothing less than such a finding of current impairment on public interest grounds, notwithstanding the length of time the proceedings have taken and the personal and financial impact this may have caused.

The panel concluded that public confidence in the profession would be undermined if a finding of impairment were not made.

Having regard to all of the above, the panel was satisfied that Dr Momoh’s fitness to practise is currently impaired on public interest grounds. They made a suspension order for a period of six months. The effect of this order is that the NMC register will show that her registration has been suspended.

22 June 2024

A Nursing Times report Celebrated FGM specialist suspended from NMC register can be accessed here.