Back in April, the Nursing and Midwifery Council (NMC) launched a consultation on changes to the education standards they look after, with a focus on practice learning.
One proposal pulls nursing programme hours down. The other pushes midwifery programme length up. It’s the latter that feels like it’s about to run into problems.
The headline nursing proposal is to reduce minimum pre-registration programme hours from 4,600 to 3,600, retaining the 50:50 split between theory and practice.
Practice learning would therefore drop from around 2,300 hours to 1,800 hours, and theory would mirror it. Nursing associate programmes would stay at 2,300 hours. Simulated practice learning would be capped at 25 per cent of the total. Community placements would be required.
The NMC’s framing is a move from an “hours-led” to a “quality-led” model. The 4,600 figure, it says, is a hangover from EU Directive 2005/36/EC, which no longer applies to the UK.
Globally, things are wildly variable – roughly 700 practice hours in the US, 800 in Australia, 1,100 in New Zealand. With less hours-bashing to meet, the argument runs, providers can design more thoughtful programmes and students will spend less time being used as free healthcare assistants.
You can spot a tidy bit of credit logic underneath it. In England, Wales and Northern Ireland, an Honours Bachelor’s degree is 360 credits. On the standard tariff, that’s 3,600 notional learning hours. The NMC has noticed that 4,600 hours is 1,000 hours more than a standard degree. So 3,600 is what you get if you stop demanding more of nursing students than the academic credit framework recognises.
The reaction has been split. Newly qualified nurse Reagan Fletcher told Nursing Standard placement “nearly broke me” because of the impossibility of balancing full-time placement, academic deadlines and paid work just to afford rent.
Lorraine Black, on Facebook, said cutting 1,000 hours of learning would not improve nursing standards but destroy public confidence. Critical care nurse Rosie Thompson noted, drily, that nursing was:
…the only profession where people argue that less education will make us better at our jobs.
The Royal College of Nursing’s (RCN) Will Malcher said he wasn’t convinced the NMC has actually shown the evidence for why this should happen, pointing out that UK programmes are already shorter than those in much of Europe and Asia. University of Lancashire associate dean Tyler Warburton said:
“Driving up student numbers, lack of placement capacity and the financial burden on students are all valid reasons to suggest reducing the hours, but they’re not particularly talking about the impact this will have on student learning. If the proposals were about making a sweep of structural changes on how to improve learning then that would be okay. But it’s not and that makes me nervous.
To put it another way – there’s a perfectly good argument for cutting hours, but it isn’t the one the NMC is making. A better version would say students are being treated as unpaid labour while the placement system buckles under capacity pressure and a cost-of-living crisis the loan won’t cover. Shout out to Essex SU’s Pay the Placement campaign, by the way.
The NMC’s version says the regulatory model needs to be more “outcome-focused”, which sounds nicer, but doesn’t tell you why now and doesn’t address whether the supervision and teaching capacity exists to make 1,800 hours actually count.
The midwifery extension
Meanwhile, the midwifery proposal is to increase the minimum length of pre-registration midwifery programmes from three years to four. The 4,600-hour requirement and the 50:50 split would stay, but students would have four years to do them rather than three.
The rationale here sits in post-Ockenden, post-Kirkup territory. Maternity safety inquiries across the four nations show Black women three times more likely and Asian women 1.3 times more likely to die during pregnancy or postnatally than White women, Black babies twice as likely and Asian babies 50 per cent more likely to be stillborn.
Add to that the NMC’s own Spotlight research finding that newly registered midwives often felt underprepared for emergencies, plus stakeholder feedback that the current three-year structure produces “task-oriented learning” (chasing the 40 births) rather than continuity of care.
So the diagnosis is that midwifery students need more time – time to repeat skills, time to consolidate, time to encounter different birthing populations, time for “reflection, rest and recuperation”. And the proposal also adds a final-part placement of at least eight weeks.
The odd thing is the contrast. For nursing, fewer hours produces better learning because the regulator stops fetishising hours. For midwifery, more time produces better learning because the regulator notices that hours alone aren’t enough. Either it’s about hours or it isn’t, surely?
Many would argue that the two professions are different and the diagnoses are different. But the consequence is that the NMC is simultaneously deregulating one programme and lengthening the other, and only one of them comes with a proper answer to the question of who pays for it.
The NMC, to its credit, says so. Buried in the consultation document:
Extending midwifery programmes would have implications for many students, including financial impacts and additional student loans. There would also be costs to the system in giving students an extra year to qualify, and these proposals will, as a result, require further work to understand policy, workforce and financial implications, should the consultation outcomes support any changes.
My husband is paying the mortgage
Which brings us to the people who’d actually have to live with it.
The Royal College of Midwives (RCM) State of UK Midwifery Student Finance survey, in 2023, drew over 1,000 responses from a workforce that – as the RCN’s own research consistently shows for nursing too – is overwhelmingly mature, female, often with children, and disproportionately reliant on a partner’s wages or benefits to make the maths work.
