More information on PAs and AAs

Benefits of regulation

As for doctors, regulation will:

• assure patients, employers and colleagues that PAs and AAs are safe to practise and can be held to account if serious concerns are raised
• allow us to set standards, issue guidance or call on other organisations to act, to promote patient safety. One way we’ll do this is by updating our clinical governance guidance for employers to make the principles applicable to PAs and AAs in the workforce
• enable us to quality assure (QA) the education the PAs and AAs receive. Working with medical royal colleges and other key stakeholders, we’ve overseen the development of updated curricula and registration assessments for PAs and AAs. We’ve also begun to QA courses for PAs and AAs, by applying our education standards. These measures will ensure PA and AA graduates are fit to practise and able to deliver service needs.

How PAs and AAs will be regulated

Our work to introduce regulation of PAs and AAs is wholly funded by direct grant from the DHSC and closely managed to ensure no cross-subsidisation from doctor fees.

Regulation will be proportionate to the size of the professions, their roles and responsibilities.

Our preparations are well advanced. The model of regulation will be similar to that for doctors, with policies and processes covering registration, revalidation, professional standards, education and fitness to practise.

As we do for doctors, we’ll:

• set standards and outcomes for initial PA and AA qualifications, and check PAs and AAs meet those to join our register

• set professional standards, and provide guidance, for PAs and AAs in practice

• seek assurance about registered PAs and AAs through revalidation

But there are important differences in the scale and scope of our activity.

• For example, initially at least, we won’t regulate or set standards for any training that PAs and AAs might undertake after joining the register, in the way we do for doctors.

• While we see benefits to establishing more structured frameworks for post-qualification development of PAs and AAs, we are not currently resourced to design or regulate these.

As with our regulation of doctors, we won’t set hard boundaries for a PA’s or AA’s scope of practice. This will be for employers and medical royal colleges and faculties to define.

We encourage these organisations and national workforce bodies to work together to set out:

• how PAs and AAs fit within multi-disciplinary team models

• how PA and AA scope of practice and roles can develop after initial qualification

• how PA and AA roles will develop over time.

Recent issues

The current debate

We’re aware that there are ongoing discussions in a range of forums about the roles played by PAs and AAs in the UK’s health services. It’s been disappointing to see the tone and language used in some of these exchanges, and we recognise the impact this can have on individuals, teams and public perception.

Many of the issues being raised are complex and are for employers, trade unions and medical royal colleges to address, including those related to doctors’ terms and conditions.

We’ve involved a range of stakeholders through our expert advisory forum and our community of interest as we’ve developed the policies and process needed for future regulation. This input and advice have allowed us to make considerable progress which we share publicly in the PA and AA hub and continue to keep under review to allow us to respond to the feedback we receive that relates to what is within our remit.

Trainees and postgraduate training

There are significant pressures on training capacity and trainees in the current environment. It should be recognised this situation has multiple causes.

We hear trainees when they say local choices about deployment of PAs and AAs sometimes reduce their access to learning opportunities. But there is also evidence that, where managed well, PA and AAs may free up time for trainees to learn.

We are committed to ensuring high quality postgraduate medical training across the UK: our annual national training survey and ongoing QA activity support this.

• We use responses from the survey to address any repeated problems in training environments. Where this is happening, we start a process where we work with postgraduate deans to resolve concerns.

• We also identify and act on UK-wide trends in collaboration with policy makers, employers, and health service leaders.

We don’t currently have any remit over post-qualification education and training for PAs and AAs. Even after regulation begins, we are unlikely to have the funding to regulate in that space for some time.

How PAs and AAs describe themselves

PAs and AAs are distinct professions. They are not doctors.

As regulated professionals, PAs and AAs will have a responsibility to clearly communicate who they are, and their role in the team, just as doctors must do now. In Good medical practice 2024 we say: “You must always be honest about your experience, qualifications, and current role.”

New guidance on ‘titles and introduction’ from the Faculty of Physician Associates (FPA) gives PAs, supervisors, employers and organisations a structured and standardised way of using the physician associate title and highlights the importance of explaining it.

If someone is falsely using a protected title or implying they are a licensed doctor when they are not, we have powers to act. These range from sending cease and desist letters to a referral to the police. Anyone can report a concern about unregistered medical practice using the information available on our website.

The names of the professions

We have no remit over job titles. The terms ‘physician associate’ and ‘anaesthesia associate’ came into use in the UK some years ago and the DHSC intend to legislate on that basis to make these protected titles.

Patient safety and patient understanding are important. Patients should always be clear on who they’re being treated by. We welcome the new guidance from the FPA and the conversation this has started.

When writing about or addressing PAs, AAs and doctors, we use the three distinct names of each profession, except on rare occasions when it makes sense to use a single umbrella term.

• For example, for ease of reading, we use the term ‘medical professionals’ in the updated Good medical practice, because the professional standards will apply to all three groups once regulation begins.

Future format of the register and GMC numbers

Once regulation begins, the name and profession of individual registrants will be displayed on the medical register.

Anyone looking at the register will be able to clearly see whether a registrant is a PA, an AA, or a doctor. It will be possible to search by profession type and filter results to look at doctors alone, PAs alone, AAs alone, or all professions together.

PAs and AAs who register with us will receive a seven-digit number in the same format as a doctor. However, we’ll be clear that this does not mean that PAs and AAs will have any of the privileges of being a licensed doctor, including the ability to prescribe.

To maintain and operate three separate online registers would be costly for the GMC and difficult for users to navigate.

• Both the General Dental Council and the Nursing and Midwifery Council (NMC) use a common registration number format for their different professional groups and allow users to search across all professions. For example, nurses, midwives and nursing associates are all searchable on the NMC’s online register.

Routes to registration from the PA and AA voluntary registers

All PAs and AAs seeking to join our register must meet the necessary standards.

There is no automatic transfer from voluntary registration. We will check each PA’s and AA’s qualification and require them to provide a work history and employer reference and complete a fitness to practise declaration.

We will verify qualification and assessment details for PAs and AAs on the FPA or the Royal College of Anaesthetists (RCoA) voluntary registers, prior to inviting them to apply for registration.

PA and AA scope of practice

We have worked with stakeholders to publish an education framework – including outcomes, curricula and registration assessment specifications – that defines the capabilities required of newly-qualified PAs and AAs. This will come into effect when regulation starts.

Currently PAs and AAs develop their skills and scope of practice over time in response to service demand. This is managed at employer level because standard deployment and development models for these professions do not yet exist. So safe practice relies on professional behaviours and open communication within teams.

When regulation begins, PAs and AAs will be required to follow the duties set out in Good medical practice 2024, including practising only within their competence.

If a doctor is unsure about a PA's or AA's scope of practice, they should ask them or speak to their department head. Employers are responsible for ensuring that PAs and AAs are inducted appropriately and that everyone in the team understands their roles.

Supervising PAs and AAs

As with other professionals that doctors supervise and work alongside in multi-disciplinary teams, doctors are not accountable to us for the decisions and actions of PAs and AAs, provided they have delegated responsibility in line with our guidance.

Doctors are responsible for all prescriptions and ionising radiation requests that they sign. Our guidance says that doctors must only prescribe medicine or treatment when they have adequate knowledge of the patient’s health and are satisfied that the medicine or treatment serve the patient’s needs.

The cost of regulation

The GMC agreed to take on regulation of PAs and AAs on the condition that no additional costs would fall on doctor registrants. We invoice the DHSC for all costs arising from our work on PAs and AAs and will continue to do so until these are covered by PA and AA registration fees.