GMC Regulation of PAs and AAs: A Step Forward or a Step Too Far?

The General Medical Council (GMC) is now the official regulator for Anaesthesia Associates (AAs) and Physician Associates (PAs), following a public consultation held by the previous government. This move is in line with the NHS Long Term Workforce Plan, which aims to increase the number of PAs to 10,000 and AAs to 2,000 by 2036/37. However, it comes at a time when these roles are under intense scrutiny. Health Secretary Wes Streeting recently described the debate around PAs and AAs as “toxic” and ordered a government review to address concerns about their use in the NHS. The review will focus on the scope of these roles and ensuring patients clearly understand when they are interacting with a PA or AA rather than a doctor.

Public Concerns and Legal Challenges

The regulation of AAs and PAs by the GMC has sparked heated debate, particularly among medical professionals. As anyone who spends time on MedTwitter will know, the presence of PAs in the NHS workforce has drawn strong opinions, with many questioning whether their roles are being properly defined and regulated.

The British Medical Association (BMA) and Anaesthetists United (AU) have each launched judicial review proceedings against the GMC, raising critical concerns about safety, clarity, and accountability.

The BMA’s judicial review focuses on the following issues:

1. The GMC’s decision to apply Good Medical Practice (GMP) equally to AAs and PAs, which the BMA argues fails to consider their distinct training and responsibilities.
2. The use of the term “medical professionals” to collectively describe doctors, AAs, and PAs, which the BMA contends blurs the critical distinction between doctors and associate professionals, potentially confusing patients and jeopardising safety.

You can read the GMC’s response to the BMA’s threat of legal action here.

Anaesthetists United’s legal challenge highlights several specific concerns:

1. The lack of adequate scope-of-practice guidelines to clearly define the tasks AAs and PAs may perform safely and lawfully.
2. The absence of proper supervision protocols to ensure these professionals are appropriately monitored by qualified clinicians.
3. The failure to establish clear measures to ensure informed patient consent, so that patients fully understand when they are being treated by an AA or PA rather than a doctor.
4. The need to integrate these safeguards into the fitness-to-practise (FTP) system to protect patients and address potential risks effectively.

You can read the letter before action in full here.  

A Growing Workforce but Lingering Gaps

AAs and PAs have been practising in the NHS since 2002 and 2004, respectively, and their roles include taking medical histories, conducting physical examinations, organising diagnostic tests, and assisting doctors in surgery or anaesthesia. Despite their growing presence, some commentators argue that there are significant regulatory gaps and express concerns about whether their roles are sufficiently defined to ensure patient safety.

The Tragic case of Emily Chesterton underscores these worries; Emily, who was 30 years old at the time of her death, was misdiagnosed with anxiety and a sprain by a PA, whom she believed to be a doctor. She later died of a pulmonary embolism. At her inquest, the coroner concluded that Emily should have been immediately referred to A&E, where timely treatment for a pulmonary embolism would likely have saved her life. Emily’s Mother argues that the incident highlights the urgent need for clearer distinctions and stronger safeguards to protect patients.

Implications for Fitness to Practise

The GMC’s regulation of PAs and AAs brings potential challenges for the fitness-to-practise system; the addition of AAs and PAs could place extra pressure on the system. With an increase in caseloads likely, there may be a need for additional resources, more case examiners, and potentially new procedures tailored to these roles. 

The debate over the GMC’s regulation of AAs and PAs reflects broader tensions about the evolving roles within the NHS. While the healthcare system undeniably needs more skilled workers, it is essential for the GMC and the Department of Health to address the concerns raised by medical professionals. Clear scope-of-practice guidelines, proper distinctions between professional roles, and robust FTP processes are critical for maintaining patient trust and safety.

As this transition progresses, all eyes will be on the GMC to ensure these changes are implemented effectively.