The RCM’s headline numbers from England were miserable. Nearly three-quarters of midwifery students surveyed expected to graduate with debts of more than £40,000. Almost half had a paid job to earn money, and said it had a negative impact on their studies. Nine out of ten worried always or often about the amount of debt they were in.
Eight out of ten had taken on additional debt over and above the standard loans. Over three-quarters worried they’d drop out for financial reasons. Ninety-one per cent knew at least someone who had.
The case studies are painful to read:
All financial income comes from myself. This means that while on placement I do full-time placement hours plus additional shifts which on occasion means I work 70 hours a week.
The bursary and student maintenance loan cancel out any benefits I can get as my partner’s income is apparently too high, although he’s only on £29k. Also, I get no childcare help with this because of the threshold for income being really low. So between us, to pay bills, childcare etc, I have to work bank shifts to make at least an extra £400 a month to be able to pay my childcare bill.
Although I feel grateful to be receiving a bursary at all, £400 per month is simply not enough to live on, especially given that we are working upwards of 35–37.5 hours per week on placement. On clinical placements, we often work over our hours, unsocial hours and public holidays for no pay. This leaves many of us in a position that warrants working another part-time job and I myself often find my working hours totalling upwards of 60 hours per week.
The point is that the financial system already barely holds three years of compulsory clinical placement together, and it does so partly by relying on partners, parents and food banks to absorb the shortfall:
[financial support] is not enough to survive on in the current crisis. I sometimes don’t attend days on campus because I cannot afford to pay for public transport. Sometimes I skip a meal or buy only in the clearance section of the supermarket to make it to the end of the month.
The political question for the NMC’s four-year proposal is therefore not really whether more time would improve confidence and competence. The question is whether the people who put their lives, mortgages and childcare on hold for three years will do it for four. And where they do, how many make it out the other end.
UCAS and RCN evidence already suggests the demographic the system most depends on – mature, often domiciled near home, often with caring responsibilities – is the one walking away. Domestic UK applicants to nursing courses fell from 53,280 in 2021 to 37,170 by the June 2025 deadline. The midwifery picture is less robustly polled but moves in the same direction.
Adding a fourth year of foregone earnings, additional debt, additional placement travel, additional childcare and additional benefit interactions to a programme already producing the testimony above runs straight into the RCM’s February 2026 finding that 31 per cent of newly qualified midwives with a PIN hadn’t yet secured a post. The system can’t reliably employ the midwives it already produces. Asking them to study a year longer to enter that same market is a hard sell.
The credit problem
And then there’s the LLE. From January 2027, fee limits under the Lifelong Learning Entitlement (LLE) will be based on credits, not academic years. Fees, and so university funding, are credit based. Maintenance also gets chunked down depending on the number of credits studied.
So the unavoidable question for a four-year midwifery programme is whether it would be a 480-credit course or a 360-credit course. The NMC consultation is silent on it, but the framing strongly suggests the latter – same hours, same award, same credit volume, just spread over four years.
If that’s right, the financial implications are not subtle. Across four years at 90 credits a year, the English tuition fee loan would be roughly 4 × £7,342.50 = £29,370, the same total fee envelope as 3 × £9,790. The provider would receive less per year while incurring an extra year of delivery, placement administration, supervision, estate use, support and regulatory burden.
Maintenance, calibrated to credits studied per year, would also fall. The student would experience four years of rent, travel, childcare and foregone earnings. The finance system would see only three years’ worth of credit.
The better (more debt) alternative would be a 480-credit four-year midwifery degree. That fits the LLE entitlement. It would also mean redesigning the qualification – more credit, more academic content, possibly a different exit award, possibly an integrated master’s. Which is more or less what the consultation’s chosen comparators have done.
The NMC names the University of Leicester’s Midwifery with Leadership MSci as an existing UK four-year midwifery programme. But it is not a 360-credit BSc spread over four years. Leicester’s specification is a 480-credit integrated undergraduate master’s, with years 1, 2 and 3 at levels 4, 5 and 6 (120 credits each) and a final year at level 7 (a further 120 credits). The exit award after three years is a non-NMC-registrable BSc in Healthcare. The fourth year carries the NMC registration outcome and is a master’s-level leadership year.
The Leicester programme also requires 4,800 hours of study, split 2,400 theory and 2,400 practice, going beyond the NMC’s 4,600 baseline.
In other words, Leicester’s solution to the four-year midwifery problem is to add 120 credits of level 7 content and call it leadership. It is structurally different from – and a different qualification to – what the NMC seems to be implying for the sector at large. Citing it as a precedent is fine if the proposal is “build a 480-credit integrated master’s”. It is misleading if the proposal is “spread the existing BSc over four years”.
The NMC also names the Republic of Ireland and France as international comparators. Both, if anything, point even more further away from where the NMC is heading.
