The Royal College of Physicians and Faculty of Physician Associates response to the government’s consultation on regulating physician associates

The government published a consultation on the draft legislation to bring anaesthesia associates (AAs) and physician associates (PAs) into regulation in February 2023. The consultation is the first step towards the government’s ambition for PAs to be fully regulated by the General Medical Council (GMC) by the end of 2024.

The RCP and FPA have long called for the regulation of PAs to enable the profession to fulfil its potential and maximise its contribution to patient care as part of the multidisciplinary workforce.

While the legislation – the ‘Order’ – will apply to AAs and PAs in the first instance, it will be used as a template for future reforms for doctors and other healthcare professionals. The consultation notes that it “paves the way for reforming the regulatory frameworks for all healthcare professional regulators.”

The main points of the joint RCP FPA response were:

• regulation is a positive and required step for PAs. We look forward to engaging with the GMC to ensure the parameters of associates’ practice, including where ongoing supervision is required, are clear to professionals and patients.
• we would welcome clarity and a timeline for when doctors can expect to be regulated under the same regulatory model.
• we welcome that the national curriculums will still be owned, developed and maintained by relevant Royal Colleges and Faculties, with the GMC playing an approval role. Royal Colleges and Faculties have a unique expertise in developing and designing appropriate curricula and relevant associated post-graduate assessments for the members they represent and as such should retain responsibility for them. 
• we would prefer to see the current six GMC fitness to practise grounds, or at least a distinct adverse health ground, maintained. The legislation sets out new grounds for action: inability to provide care to a sufficient standard or misconduct.
• we support a three-stage fitness to practise process.
• we believe there should be adequate and appropriate clinical representation, including AA and PA representation, on fitness to practise panels and in shaping the initial assessment stage of the three-stage fitness to practise process.
• we believe any future public facing medical register should make clear to the public that doctors, AAs, and PAs are distinguishable groups.
• we support that the pre-registration assessment will become one of the requirements for PA registration with the GMC and the move to a revalidation process to ensure that AAs and PAs remain fit to practise. It is key that PAs have sufficient time in job plans to undertake continuing professional development (CPD) and provide wider evidence for appraisal and revalidation, for example evidence of learning from safety incidents and evidence of multidisciplinary working, as well as any other elements pertinent to an individual’s professional portfolio such as education or research.
• we welcome that government expects PAs to be able to order ionising radiation once they are regulated, registered with the GMC and have completed the appropriate training. 
• we also welcome that the government supports the principle of extending a form of medicines mechanism for both professions. To maximise the potential of PAs in the UK, the time period between regulating PAs and extending them prescribing rights must be as short as possible. We look forward to continuing to engage with relevant stakeholders on this issue.
• while we understand that it is not a consequential amendment covered by this Order, we hope PAs will be considered for any further extensions to the eligible healthcare professionals able to issue fit notes once they are a regulated profession.
• we welcome powers for regulators to act more flexibly, backed up by proper transparency and accountability. We support a more flexible approach to regulation and recognise that rule making powers will enable the GMC to adapt to changing circumstances over time.  

Read more about the RCP FPA #RegulatePAsNow campaign.