A motion of regret is respectfully requested for the legislation laid down by Statutory Instruments in the House of Commons in December 2023, putting in place regulation of Physician Associates (PAs) and Anaesthetic Associates (AAs) by the General Medical Council (GMC) (Health and Care Act 2022).

The Department of Health and Social Care (DHSC) state that the GMC will set standards of practice, education, training, and operate fitness-to-practise procedures, ensuring that PAs and AAs have the same levels of regulatory oversight and accountability as doctors and other regulated healthcare professionals. 

However, this is in fact not the case. The GMC adopts standards and competencies for doctors from their relevant Colleges who oversee post graduate education and training. PA and AAs, who qualify after 2 years of university education, have no such processes in place nor are there equivalent plans ahead save for a consultation process that will report at the end of 2024. The outputs of the consultation are less than clear. The GMC issued a statement on 24 October 2023 stating that it “won’t regulate or set standards for any training that PAs and AAs might undertake after joining the register” nor will it “regulate or set standards for any training’. Who therefore is responsible for these standards?

Currently PAs and AAs are being appointed to posts equivalent to a General Practitioner or into any hospital speciality, and further they can switch between specialities as they choose. They carry out unsupervised one-to-one consultations in general practice, are being substituted into hospital rota gaps, previously deemed only suitable for doctors.

Furthermore, the scope of practice of the Practitioners is currently determined by where Trusts and GP practices find need, encouraged by perverse schemes, such as ARRS funding, that encourage their recruitment whilst doctors face unemployment. A quick search of NHS Jobs will find posts being advertised for PA roles in orthogeriatics, specialist mental health, and paediatric surgery for starters. They can work in these roles straight after graduation again perversely paid sometimes double their junior doctor counterparts with no requirement to work nights or weekends. While currently they are not allowed to prescribe or request ionising radiation, there is overwhelming evidence that CQC/MHRA guidelines on prescribing practices, and IRMER legislation regarding the ordering of ionising radiation is being ignored. For the avoidance of doubt there is no shortage of doctors but there is a shortage of funds to employ doctors where they are needed.

All PA patient assessment and care is, as set out in the GMC Good Medical Practice 2024, supposed to be overseen and supervised by a named doctor. There is again overwhelming evidence that this supervision is largely ad hoc, in name only and often absent. PAs job descriptions, social media posts and advocates conversely describe their ‘autonomous role’, acting up to consultant level care in many instances. Most doctors do not know that, in law, they are responsible for PA care they may not even know is happening. Most doctors furthermore do not have any time built into their job plan to carry out this time-consuming task. A bizarre example of this involved a GP calling an on-call Paediatrician asking advice for their patient. The ‘On call Paediatrician’, giving specialist advice was in fact an unsupervised PA. The advice was incorrect, the patient care was compromised, but the GP was held responsible as the ‘supervising doctor’. Numerous surveys, including one by the BMA, find the majority of respondents stating that the way AAs and PAs currently work in the NHS was always or sometimes a risk to patient safety.

Of further concern is emerging evidence that many doctors in training are reporting that tasks and procedures, which they need to practice repeatedly, are being reallocated to PAs/AAs. There are numerous incidences of PAs allocating routine and administrative tasks to doctors in training, whilst the PA is attends training in surgical theatres or outpatient clinics. Such scenarios are a complete inversion of the intention that PAs undertake routine tasks to support and enable doctors to take advantage of training opportunities. The future implications for the next generation of highly trained medical professionals are profound. In some cases, the PAs/AAs undertaking these procedures do not themselves appear to have been adequately trained.

Lastly and of perhaps the highest importance is the plain fact, reported by doctors and patients alike, that patients and the wider public are not aware of the difference between these roles, with many thinking they are seeing a doctor when they are not. Patients and families should know the capability of those who meet and treat them. In the midst of a workforce crisis, these professionals seem to provide a solution to boost staff numbers. We recognise the skills and contributions of Pas and AAs within our health service, but it must not be at the expense of fully trained doctors. Careful evaluation of the role of PAs and AAs is needed to ensure clinical effectiveness without negative impacts on patient safety, quality of care and health outcomes. We need clear standards around training and supervision, and a clear regulatory structure, provided by a non-GMC regulator to avoid blurring lines between PAs, AAs and doctors. We also need robust qualitative and quantitative data for outcomes from these new professional roles.

Blurring the roles between doctors and non-doctors, presents the most significant risk to patient safety. This piece of legislation will detrimentally change patient care in our NHS, and the vast majority of the public are unaware. We urge the government to scrutinise healthcare policy in the same way we scrutinise new medicines or treatments before rolling them out

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