In Ireland, an Honours Bachelor Degree at NFQ Level 8 requires 240 ECTS across four years – not 180. Irish midwifery is genuinely longer in academic credit, not just in elapsed time, with all four years combining academic study and clinical practice and the final year built around a 36-week internship.
In France, the situation is even more divergent. The Diplôme d’État de Sage-femme is reached through four years of midwifery study (240 ECTS) following a one-year health studies access route, making it five years post-baccalaureate. Output is a Bac+5 master’s-level qualification, with 180 ECTS at first cycle (DFGSMa) and a further 120 ECTS at second cycle (DFASMa).
If anything, the international comparators the NMC has chosen suggest the only proper version of a four-year midwifery programme is a 480-credit, level-7-bearing one – which takes us back to the Leicester model and the LLE entitlement, and away from the cheaper “spread the BSc thinner” version.
Medical architecture
There is of course an obvious adjacent precedent for funding a regulated, longer-than-ordinary professional degree. For a five-year undergraduate medical degree in England, Student Finance England funds tuition fee and maintenance loans in the earlier years, and then the NHS Bursary scheme takes over for the later clinical years. Medicine has an explicit, settled, longer-course funding architecture. Department for Education (DfE) handles the bachelor-equivalent tuition and ordinary maintenance. The Department of Health and Social Care (DHSC), via NHSBSA, picks up the years that exceed the ordinary entitlement, with a different funding mix and direct fee payment to the institution.
It doesn’t really work, but in principle the government has accepted, and Treasury has signed off, that some regulated professional courses can’t be funded inside the standard undergraduate envelope.
Midwifery, under the current proposal, has no such precedent. DfE has named “midwifery” as a priority subject for additional LLE entitlement, which matters for graduates and those with limited residual entitlement, and as one of the subjects eligible for modular LLE funding.
But there is nothing from DfE that addresses the specific case of a four-year, 360-credit midwifery degree carrying 4,600 hours, and no equivalent of the medicine year-five fee contribution.
Ironically, as I’ve argued before on here, if we ignore the tuition fees aspect for a minute and imagine that some sort of arrangement was made that recognises the pressures on these students and gives them 120 credits worth of maintenance a year for 90 credits of learning, that’s almost certainly a jolly good idea. But it would beg the question – why just midwives?
Alternatively, if the fix is “we’ll wedge more content in to make it 480 credits overall”, that’s more pressure when the idea is supposed to be spreading out what’s there. It’s almost as if linking maintenance and funding to credit on a supposedly uniform basis, with bits of top up via OfS and the DoH doesn’t really work.
I’ll also be forgiven for being a bit baffled by the choreography. Fair enough – the NMC is the body that sets standards, and it’s under pressure to respond to Ockenden, Kirkup and its own research. But for all the stick they get, I can’t imagine OfS or QAA straight up consulting on requiring “4 year degrees” without having lined the funding ducks up first.
The triple bind
Which leaves the NMC, and any DfE/DHSC official watching this consultation, with a triple bind.
The current funding envelope is not enough to deliver three years of midwifery for either students or providers. The RCM’s evidence is overwhelming on the student side, with nearly three-quarters of English students expecting to graduate with over £40,000 of debt, eight in ten taking on additional borrowing, and a workforce that survives on partners’ wages, bank shifts and food banks.
On the provider side, the Council of Deans of Health has been warning for years about cuts, shrinking teams and fewer experienced educators, and the RCM has flagged that midwifery departments are facing the same pressures.
If the four-year programme is a 360-credit course spread over four years, it doesn’t work for either party. Providers receive less annual fee income while delivering an extra year of placement support and supervision. Students get an extra year of rent, childcare and unpaid placement, on a maintenance package potentially calibrated to a lower annual credit load.
If the four-year programme is a 480-credit integrated master’s – the Leicester model – then it works under LLE, but it’s a different qualification with a different entry threshold and probably different provider economics, and it doesn’t transparently solve the financial intensity question for the existing target demographic.
And if the four-year programme requires an extra funded year on top of the existing arrangements, the question is who pays for it. DfE, through additional debt? DHSC, through cash and bursary? Nobody, in which case it becomes whichever existing pot of money can be raided?
The line about “further work to understand policy, workforce and financial implications, should the consultation outcomes support any changes” is doing a lot of work. The NMC has set the regulatory direction without securing the funding architecture, and is hoping that the consultation buys enough time for somebody else to invent one.
The NMC consultation closes on 23 July, so there’s still time to ask the question that the document doesn’t quite ask. Are we changing the standard, or are we changing the funding model?
Because, however sensible funding-by-credit might look on a spreadsheet, applying it to regulated professional formation without an explicit override doesn’t work in real life.
And if there’s one workforce in the UK that already knows that, it’s the student midwives whose partners are paying the mortgage so they can do this in the first place.